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U.S. DEPARTMENT OF AGRICULTURE

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NATIONAL ORGANIC STANDARDS BOARD

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PUBLIC HEARING

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THURSDAY

APRIL 13, 2017

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The National Organic Standards Board 

convened via teleconference, at 1:00 p.m. EDT, Tom 

Chapman, Chairperson, presiding.
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BOARD MEMBERS PRESENT:

TOM CHAPMAN, Chair

ASHLEY SWAFFAR, Vice Chairperson 

SUE BAIRD

HARRIET BEHAR

ASA BRADMAN

JESSE BUIE, Secretary 

LISA DE LIMA

STEVE ELA

DAVE MORTENSEN

JOELLE MOSSO

EMILY OAKLEY

SCOTT RICE

A-DAE ROMERO-BRIONES

DAN SEITZ 

FRANCIS THICKE 

STAFF MEMBERS PRESENT:

MICHELLE ARSENAULT, Advisory Board Specialist

DR. JENNIFER TUCKER, Associate Deputy

Administrator

MARK BRADLEY, Assistant to the Deputy

Administrator 

DR. LISA BRINES, National List Manager

SHANNON NALLY YANESSA, Assistant Director,

Standards Division

DEVON PATTILLO, Materials Specialist, Standards

Division

MATTHEW PAVONE, Policy Analyst, Standards

Division

JESSICA WALDEN, Materials Specialist
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ALSO PRESENT:

COLIN ARCHIPLEY, Archi's Acres

KAREN ARCHIPLEY, Archi's Acres

HAROLD AUSTIN, Former NOSB Member

JULIA BARTON, Ohio Ecological Food and Farm 

Association

CARMELA BECK, Driscoll's

JANE BELL, Tide Mill Farm

COLEHOUR BONDERA, Former NOSB Member

STEVEN BRANCH, Zirkle Fruit Corporation

MARIE BURCHAM, The Cornucopia Institute

DOUGLAS DOOHAN, The Ohio State University

STEVE ETKA, National Organic Coalition

BARRY FLAMM, CCOF

JOE GABRIEL, Gilbert Orchards, Inc. 

AVIVA GLASER, National Wildlife Federation 

LYNNE HAYNOR, MOSA

ROBERT HOFFMAN, Shenandoah Growers, Inc.

CLAIRE JORDAN, Center for Food Safety 

THOMAS LAGINESS, BASF Corporation

KELSEY MABEN 

CECILLE MADRIZ, Fennel Farms

TIM MANN, Friendly Aquaponics, Inc. 

GUILLERMO MARTINEZ, Kingdom Fresh Produce

DAVEY MISKELL, Miskell's Farm

AMBER POOL, CCOF

MABELL RIVAS, QAI Inc.

GERRY ROBERTSON, Reiter Affiliated Companies

ANNE ROSS, The Cornucopia Institute

MARK RUSSELL 

DAMON SEAWRIGHT, AmeriCulture, Inc.

ZEA SONNABEND, CCOF

JANE SOOBY, CCOF

BILL STONEMAN, W.F. Stoneman Company LLC

SIMI SUMMER

KELLY TAVERAS, Organic Trade Association

ANDREW TOMES, WISErg Corporation
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CONTENTS

Introduction by Shannon Nally Yanessa ......... 6

Opening Remarks by Chairperson Chapman ........ 7

Public Comment ............................... 10

Adjourn ..................................... 165
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1 P-R-O-C-E-E-D-I-N-G-S

2 1:02 p.m.

3 MS. ARSENAULT: So we're going to start 

4 the call with an introduction by Shannon Nally 

5 Yanessa, who is the Standards Associate Director, 

6 and so welcome here. 

7 MS. YANESSA: Thank you, and welcome 

8 all to the NOSB public comment webinar. We are 

9 looking forward to hearing remarks from many 

10 members of the public who are interested in the 

11 activities of NOSB, National Organic Standards 

12 Board, and the National Organic Program.

13 Your input is a bit part of helping the 

14 NOSB prepare their recommendations to the USDA, and 

15 we really appreciate your participation here 

16 today. I would also like to recognize the NOSB 

17 members for contributing their time and focus and 

18 thought to prepare for the public meeting in 

19 Denver, which will take place next week. Thank you 

20 for your commitment. The NOSB members have 

21 challenging tasks.

22 And I also want to thank my colleagues 
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1 at the National Organic Program who provide 

2 critical support for the NOSB year-round, and in 

3 particular for these public comment webinars and 

4 the NOSB meetings. And now I will turn it over to 

5 Tom Chapman, who is the NOSB Chair. 

6 CHAIRMAN CHAPMAN: Thank you, Shannon. 

7 On behalf of the Board, I would like to welcome 

8 everyone to the public comment webinar prior to our 

9 spring meeting. This will be our fourth meeting 

10 with webinar, and I think everyone sees the 

11 tremendous value that an increased access to these 

12 web meetings brings. We're going to ask for some 

13 forgiveness up from everybody in communication. 

14 If we have any IT issues, again, please, please 

15 remember to keep yourself on mute.

16 For Board members, please remember to 

17 type in the question in the box if you have a 

18 question to ask a presenter. For public 

19 commenters, please remember to give your name and 

20 relevant affiliation for the record at the 

21 beginning of our comments. Please try to keep your 

22 comments to three minutes, and when you hear the 
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1 buzzer from Michelle, please finish your sentence 

2 so we can move on to questions or the next 

3 commenter. 

4 Now Michelle, can you read into the 

5 record the Board members present and program staff? 

6 MS. ARSENAULT: Sure. Thanks, Tom.

7 So on the webinar and the phone with us, 

8 we have Sue Baird, Harriet Behar, Jesse Buie, Tom 

9 Chapman, Lisa de Lima, Steve Ela, Dave Mortensen, 

10 Joelle Mosso, Emily Oakley, Scott Rice, A-dae 

11 Briones, Ashley Swaffar, and Francis Thicke -- and 

12 Dan Seitz is with us on the phone as well, so that's 

13 all 15 Board members.

14 And --

15 CHAIRMAN CHAPMAN: Actually, Asa 

16 Bradman is here too. 

17 MS. ARSENAULT: Oh Asa, I am so sorry, 

18 I skipped over you. Thank you. 

19 And there's several NOP staff members 

20 present on the call as well: Jenny Tucker, who is 

21 facilitating the call for us, thank you Jenny; Dr. 

22 Lisa Brines is on the call; Jessica Walden; Shannon 
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1 Nally Yanessa, who you heard from at the outset; 

2 Matt Pavone; and Devon Pattillo -- Pattillo. And 

3 if I missed anybody, I will catch up with you guys 

4 to make sure your name gets into the transcript.

5 And Tom, if you would just indulge me 

6 for seven seconds, I am going to set the timer off 

7 so people know what it sounds like. Let me know 

8 if you can hear it okay. 

9 CHAIRMAN CHAPMAN: Yes, sounds good.

10 MS. ARSENAULT: All right. 

11 Excellent. 

12 CHAIRMAN CHAPMAN: Okay. 

13 MS. ARSENAULT: Thank you. 

14 CHAIRMAN CHAPMAN: Thank you very 

15 much, Michelle. 

16 MS. ARSENAULT: And so any -- also, any 

17 logistics, again, Jenny mentioned several times 

18 that, you know, noise, background noise is a 

19 problem. We have heard conversations we probably 

20 shouldn't hear. So if -- it will make the process 

21 go much smoother if you can self-mute yourself, and 

22 you can do that by either hitting the mute button, 
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1 if you have a phone that has a mute button, or by 

2 hitting star 6 on your cell phone, and then you 

3 would push star 7 if you needed to unmute yourself.

4 We are going to try to leave the lines 

5 open if people can keep the background noise to a 

6 minimum. If not, then we will have to mute 

7 everyone from our end and unmute as we go along.

8 All right. I think -- I think that is it.

9 CHAIRMAN CHAPMAN: Okay. Thank you 

10 very much, Michelle. So I think we're waiting to 

11 get started. Up first is Harold Austin. On deck 

12 is Gerry Robertson. Gerry, thank you for typing 

13 in your first four digits. Harold, you are up. I 

14 hope you have been practicing your three minutes. 

15 MR. AUSTIN: Thanks, Tom, and quite a 

16 different feeling to be on this side of the speaker, 

17 so hopefully I am debuting okay.

18 Good day, everybody. First, as a 

19 recently sunsetted member of the NOSB, I would like 

20 to say hello to all of those of you that I have had 

21 the privilege to have served on the Board with, and 

22 to the new members, I wish to thank you for your 
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1 willingness to serve the organic community in this 

2 capacity. I urge you all to read the written 

3 comments that I have submitted, and please remember 

4 to do your best to fairly represent all organic 

5 stakeholders.

6 For crops, I have submitted detailed 

7 comments in support of the continued listing for 

8 micronutrients in soluble boron, which are 

9 extremely important to organic tree fruit; 

10 berries; and grape production; also for 

11 herbicides, soap-based; sticky traps; coppers; 

12 humic acids, which all are still very important in 

13 organic crop production today.

14 For the marine algae proposal submitted 

15 by the -- proposed by the Crop Subcommittee with 

16 the use of the annotation limiting it only to brown 

17 algae, completely disregards the fact that there 

18 are two other forms that were identified as being 

19 used in organic crop production. The proposal 

20 needs to go back to the subcommittee to get 

21 re-looked to ensure that those other additional 

22 forms, red algae and green algae, are also included 
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1 in use by organic crop producers. 

2 Certainly -- and this would be helped 

3 --

4 (Simultaneous speaking.) 

5 MR. AUSTIN: -- inappropriate amount 

6 of time given to the public and organic 

7 stakeholders to read, research, and submit 

8 properly prepared comments. For both crops and 

9 handling, I support the continued listing on the 

10 national list for all the chlorine substances 

11 currently under Sunset Review. These are 

12 critically important uses in both crops and 

13 handling alike. 

14 Now, with the implementation of FSMA, 

15 we have a legal responsibility to ensure consumer 

16 safety. While we have alternatives, they do not 

17 always work in every situation. Plus, we must 

18 protect from resistance management by using 

19 different substances in a rotation use pattern. We 

20 need these materials to assist us in controlling 

21 e coli and listeria as well as fire blight in the 

22 field. Without these, it would be next to 
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1 impossible to accomplish this task.

2 For handling, as the recent Chair of the 

3 Handling Subcommittee, I would support all of the 

4 substances currently up for the 2019 Sunset Review 

5 for relisting. Most of these have just recently 

6 been reviewed, and at that time, we found no issues 

7 that would make them -- would make us think 

8 otherwise about relisting them at that time. 

9 These are all important substances currently used 

10 in the organic handling process. Please read my 

11 comments on these. I do support the proposals as 

12 submitted for L-methionine, Tocopherols, Short DNA 

13 Tracers, and marine algae. Finally, 

14 regarding the proposal for additional ancillary 

15 substances for use in cellulose as listed, there 

16 have been some concerns raised in regards to three 

17 of the substances on that list. Under coatings, 

18 it should state polyvinylidene chloride. Vinyl 

19 chloride should not have been on that list, and how 

20 it got there was simply an oversight and mistake.

21 Secondly, under coatings, Kymin should 

22 be re-looked at and probably be added to the --
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1 CHAIRMAN CHAPMAN: Thank you very 

2 much, Harold. I don't see any questions, so thank 

3 you for your comment, Harold, and we will be moving 

4 on to Gerry Robertson. On deck is David Martinez. 

5 David, if you would type in the first four digits 

6 of your phone number, that would be appreciated. 

7 Gerry? 

8 MR. ROBERTSON: Good afternoon. My 

9 name is Gerry Robertson, and I am the Director of 

10 Supply at Reiter Affiliated Companies in Oxnard, 

11 California. We grow organic and conventional 

12 berries throughout the U.S. and Mexico.

13 I am here to comment on the recent Crop 

14 Subcommittee discussion document on hydroponics. 

15 With regards to the recent document, we feel that 

16 it does not adequately identify container 

17 production as a system distinct from hydroponics, 

18 as has been the case in previous NOSB discussions 

19 and documents.

20 The inclusion of the term "biologically 

21 recalcitrant" in the definition of hydroponics is 

22 too vague, and it is even a bit confusing. For 
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1 example, a stated definition of recalcitrant 

2 materials lumps coconut coir, wood shavings, peat 

3 moss, and humus together in the same category. 

4 If the intent of this definition is to 

5 exclude practices that are not dependent on 

6 biological processes in the uptake of nutrients, 

7 we would suggest removing the term "biologically 

8 recalcitrant" from the definition of hydroponic. 

9 Adding the word "sterile" prior to "nutrient rich" 

10 and "nutrient solution" in the same definition 

11 could further clarify this distinction. 

12 We further suggest that NOSB should 

13 develop a specific definition for container 

14 systems that acknowledges the active biological

15 processes inherent to those systems. Our current 

16 organic container systems are being certified in 

17 part because they depend on the same biological 

18 processes that exist in our soil-grown organic 

19 systems, and because they meet the NOP 205.2 

20 definition of organic production. 

21 Both our organic soil and 

22 container-grown systems depend upon the complex 
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1 interaction of microbial activity. Both systems 

2 rely upon external allowable liquid nutrients, and 

3 both systems invest in biodiversity and natural 

4 resource sustainability efforts. Our organic 

5 container farmers deserve to have a definition that 

6 affirms the validity of these practices while 

7 distinguishing from practices that are clearly not 

8 allowed. 

9 These farmers are highly focused on 

10 developing and managing the biodiversity of their 

11 respective growing mediums and are fully aware that 

12 this process of feeding the soil in order to feed 

13 the plant is critical to a successful organic 

14 system. These farmers are not content to apply the 

15 term "magic" to processes they do not understand. 

16 Rather, they seek to better understand those 

17 processes in order to become better organic 

18 farmers. 

19 We believe that it is important for the 

20 Board to develop sound and science-based standards 

21 for container production systems as well as other 

22 types of systems that align with organic principles 
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1 and that allow flexibility for the innovative 

2 farmer to adapt to site-specific conditions, 

3 climate change, et cetera. 

4 On behalf of the various Reiter 

5 entities throughout the U.S. and Mexico, I wish to 

6 thank the members of the Board for this opportunity 

7 to comment and for your ongoing dedication and 

8 commitment to the organic community. Thank you. 

9 CHAIRMAN CHAPMAN: Thank you very 

10 much, Gerry. I don't see any questions at this 

11 time, so we will move on to the next commenter. Is 

12 David Martinez on the line? We are not seeing your 

13 phone number. 

14 (Pause.)

15 CHAIRMAN CHAPMAN: David Martinez, 

16 going once, going twice? 

17 (No audible response.)

18 CHAIRMAN CHAPMAN: Up next will be 

19 Cecille Madriz, then, and following that will be 

20 Carmela Beck. Cecille? 

21 MS. MADRIZ: Hello. My name is 

22 Cecille Madriz. I am the Manager of Fennel Farms 
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1 here in Aromas, California. We grow organic 

2 container blueberries.

3 I did provide feedback last fall, just 

4 as a reminder, and I would like to reiterate the 

5 importance of substrates for young, small farmers 

6 like myself, as well as having the ability to 

7 transition conventional land into organically 

8 certified land. As you know, in these areas, it 

9 is really difficult to find organically certified 

10 land. There's a lot of in-ground growers to be 

11 using it at a better cost to them, so that is one 

12 of the key things that -- where we're looking at 

13 the excuses would really go hand in hand.

14 The aeroponic, hydroponic, and 

15 aquaponic discussion documents that we needed 

16 earlier on, there's a few things that I would like 

17 to touch on. The biologically recalcitrant usage 

18 in the hydroponic definition, or in any definition,

19 really does not make any sense to me because 

20 recalcitrant means that it is impeding or does not 

21 allow, and that is not entirely scientifically true 

22 when you think about these systems. 
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1 And these systems, whether they are 

2 water-based or substrate-based, are completely 

3 different when it comes to microbial activity. So 

4 you can't really provide discussion documents on 

5 both of them when you think of them on their 

6 scientific value, where we have different 

7 microbial communities in those systems, completely 

8 different. There is just no way that they could 

9 be exactly the same.

10 Another thing that I would like to touch 

11 on is being able to use these systems to provide 

12 more organic choices to the community at a price 

13 that they could afford versus the dilemma that we 

14 find ourselves now, where we can't really get 

15 organic -- where we do have it in a lot of places, 

16 but a lot of times, that is brought in from other 

17 countries, and we are not producing anywhere near 

18 as much as we should be ourselves, so it is not 

19 allowing people to use these systems is like saying 

20 we're not allowed to provide our own organic 

21 products to our own consumers. It is just a simple 

22 thought. 
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1 And other than that, I look forward to 

2 working with you guys further on getting better 

3 definitions of these two different systems 

4 separately, and getting discussion documents from 

5 them separately. I would like to see that 

6 addressed a little more clearly in the future so 

7 that when the public does see what we're doing here, 

8 that they do see that these are two different 

9 systems. They are not -- they can't be lumped up 

10 together. There is no way that they could 

11 understand if you put them together. 

12 Thank you for your time. I look 

13 forward to working with you guys further on this.

14 CHAIRMAN CHAPMAN: Thank you, thank 

15 you very much. I see we have a question from 

16 Ashley. Ashley? 

17 VICE CHAIR SWAFFAR: Hi, and Cecille, 

18 thank you for your comment. I have a question, and 

19 you may not know the answer to this, but if 

20 container production was disallowed, what 

21 percentage do you think of the -- you said you're 

22 a berry grower -- what percentage of the berries 
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1 grown in the U.S. organically do you think would 

2 go away? Do you know that? 

3 MS. MADRIZ: Removing substrate or 

4 disallowing the use of substrate systems would also 

5 remove the ability for us to have like organic 

6 strawberries start, so it's a really big picture 

7 that we're looking at when we think of substrate. 

8 We think of it more than just the people like me 

9 who are producing berries. It is a growing portion 

10 of the berry commodity simply because blueberries 

11 -- just blueberries themselves cannot be grown in 

12 most of the ground around here because we have 

13 nowhere near the soil type that they like to grow 

14 in to have the full genetic expression to keep them 

15 from getting diseases and other kinds of problems.

16 So if you don't have full genetic 

17 expression, you end up adding more things to your 

18 plants and spraying wasps and -- versus using what 

19 the plant already has genetically to grow the best 

20 berries you can. So it's a really big picture when 

21 you say you could not allow substrate. It's like 

22 not allowing a lot of different things, from 
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1 production to plant propagation. It's a really 

2 big picture. 

3 CHAIRMAN CHAPMAN: Okay. Thank you 

4 very much.

5 Up next is Carmela Beck, and on deck is 

6 Steve Etka. 

7 MS. BECK: All right. Good morning. 

8 My name is Carmela Beck. I am the Organic Program 

9 Manager at Driscoll's, based out of Watsonville, 

10 California. 

11 We're an international distributor and 

12 marketer of conventional and organic strawberries, 

13 raspberries, blackberries, and blueberries. 

14 Organic is 14 percent of our business and growing 

15 aggressively. I work with over 150 small, medium, 

16 and large independent organic family farmers 

17 across the U.S., Mexico, and Chile assisting with 

18 their organic certification needs. My comments 

19 pertain to the aeroponic, hydroponic, aquaponic 

20 discussion document. I have seven points to 

21 outline. 

22 One, the Crop Subcommittee tried to 
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1 rush the publication of the proposal and only 

2 decided at the last minute to revert to publication 

3 of the discussion document. Five new Board 

4 members joined the NOSB this January, allowing new 

5 members less than one month's time to get up to 

6 speed on all meeting topics. These short 

7 timelines are insane. Please go down, allow your 

8 colleagues time to objectively study the issues.

9

10 Two, the discussion document does not 

11 make mention of container production in the title. 

12 However, the subcommittee stuck eight questions 

13 specific to containers into the document. 

14 Heretofore, the Board worked to clearly 

15 distinguish container production from water-based 

16 production systems by issuing separate documents. 

17 Mixing container-based systems with water-based 

18 systems into one document was highly confusing and 

19 inappropriate. Please issue separate water-based 

20 substrate and container production discussion 

21 documents. Avoid blurring the lines and smushing 

22 the topics together. Stop the practice of issuing 
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1 one document in the absence of the other. The 

2 Board and the public should review both topics in 

3 tandem.

4 Three, the written NOSB meeting 

5 materials were slated for publication on 3/1/17. 

6 However, they were not posted until 3/17/17. This 

7 allowed 14 days to review the materials. Please 

8 ensure future one-month public comment period.

9 Four, the Crop Subcommittee introduced 

10 new definitions without providing context or clear 

11 explanations for their evolution. More 

12 specifically, the Board is seeking to prohibit 

13 biologically recalcitrant or 

14 resistant-to-microbial-attack materials such as 

15 coconut coir, wood shavings, and/or peat, which are 

16 key ingredients in commercial container production 

17 systems. Going forward, please provide a chart 

18 tracking the evolution of definitions. Cite their 

19 sources for clear public transparency, and provide 

20 rationale for modifications. Provide data with 

21 citations that coconut coir, wood shavings, and 

22 peat are biologically recalcitrant and that they 
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1 do not serve as substantive sources of nutrients 

2 for the plants being grown, as indicated in the 

3 document. Revert to the fall 2016 proposal 

4 definition for soil. 

5 Five, please invite a panel of 

6 container production substrate experts to your 

7 next NOSB meeting. 

8 Six, please visit your local 

9 organically certified container production 

10 operators in the coming months to help inform your 

11 deliberations and vote.

12 Seven, I encourage the Board to engage 

13 in robust NOSB meeting public debate on the topic. 

14 In closing, it is my belief that the 

15 regulation as originally written was meant to 

16 protect the integrity of the organic label but was 

17 not meant to be static. It was written to allow 

18 for the future creation of innovation production 

19 practices intended to benefit subsequent 

20 generations. There is not a Driscoll's customer 

21 that doesn't want organic. Not one has demanded 

22 that organic berries be grown in soil in the upper 
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1 crust of the earth. On the contrary, our customers 

2 are continually impressed with our farmers 

3 innovative, forward-thinking, and sophisticated 

4 organic growing methods. 

5 Let's work together to find a way 

6 forward. Thanks everyone for your commitment to 

7 organic integrity. 

8 CHAIRMAN CHAPMAN: Thank you very 

9 much, Carmela. I have a question from Ashley, then 

10 Frank. Ashley? 

11 VICE CHAIR SWAFFAR: Thanks, Carmela. 

12 Maybe you can answer my question that I had asked 

13 Cecille earlier: do you know like what percentage 

14 of all of the berries would go away if we didn't 

15 allow container production? 

16 MS. BECK: Ashely, yes, I don't 

17 actually have that number, but I am more than happy 

18 to provide it to -- to you in -- in our public 

19 comments that we will be publishing post-meeting, 

20 so that is data that we can include. 

21 VICE CHAIR SWAFFAR: Okay. Thank you.

22 MS. BECK: Yes. 
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1 CHAIRMAN CHAPMAN: Francis? 

2 MR. THICKE: Hi Carmela. You 

3 mentioned that 14 percent of the produce of 

4 Driscoll's is organic. What percent of that 

5 organic is hydroponic or container-growing that 

6 has the majority of the nutrients coming from 

7 liquid feed? 

8 MS. BECK: Francis, all of our -- you 

9 know, our in-ground crops and our container 

10 production rely on liquid nutrients, and as Ashley 

11 asked about the percentage of our container 

12 production, not hydroponic, our container 

13 production growing practices, I don't have that 

14 number for you, but that is going to be included 

15 in our public comments that we will issue 

16 post-meeting during the open docket session. We 

17 were unable to provide comments with the timeline 

18 that was provided. 

19 MR. THICKE: Okay. And just a quick 

20 point of clarification: the reason there are 

21 questions about containers in the discussion 

22 document is so that we can help us prepare two 
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1 separate proposals for the fall, one on hydroponics 

2 and one on container growing. Thank you. 

3 MS. BECK: Thank you. Yes, thank you, 

4 Francis, I appreciate that. And I would just 

5 reiterate that I think it is really helpful to have 

6 issued a separate discussion document that 

7 pertains specifically to container production to 

8 keep the topics separate. 

9 CHAIRMAN CHAPMAN: Thank you, Carmela. 

10 Thank you Board --

11 MS. BECK: Thank you.

12 CHAIRMAN CHAPMAN: -- members.

13 Up next, we have Steve Etka, and after 

14 that, we have Amber Pool. Amber, if you could type 

15 in the first four digits of your phone number, that 

16 would be appreciated. 

17 MR. ETKA: Good morning. I am Steve 

18 Etka. I am Policy Director for the National 

19 Organic Coalition.

20 There is a lot of anxiety in the organic 

21 community right now in light of the anti-regulatory 

22 fervor of Congress and the new administration. 
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1 Organic depends heavily on regulations to 

2 establish the rules for those operations who 

3 voluntarily choose organic certification and for 

4 consumers who buy organic. Some of that fervor has 

5 been targeted at organic, most notably the pending 

6 organic animal welfare rule.

7 While acknowledging these threats, we 

8 must not overstate these threats. Some have 

9 politicized the idea that the far right Freedom 

10 Caucus in the U.S. House includes the -- included

11 the entire National Organic Program on a list of 

12 programs to be cut. In reality, a careful reading 

13 of the list shows that the group is not proposing 

14 elimination of the NOP broadly, but a cancellation 

15 of the organic animal welfare rule instead.

16 We have a positive story to tell about 

17 organic that should resonate across the political 

18 spectrum. Even House Speaker Ryan in his 

19 blueprint document about the economy used organic 

20 standards as an example of a better way to 

21 promulgate federal regulations because the regs 

22 are voluntary in the sense that farmers decide 
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1 whether or not to opt into the program, and 

2 similarly, consumers voluntarily decide whether to 

3 buy organic food. There is no question that 

4 organic will be facing some challenges as we go into 

5 the next farm bill and appropriations cycles, but 

6 it is important that we not make our challenges even 

7 greater by fabricating additional foes. 

8 With regard to biodegradable bio-based 

9 mulch, NOC acknowledges that BBM film would be a 

10 great asset to producers. However, we still have 

11 concerns regarding the environmental and health 

12 effects of the breakdown. NOC is also concerned 

13 that BBM is being measured against a standard that 

14 is inadequate to ensure complete removal of the 

15 plastic product in the new ASTM standard, although 

16 development is not yet available. In short, NOC 

17 believes that BBM mulches are not yet ready for 

18 prime time. 

19 With regard to copper, NOC supports 

20 keeping fixed coppers and copper sulfate on the 

21 national list. Copper has been used for centuries 

22 in agricultural and livestock, and it remains an 
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1 important tool for organic farmers. When used 

2 properly, copper products are less toxic than other 

3 classes of degree-of-control materials. Copper 

4 products for degree of control seem to be the only 

5 material available right now for organic growers 

6 to combat many serious crop diseases. 

7 However, we can't lose sight of the fact 

8 that copper products are toxic, and that elemental 

9 copper in the formulations is persistent. In 

10 short, organic certifiers in the short term --

11 excuse me -- organic certifiers are requiring 

12 routine monitoring of copper levels in the soils 

13 of growers, using that to identify early evidence 

14 of build-up and toxic accumulation, or to prevent 

15 toxic accumulation.

16 In the long run, alternatives must be 

17 found to avoid the long-lasting adverse effects of 

18 copper use, and we strongly support efforts to make 

19 copper sulfate alternatives a high-priority 

20 research topic for federal funding. Thank you. 

21 CHAIRMAN CHAPMAN: Thank you, Steve. I 

22 do not see any questions at this time. Thank you.
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1 We will move on to Amber Pool. Amber? 

2 And on deck we have Kelly Maben. Kelly, if you 

3 could type in your first four digits as well? 

4 Thank you. 

5 MS. POOL: Hi. My name is Amber Pool, 

6 and I am a Farm Technical Specialist for CCOF, and 

7 I just had to just thank you guys for again hosting 

8 this webinar. I work with so many farmers that 

9 have a lot of responsibilities on their farm, and 

10 they wouldn't be able to travel to attend this 

11 meeting in person, and I am really happy to see that 

12 I see a lot of their names on the schedule today, 

13 so I look forward to hearing from them.

14 I wanted to talk about the crop Sunset 

15 Review, and in general, CCOF does -- we want 

16 stability in the rule so farmers know that they have 

17 a tool that they can rely on, and we don't want to 

18 see Sunset materials go away unless there is a 

19 compelling reason for the change or a specific 

20 replacement has been created.

21 And I just -- I have had so many really 

22 heartbreaking conversations with farmers that lost 
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1 their certification when antibiotics for fire 

2 blight went away, and apples and pears, it 

3 specifically hit the pear growers really hard in 

4 California. And, you know, they tried to manage 

5 it with organic-approved methods, and they lost 

6 tens of thousands of dollars every year to damage 

7 on their trees, and ultimately, they went back to 

8 the antibiotics because they had no other way to 

9 control the fire blight. 

10 And it was a really -- it was hard and 

11 tough, and we all had hard conversations with those 

12 growers. But I just wanted to keep that in mind 

13 any time material Sunsets. In our written 

14 comments, we have provided numbers of growers who 

15 are using each material for the Sunset Review.

16 And then I also wanted to just talk 

17 about strengthening the organic feed items and some 

18 of the things we do. Every year, at the annual 

19 inspections, the growers have to report the 

20 percentage of organic feeds that they have used, 

21 and that is tracked in our database, so we can 

22 easily see from year to year if they are improving 
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1 for example organic feed. 

2 And we really want to advocate for a 

3 feed database that growers can go to and that is 

4 just one place, and it is live and it is updated, 

5 and it will be helpful for our growers and for our 

6 certifiers to verify if a feed is commercially 

7 available, it's organic. And with our large 

8 growers, they often use the excuse that quantity 

9 of feed is not available for organic commercial 

10 availability, and so we're really working with 

11 those growers to find out why they cannot contract 

12 with organic feed producers to grow the variety 

13 that they need and the quantity that they need.

14 And with that, I will complete. Do you 

15 guys have any questions? Thank you. 

16 CHAIRMAN CHAPMAN: Thank you, Amber. 

17 I don't see any questions at this time. We will 

18 move on to Kelsey, and on deck is Zea. Kelsey? Are 

19 you there? 

20 (No audible response.)

21 CHAIRMAN CHAPMAN: Kelsey, if you're 

22 speaking, you're on mute. 
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1 (No audible response.)

2 CHAIRMAN CHAPMAN: All right. 

3 MS. ARSENAULT: We have three numbers 

4 on from 831, and they're all unmuted right now. 

5 Kelsey, are you there? 

6 (No audible response.)

7 CHAIRMAN CHAPMAN: All right. We will 

8 move on then. Up next is Zea, and on deck is Bill 

9 Stoneman. Bill, if you could put in your first 

10 four digits, that would be appreciated. Zea, are 

11 you ready? 

12 MS. SONNABEND: Thanks. Can you hear 

13 me? 

14 CHAIRMAN CHAPMAN: Yes. You're a 

15 little light. 

16 MS. SONNABEND: A little iffy? How is 

17 that? 

18 CHAIRMAN CHAPMAN: Still a little 

19 light, but go ahead. 

20 MS. SONNABEND: Hi everyone. I am 

21 glad I won't be joining you, but I miss you somewhat 

22 -- I will miss you somewhat, but I won't be sad to 
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1 not be there. Zea Sonnabend, Fruitilicious Farm 

2 and CCOF. I want to touch on several points 

3 quickly, and I will speak as fast as I can, and I 

4 won't catch everything I have been working on, but 

5 if you want to ask me questions, you can. 

6 First thing is marine materials. The 

7 crops version is completely lacking in a discussion 

8 of impact of this very big change on crops inputs. 

9 This would limit the products able to be used, since 

10 now there are products from red and green seaweeds 

11 on the market. It would create a lot more work for 

12 certifiers and materials review organizations to 

13 track the sources of each brand used, which they 

14 don't now. If such a major change is to 

15 be implemented, you at least need to give some 

16 reason in the text of the document why you want to 

17 do this, along with trying to reach out and assess 

18 how this would affect the many users of these 

19 products. I think you should scrap this proposal 

20 and go back to the drawing board. 

21 The handling version of the marine 

22 materials is fine for the substances that clearly 
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1 have an identity based on one species, but the 

2 listing for kelp is problematic. Why would you 

3 pass a proposal to limit the species by Latin name 

4 before you create the guidance on the meaning of 

5 it, which is in the second motion? I suggest you 

6 remove the kelp listing from the first motion and 

7 pass the second motion, and then keep working on 

8 kelp. 

9 Seed: as the main author of the seed 

10 proposal, I think it is a step forward and a needed 

11 revision. However, it needs some reconsideration 

12 on a few points to see if it is really meeting 

13 stakeholders needs and/or is over-prescriptive or 

14 needs some work or that kind of thing. I realize 

15 that it is over-prescriptive perhaps in a few 

16 areas. In light of this being a first posting and 

17 a very short comment period, I think you should take 

18 the proposal back to subcommittee for more work. 

19 And lastly, just briefly on the subject 

20 of recalcitrant as a term, mineral soil that has 

21 no organic matter is more recalcitrant than coir 

22 is. Don't use this term. Instead, just list what 
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1 you want in or out instead of trying to confuse what 

2 you want with a vague term. 

3 So that is all I really have to say at 

4 the moment, and I am in before the deadline. Truly 

5 amazing. 

6 CHAIRMAN CHAPMAN: Thank you very 

7 much, Zea. Any questions for --

8 MR. STONEMAN: This is -- this is Bill 

9 Stoneman. Can you hear me? 

10 CHAIRMAN CHAPMAN: Yes. We will move 

11 on to Bill. Though, one moment: after Bill is Mark 

12 Russell. You're on deck. So Bill, go ahead. 

13 MR. STONEMAN: Thank you, and I 

14 appreciate the opportunity to address this group, 

15 and thank you for setting up this webinar. 

16 Hello. My name is Bill Stoneman, and 

17 I am an independent crop inspector and a gardener. 

18 I hold a bachelor's degree in natural resource 

19 management and a master's in agronomy and soil 

20 science, both from Minnesota. I have 50 plus years 

21 of experience in agriculture, including soil 

22 fertility, crop management, et cetera. The past 
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1 ten years, I have worked in organic agriculture and 

2 have worked with regulatory affairs for biological 

3 input and for use in organic agriculture for 

4 significantly longer. 

5 I am here to speak in favor of expanded 

6 allowance of ammonium nonanoate in organic 

7 agriculture as a weed control agent. It is my 

8 understanding that -- that a recent petition to 

9 allow the use of ammonium nonanoate -- are you 

10 getting an echo? 

11 CHAIRMAN CHAPMAN: Yes. You might 

12 want to decrease your own volume. 

13 MR. STONEMAN: Okay. I can do that. 

14 Can you still hear me? 

15 CHAIRMAN CHAPMAN: Yes.

16 MR. STONEMAN: Okay. It is my 

17 understanding that a recent petition to allow the 

18 use of ammonium nonanoate in cropping areas for 

19 weed control was recently passed over by the Crops 

20 Committee of the NOSB. I think the material 

21 deserves reconsideration, and I have knowledge 

22 that one basic manufacturer of the material as a 
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1 U.S. EPA registrant has resubmitted once again.

2 The product is an EPA-registered 

3 biological agent for control of weeds. As an 

4 organic inspector, I personally witness the 

5 struggle of growers to meet the requirements of 

6 weed control, not only to be in compliance with the 

7 standards, but for economic reasons. Weed control 

8 is often a problem in a farm and a limiting factor 

9 to production. With limited resources applicable 

10 to the practice of weed control and limited 

11 methods, this is often the primary stumbling block 

12 to growers' decisions to become certified. The 

13 labor available to organic farms will likely 

14 continue to shrink, and farmers could really use 

15 this gentle tool.

16 First, let's look at the soil. Soil 

17 quality building fertility and soil biodiversity 

18 is always first and foremost as we seek food and 

19 fiber production and naturally occurring 

20 biological control in organic cropping systems. 

21 For tillage especially, the often excessive 

22 tillage required to control weeds in many of our 
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1 organic production systems is destructive to the 

2 soil structure and biological diversity.

3 Many of the organic farms I have visited 

4 are either riddled with weed problems, or tillage 

5 is practiced multiple times to try to stay ahead 

6 of the weeds. Excessive tillage is destructive to 

7 soils, even in organic systems. University data 

8 often shows continuing tillage in organic systems, 

9 even with sound rotational programs, cover 

10 cropping, and -- and addition to the soil organic 

11 matter would still lose that recalcitrant organic 

12 matter.

13 We all know from our personal 

14 experience with gardening and in crop production 

15 that tillage accelerates organic matter breakdown, 

16 and for non-recalcitrant carbon, the plant matter, 

17 compost, animal manures, and so forth are broken 

18 down. 

19 (Simultaneous speaking.)

20 CHAIRMAN CHAPMAN: Mark, we're at the 

21 end of your time. If you could just wrap up --

22 MR. STONEMAN: Okay. Okay. So I ask 
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1 the Crops Committee of this prestigious body to 

2 reconsider rejection of the petition for the 

3 allowance of ammonium nonanoate as a biologically 

4 based herbicide in food production. Thank you.

5 CHAIRMAN CHAPMAN: Thank you very 

6 much, Mark. We're down to -- oh, sorry, Bill. I 

7 don't see any questions.

8 Up next is Mark Russell, and on deck is 

9 Kye Witek. And Kye, if you could type in your phone 

10 number, that would be appreciated. Mark?

11 MR. RUSSELL: Yes, good morning from 

12 Oregon. My name is Mark Russell. I have been in 

13 the agricultural production business for 30 plus 

14 years, starting my industry -- my current industry 

15 with some agricultural clinical companies and in 

16 distribution, and the last 15 years in product and 

17 business development for individual companies as 

18 a contract employee. 

19 And as a result of that, over the last 

20 15 years, I have had the opportunity to be involved 

21 with numerous new companies and new product 

22 launches, both in the organic and the EPA 
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1 biopesticide arena for conventional, with really 

2 the intent I think in all of this to provide an 

3 abundant food source and a safe food source for, 

4 not just America, but for the world, and I think 

5 it is amazing, you know, that we have been able to 

6 do all that we have been able to do, and people on 

7 this Board have certainly been involved in all that 

8 as well as the commentators on here, so 

9 congratulations to everybody. It's a great 

10 position that we have over food that we do have.

11 My comments this morning are specific 

12 to some of the Sunset I guess products that are 

13 considered to be sunsetted off of an approved list, 

14 and specifically in weed control arena. Here in 

15 Oregon, and the Northwest and a lot of areas, weed 

16 control, given the amount of moisture we have and 

17 soil that we have, weed control is a major part of 

18 a production system, and specifically weed 

19 challenges with labor, with mechanization that we 

20 control. This spring, it is extremely wet in 

21 Oregon, and so getting it and actually doing weed 

22 control right now with mechanization actually is 
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1 destructive to soil.

2 So the soap-based herbicides are 

3 materials that have been used and are being used 

4 and needing to be extended for use, in my opinion, 

5 with people that I work with, and I believe that 

6 currently, there is a probability of that being 

7 sunsetted, and soap-based herbicides off organic 

8 production to not be able to be used would be 

9 certainly detrimental to the people that I work 

10 with here in the Pacific Northwest.

11 In addition to that, I would like to say 

12 that these same basic technologies, the soap-based 

13 materials that are registered and approved for 

14 organic use as insecticides, have the ability to 

15 be able to be used both in crop and out of the crop 

16 as well, and the soap-based herbicides are actually 

17 only allowed to be used outside the scope of the 

18 crop production area. 

19 This is confusing to me and has been for 

20 some time, when it is basically the same materials 

21 being able to be used in the crop for one use and 

22 not in the crop as another use, so I guess there's 
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1 an adaptation or something that possibly could be 

2 modified for that.

3 Sounds like my time is up. I thank you 

4 for allowing us to comment, and we strongly 

5 consider the continued use of soap-based 

6 herbicides. 

7 MR. CHAPMAN: Thank you, Mark. I 

8 don't see any questions at this time, so we'll move 

9 on to the next presenter. I'm probably butchering 

10 the name. Kye, K-Y-E, are you here? Not seeing 

11 your phone number on the list. 

12 MS. ARSENAULT: We have looked in all 

13 possible areas. We do not see the name or the 

14 number. 

15 MR. CHAPMAN: Yes. Going once, going 

16 twice. We'll be moving on to Julia Barton and on 

17 deck after Julia will be Joe Gabriel. Joe, if you 

18 could type in your first four digits. Julia, if 

19 you're ready, you're up. 

20 MS. BARTON: Yes. Can you hear me? 

21 MR. CHAPMAN: Yes, we can. 

22 MS. BARTON: Okay. This is Julia 
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1 Barton. I'm speaking on behalf of the Ohio 

2 Ecological Food and Farm Association. OEFFA is a 

3 grassroots coalition of more than 4600 members 

4 working to build a healthy and sustainable food 

5 system. Our certification program certifies over 

6 1200 organic producers and handlers. 

7 I'd like to comment today about the real 

8 and current impact of oil and gas industry 

9 infrastructure on organic farms. OEFFA has long 

10 been concerned about these issues, and we have 

11 raised them with you over the past two years. Last 

12 spring, Kip Rondy, an organic vegetable producer 

13 from Ohio, traveled to the NOSB meeting in D.C. to 

14 comment on this issue and asked that it be added 

15 to the work agenda. In this docket, seven organic 

16 producers, six private citizens, and several 

17 organizations shared comments requesting the NOSB 

18 look more closely at this important topic.

19 The lack of attention to this matter has 

20 already resulted in one casualty. Starline 

21 Organics was a certified organic vegetable 

22 operation in Southeastern Ohio, which directly 
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1 marketed veggies at farmers' markets and to 

2 restaurants. In 2010 and 2011, two injection 

3 wells were built adjacent to the farm. Multiple 

4 trucks ran in and out daily, injecting fracking 

5 industry waste beneath the soil surface.

6 Due to the use of spring water for 

7 irrigation, the exorbitant cost of repeated water 

8 sampling, and the lack of information regarding 

9 what chemicals for which to test, Starline Organics 

10 shut down. Matt Starline stated he could no longer 

11 be sure of the safety of the food he and his wife, 

12 Angie, were producing. In the absence of guidance 

13 or support, these organic producers made the 

14 difficult decision to protect the integrity of 

15 organics and the quality of food for their buyers 

16 at the expense of their livelihood.

17 The Starline family story is just one 

18 example of the impacts of fracking and oil and gas 

19 industry infrastructure on organic farms. 

20 Certifiers working directly with organic 

21 producers, they're witness to these wide-reaching 

22 effects. We must address the unique concerns of 
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1 organic farmers faced with this infrastructure. 

2 These issues will not go away if we ignore them.

3 Please add this important topic to 

4 NOSB's work agenda and consider the development of 

5 a discussion document to unpack the many ways 

6 organic farmers are impacted by oil and gas 

7 industry infrastructure. Thank you for your 

8 consideration and for your service to our 

9 community. 

10 MR. CHAPMAN: Thank you very much, 

11 Julia. I don't see any questions at this time. We 

12 will be moving on to the next presenter, Joe 

13 Gabriel. Then on deck is Marie Burcham. Marie, 

14 if you could type in your phone number, that would 

15 be appreciated. Joe? 

16 MR. GABRIEL: Hello. I'm Joe Gabriel. 

17 I work with Gilbert Orchards, and I've been an 

18 organic advocate and stakeholder for the last 45 

19 years. In the 50's and 60's, when growers began 

20 adopting organic techniques, Rodale Press evolved 

21 organic methods doing his models. California 

22 certified organic farmers launched an organic 
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1 certification program in 1974. Their standards 

2 have hereto ruled. Otherwise, from the early 70's 

3 to the mid 80's, farmers distributed to natural 

4 food retailers made up of a loose-knit network that 

5 vouched for or disclaimed the authenticity of 

6 organic farms. By and large, the organic movement 

7 operated without standards, material lists, or 

8 third-party inspections. 

9 In the mid 80's, additional certifiers 

10 began to develop organic standards and joined CCOF 

11 certifying organic farms and processes. Several 

12 certifiers formed a group called the Western 

13 Alliance of Certification Organizations. These 

14 groups helped shape standards and material lists. 

15 Some of the changes the groups made were 

16 eliminating materials such as nicotine-based 

17 pesticides, strychnine, arsenated lead, and 

18 rotenone. Certifiers also eliminated the 

19 practice of packing organic food and vegetables in 

20 a recycled conventional produce process; instead 

21 a three-year transition organic period that had 

22 ranged from one to four years. No official 
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1 oversight of the certifiers in those standards 

2 existed. 

3 In the late 80s, the Organic Trade 

4 Association established the Organic Certifiers 

5 Council. This council worked in conjunction with 

6 OTA's Quality Assurance Committee to find common 

7 ground for materials and language. These groups 

8 developed the American Organic Standards. This 

9 was a start for accrediting certifiers in the 

10 business for the NOP when it came into play in 2000.

11 When I hear we must go back to the roots 

12 of organics, I have to wonder what that means. 

13 After looking at the history of organic 

14 agriculture, what will we go back to? It has been 

15 a 45-year process in time organic as we know it 

16 today. From the early 70's to 2000, organic unity 

17 developed organic standards that eliminated as 

18 many harmful inputs as possible. These standards 

19 also allowed for compromises in cases where no 

20 alternate use existed. Many of these are 

21 materials on the sunset list today. We can't 

22 forget the sunset materials helped to allow tens 
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1 of thousands of acres used for organic production. 

2 In the process, organic farming influenced 

3 agriculture at large. Some examples are compost 

4 pheromones pest control, soil microbiology, the 

5 benefits of predatory and pollinating instincts, 

6 and biological pest controls. Also, the periodic 

7 testing of organic produce for residue brought to 

8 life (inaudible) and contributes 

9 organophosphates.

10 I urge the NOSB to keep in mind the 

11 history of the sunset materials, why they exist, 

12 and the role they have played in the organic medium. 

13 Organic growers count on copper micronutrients to 

14 keep crops healthy and (inaudible). Without 

15 chlorine sanitizers, processors will not pass 

16 federal or state health standards. Sulfates weed 

17 control products and possibly biodegradable 

18 plastic mulch offer options other than the 

19 conventional for landscapers and road maintenance. 

20 Organic stakeholders, let's pull 

21 together as in the past and pool our resources to 

22 find alternatives. If materials are taken off the 
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1 sunset list without viable replacements, the 

2 consequences will be fewer acres farmed or 

3 maintained organically, less organic food 

4 available to consumers, increased prices for 

5 organic food, more acreage in non-organic 

6 production, sadly weaken the organic farmer 

7 community in its' effort to evolve and improve 

8 organic agriculture in general. 

9 MR. CHAPMAN: Okay. We've come to the 

10 end of your time. Thank you very much for your 

11 comments. I don't see any questions at this time, 

12 so we'll be moving on to Marie. On deck is Dain 

13 Carver. Dain, if you could type in the first four 

14 digits of your phone number. And, Marie, if you're 

15 ready. 

16 MS. BURCHAM: Hi. Can you hear me? 

17 MR. CHAPMAN: Yes.

18 MS. BURCHAM: Excellent. Hello and 

19 good afternoon. My name is Marie Burcham, and I 

20 am the Livestock Policy Analyst for The Cornucopia 

21 Institute. I'm also an attorney with a background 

22 in environmental, natural resource law, and animal 
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1 law.

2 Members of the Board and the public, 

3 thanks for the opportunity to speak on the two 

4 discussion documents for the emergency use of 

5 parasiticides and the conversion of native 

6 ecosystems. As with respect to the emergency use 

7 of parasiticides in organic livestock, consumers 

8 expect organic products to be free of inputs and 

9 clean of synthetic parasiticides. Until that 

10 reassurance is established, the use of synthetic 

11 parasiticides should be approached with caution. 

12 This is especially true because a well-managed 

13 livestock operation should not have any recurring 

14 parasite problems.

15 Cornucopia requests that the term 

16 "emergency" be defined in the regulations rather 

17 than with the guidance. The need for a strict 

18 definition is serious. As other commenters have 

19 said, the changes in withdrawal time for these 

20 substances will very likely lead to overuse. We 

21 believe that emergency should be defined strictly 

22 so these substances are never used unless an 
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1 animal's permanent welfare is immediately 

2 threatened by their parasite load. 

3 As to the issue of keeping high-value 

4 lands, in general, Cornucopia supports the Wild 

5 Farm Alliance's comments. We hope that the NOSB 

6 will consider information and understand what the 

7 Wild Farm Alliance brings to this issue. The NOP's 

8 waiting transition to organic production is 

9 critical to maintaining organic integrity. 

10 However, incentivizing farmers to convert pristine 

11 habitat in high-value lands by allowing them to 

12 immediately go into organic production flies in the 

13 face of biodiversity conservation and the basic 

14 tenets of organic production.

15 Cornucopia suggests the term 

16 "high-value conservation lands" be used instead of 

17 the term "native ecosystem." High-value 

18 conservation lands is a more inclusive term that 

19 is more accurate with regards to the problem at 

20 hand. We believe that using an eligibility period 

21 would de-incentivize conversion of high-value 

22 lands. The eligibility period we suggest require 
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1 that if the areas in question are damaged or 

2 destroyed within five years prior to a request for 

3 organic certification they will never be eligible 

4 for organic certification.

5 A rule change is needed to 

6 de-incentivize this destruction. A guidance will 

7 not suffice because the conversion of this land in 

8 question occurs prior to organic production, where 

9 NOP regulations currently apply to lands that are 

10 already certified.

11 We have made further recommendations 

12 and comments on both of these issues in the 

13 discussion documents and our official submitted 

14 comments that we hope will be helpful to NOSB. 

15 Thank you for this opportunity to provide any 

16 comments on these issues, and I would love to answer 

17 any questions you may have. 

18 MR. CHAPMAN: Thank you, Marie. I 

19 don't see any questions at this time. We'll be 

20 moving on to the next commenter. I have Dain 

21 Carver. Dain, are you here? Don't see your phone 

22 number. 
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1 MS. ARSENAULT: Right. We have three 

2 from that area code, but we don't see the exact 

3 number and no numbers have been typed in to the 

4 chat. 

5 MR. CHAPMAN: Dain, going once. Dain, 

6 going twice. We'll be moving on to Anne Ross. 

7 Anne, are you --

8 MS. ROSS: Yes, I'm here. 

9 MS. ARSENAULT: Okay, great. 

10 MS. ROSS: Can you hear me? 

11 MR. CHAPMAN: Yes. Give me one 

12 second, Anne. On deck after Anne is Michael 

13 Collins-Frias. Michael, if you could type in your 

14 phone number, that would be appreciated. Anne, go 

15 ahead. 

16 MS. ROSS: Good afternoon, everyone, 

17 and thank you for this opportunity to comment. My 

18 name is Anne Ross, and I'm a foreign policy analyst 

19 at The Cornucopia Institute. I'm a lawyer, and I 

20 have an advanced law degree in agricultural and 

21 food law. I'm also a consumer of organic food and 

22 a public health advocate. 
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1 The Handling Subcommittee has asked for 

2 comment from the use of chemical BPA in the 

3 packaging of organic foods. Cornucopia opposes 

4 the use of BPA for the following reasons: The 

5 founding principle of organic agriculture is that 

6 organic agriculture should sustain and enhance 

7 human health. Organic agriculture is intended to 

8 produce high-quality nutritious food that 

9 contributes to the health and well-being. The use 

10 of BPA in food packaging materials for organic food 

11 is entirely inconsistent with these principles and 

12 with NOP Regulations, Section 205.272, which 

13 prohibits the use of a substance which compromises 

14 the organic integrity of the product unless there 

15 is no risk of contact with the organically-produced 

16 product.

17 The use of BPA has inherent known risks 

18 that are far-reaching and clearly compromise 

19 organic integrity. BPA is an endocrine disruptor. 

20 BPA acts on the reproductive systems of males and 

21 females in ways which result not only in 

22 reproductive problems but are associated with the 
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1 development of cancer. BPA is linked to the 

2 development of type 2 diabetes. BPA is linked to 

3 the development of neurological, developmental, 

4 and behavioral problems in children. BPA acts in 

5 low doses and is especially concerning for our 

6 children.

7 Our laws acknowledge the devastating 

8 health effects of BPA but do not go far enough. For 

9 example, BPA is banned in formula bottles in the 

10 U.S., Canada, and the European Union. However, we 

11 must do more to protect the public health. BPA 

12 should be banned for use in all food contact 

13 materials, not just in infant formula bottles. In 

14 October 2016, the majority of the members of the 

15 European Parliament called for a ban of BPA in all 

16 food contact materials. The U.S. should follow 

17 suit, and the organic movement should take the lead 

18 to protect the public health and prohibit the use 

19 of BPA in all food contact materials used in organic 

20 agriculture to protect both children and the entire 

21 population. 

22 Thank you for your attention to this 
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1 very important issue. This concludes my comments. 

2 If there are any questions, I'll be happy to answer 

3 them. 

4 MR. CHAPMAN: Thank you, Anne. I 

5 don't see any questions at this time, so we'll be 

6 moving on to our next presenter. Is Michael 

7 Collins on the line? 

8 Sorry, Anne, if you're still there, I 

9 do have a question from Asa. 

10 MR. BRADMAN: Hi. Can you hear me 

11 okay? I just want to ask if you had considered some 

12 of the issues with food contact materials for other 

13 substances, as well, and considered the 

14 implications of that for other compounds. Thanks. 

15 MS. ROSS: Yes, Asa. We're very 

16 concerned about the other substances, but the 

17 scientific evidence on BPA is longstanding and the 

18 adverse health effects are well documented. And 

19 so at this time, we focused on BPA. 

20 MR. BRADMAN: Okay. Thanks. I don't 

21 think there's more to talk about right now, but I 

22 think this is an important issue as we go forward.
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1 MS. ROSS: Yes, thank you. And we've 

2 also submitted a comment on this, a formal comment, 

3 for review, as well. 

4 MR. BRADMAN: Thank you. 

5 MR. CHAPMAN: Thank you very much. So 

6 back up next is Michael Collins-Frias. Michael, 

7 are you on the line? Okay. There seems to be a 

8 series of folks here that we may not have identified 

9 on the line, so I'm going to read a few names here. 

10 Karen Archipley, Colin Archipley, and Larry 

11 Griffis, all from 760 area codes. Are any of you 

12 folks on the line? 

13 All right. Hearing none, we will be 

14 skipping past all of those, and next up is Jane 

15 Sooby. Jane, are you on the line? 

16 MS. SOOBY: Yes. 

17 MR. CHAPMAN: All right.

18 MS. SOOBY: Good afternoon.

19 MR. CHAPMAN: Sorry. One second, 

20 Jane. Up after Jane will be Barry Flamm. Barry, 

21 we found you, so I don't need your number. Jane, 

22 go ahead. 
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1 MS. SOOBY: Thank you. Good afternoon 

2 and thank you, NOSB members and NOP staff, for all 

3 of your hard work in protecting organic integrity.

4 I'm with CCOF, a non-profit 

5 organization that's governed by the people who grow 

6 and make our food. We were founded in California 

7 more than 40 years ago, and CCOF advocates on behalf 

8 of our members for organic policies. We support 

9 the growth of organics through education and 

10 grants, and we also provide organic certification 

11 services.

12 From the certifier perspective, CCOF 

13 supports maintaining a clear, consistent 

14 regulatory environment for organic producers of 

15 all scales and types. CCOF supports the Handling 

16 Subcommittee's proposals to change the annotation 

17 of the tocopherol listing in 205.605(b) of the 

18 National List and also to accept the list of 

19 additional functional classes of ancillary 

20 substances permitted for use in cellulose. 

21 CCOF supports changing the annotation 

22 of the Tocopherol listing in 205.605(b) because it 
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1 will encourage the use of organic and non-synthetic 

2 tocopherols by organic food manufacturers, and it 

3 will create increased demand for production of 

4 organic tocopherol.

5 CCOF also supports the Handling 

6 Subcommittee's proposal to accept the list of 

7 additional functional classes of ancillary 

8 substances permitted for use in cellulose. CCOF 

9 commends the Handling Subcommittee for their hard 

10 work in making progress on assessing these 

11 ancillary substances by classifying their 

12 functional group. Organic manufacturers and 

13 certifiers require clear guidance on these 

14 substances. Ancillary substances are minor 

15 additives to other minor ingredients. The organic 

16 sector is, unfortunately, not yet large enough to 

17 generate adequate demand for minor ingredients 

18 free of these ancillary substances. So from that 

19 perspective, CCOF supports the proposal. Thank 

20 you very much for your time. 

21

22 MR. CHAPMAN: Thank you, Jane. At 
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1 this time, I don't see any questions. Next up --

2 MS. ARSENAULT: If you have a dog, if 

3 somebody has a dog in the background, if you could 

4 put yourself on mute and not telling it to speak. 

5 MR. CHAPMAN: Next up, we have Barry 

6 Flamm. After Barry, we have Andrew Tomes. 

7 Andrew, it sounds like we found you, so no need to 

8 type in the phone number. Barry, you are up. 

9 MR. FLAMM: Thank you. I'm very 

10 pleased that the CACS has issued a discussion on 

11 eliminating the incentive to convert native 

12 ecosystems for organic production. I appreciate 

13 and understand somewhat the hard work that's 

14 involved, as I am a former NOP member and also board 

15 chair.

16 I have worked on this issue closely with 

17 Wild Farm Alliance and with The Cornucopia 

18 Institute, where I'm a board member. And I do 

19 support their detailed comments.

20 In 2008, I chaired a joint CAC and Crops 

21 Committee that developed a discussion document 

22 which led to the 2009 Supplier Diversity Guidance 
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1 Statement. In this statement, it converted 

2 high-value conservation areas to organic 

3 production and identified there's a problem. 

4 Again, in 2012, I chaired an effort to review the 

5 progress in implementing the board's 

6 recommendation action in considering biodiversity 

7 and creating incentive to convert chemicals from 

8 the area.

9 Thankfully, in the last couple of 

10 years, I've witnessed an increased interest in 

11 dealing with the problem in the public groups and 

12 also in NOSB. I believe a necessary step is adopt 

13 a policy that states organic management does not 

14 entertain any action that negatively impacts 

15 high-conservation terrestrial and aquatic 

16 ecosystems and that the clearing of 

17 high-conservation is prohibited. These negatives 

18 must not have occurred on the parcel when they were 

19 released five years at the date of the 

20 certification application. This is not a perfect 

21 solution but should reduce the incentive to gain 

22 a quick profit by taking advantage of the present 
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1 rule. 

2 As you know, the organic means a lot to 

3 consumers. Sorry for the bird sounds. It should 

4 mean that the products produced did not come from 

5 high-conservation lands or aquatic systems that 

6 were recently destroyed or damaged for profit, not 

7 having to wait the three-year transition period. 

8 I know there are questions about how big 

9 a problem this is, but folks, we haven't had a 

10 problem that has not been any attempt to really 

11 determine the acreage involved. I hope the 

12 problem is not as extensive as it could be, but the 

13 pressure will increase as the organic market 

14 increases, which we hope will occur. To address 

15 this problem, I think we should adopt the policies 

16 suggested above and also develop an implementation 

17 process to complement our already developed good 

18 organic systems. Organics better achieves its 

19 lofty goals when it can chemical and other 

20 non-sustainable farming practice ending 

21 ecologically-healthy organic farming. Thank you. 

22 MR. CHAPMAN: Thank you very much, 
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1 Barry. At this time, I don't see any questions for 

2 you, so we'll be moving on to the next commenter, 

3 Andrew Tomes. Andrew? And up next is Reyna 

4 Ventura. Reyna, if you can type in your number. 

5 We're not seeing you. After Reyna is Tim Mann. If 

6 you could also type in your number and realize 

7 you're on deck. Andrew? 

8 MR. TOMES: Hi. I work for a company 

9 that makes organic liquid fertilizer out of food 

10 waste. I would like to address the 

11 recommendations for restrictions on bioponic 

12 production liquid fertilizer use in containerized 

13 systems. 

14 The rationale for these changes, indoor 

15 plant production cannot advance the NOP's 

16 objectives of improving soil and contributing to 

17 a diverse agroecosystem is a narrow reading. The 

18 NOSB should consider other requirements the NOP 

19 endorsed, including safety, affordability, and 

20 reduced emissions.

21 To consumers, it's a constellation of 

22 meanings ranging from lower environmental impact 
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1 to reduced use of chemicals and what cultivation 

2 methods offer these benefits. The lower test 

3 pressure and indoor systems leads to lower worker 

4 pesticide exposure. Indoor methods can also be 

5 employed in urban areas where land is unavailable 

6 and reducing the emissions and associated costs of 

7 transportation.

8 Further, the reasons supplied for 

9 restricting bioponics may cause negative impacts 

10 if extended to other indoor production methods. 

11 For example, this kind of container raised the 

12 concern that this method resembles hydroponics in 

13 its use of external inputs and the perceived lack 

14 of commitment to building a healthy soil 

15 microbiome.

16 Organic nutrients are processed the 

17 same way by the same microbes, regardless if 

18 they're moist or not. Liquid fertilizers offer 

19 growers, indoors and out, the chance to respond

20 quickly to nutrient needs during the growing season 

21 and are a valuable tool and should not be curtailed. 

22 Growers should have access to the most effective 
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1 options available among organic food-derived 

2 inputs and have the right to tailor programs to the 

3 needs of plants and production systems.

4 Indoor production practices are 

5 becoming increasingly essential to a secure food 

6 supply. Right now, the NOSB is facing a choice 

7 between shaping this trend or ignoring it. By 

8 developing standards that correct bioponics toward 

9 the larger goal of creating a system that benefits 

10 both people and the environment, the NOSB can 

11 address problematic aspects of indoor production 

12 and drive change.

13 If the incentive to follow the NOP 

14 disappears, users of these methods may return to 

15 conventional practices. We shouldn't be asking 

16 can bioponics be organic. Instead, we should ask 

17 how do we make bioponics organic. Thank you. 

18 MR. CHAPMAN: Thank you, Andrew. I 

19 don't see any questions at this time, so we'll move 

20 on to the next speaker. Is Reyna on the line? 

21 MS. ARSENAULT: We have not seen a 

22 number from Reyna yet and not on the headsets 
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1 either.

2 MR. CHAPMAN: Yes. Is Tim Mann on the 

3 line? I haven't seen an 808 number either. Is 

4 Esteban on the line or Thomas Laginess? 

5 MR. LAGINESS: Tom Laginess, yes.

6 MR. CHAPMAN: Okay, Tom. You're right 

7 here. We'll probably skip to you next, if you're 

8 ready. Before we do that, Mabell, you'll be next. 

9 I see you just typed in your number. So we'll start 

10 with Tom, and Mabell is next. Tom, go ahead. 

11 MR. LAGINESS: Okay. Yes, good 

12 afternoon. My name is Tom Laginess, and I'm a 

13 senior sustainability specialist with BASF 

14 Corporation based out of our offices near Detroit, 

15 Michigan. I'm a scientist with a specialized role 

16 in managing the stewardship of our products and 

17 their intended applications. I am also a row crop 

18 farmer in Southeast Michigan. Sustainability and 

19 stewardship are two keys at BASF, and I thank you 

20 for taking the time to consider the science of 

21 biodegradable mulch films.

22 Today, I wish to address only one topic 
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1 regarding biodegradable mulch films. Do 

2 biodegradable mulch films have to be bio-based in 

3 order to be biodegradable? The answer is no. 

4 Unfortunately, this fact has not been shared 

5 widely. As a result of this, there has been much 

6 confusion and discussion on this topic.

7 This confusion has led to the addition 

8 of problematic language in the regulation around 

9 the use of biodegradable mulch films after the 

10 material was added to the National List. For a 

11 brief background, please consider that microbes 

12 will eat any material that they view as food. 

13 Today, biodegradable mulch films are made from 

14 polymers that were designed for two purposes: one, 

15 performance in the field for the farmer; and, two, 

16 consumption by microbes. The polymer itself is 

17 what determines these two performance features.

18 These polymers are made from monomers 

19 which can be made from either bio-based feed stock 

20 or fossil sources. The origin of the monomers has 

21 no bearing on the performance features in the film. 

22 Only the final polymer determines performance.
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1 In my role, I frequently work on 

2 projects to measure total sustainable attributes 

3 of a material for a given application. To do this, 

4 we use life cycle to measure environmental, 

5 economic, and social impacts. 

6 I submitted a written comment, number 

7 1751, which shows some examples of past work we have 

8 done in comparing bio-based materials versus 

9 fossil-based materials for a given application. 

10 These examples show that if we look at the total 

11 sustainability perspective, bio-based sources are 

12 not always more sustainable.

13 If the NOSB truly holds an interest in 

14 sound science and sustainability as its primary 

15 standard for preserving organic integrity, please 

16 consider the interests of the farmers. The 

17 challenges of the organic farmer are well known. 

18 They deserve -- pardon me? 

19 PARTICIPANT: Okay. I'm on the phone.

20 MR. CHAPMAN: Sorry. We have someone 

21 speaking in the background. 

22 MR. LAGINESS: The challenges of the 
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1 organic farmer are well known. They deserve 

2 access to new tools that have helped them with both 

3 their environmental and economic impact. 

4 Biodegradable mulch films have been shown to 

5 provide a positive impact to farmers in these areas 

6 with reducing labor costs, top soil, and 

7 eliminating challenges in film removal and 

8 disposal.

9 Today, I wish to address any of your 

10 questions regarding sustainability. In order to 

11 have a proper dialogue on the technology itself, 

12 along with the current state of regulations, we 

13 invite this board, along with other stakeholders, 

14 to join a public webinar to be scheduled in the 

15 coming months. We have spent the past years trying 

16 to go up through the existing channels to 

17 communicate the details of this technology with no 

18 success in remedying the problematic language in 

19 the regulation. Had this language requiring 

20 100-percent bio-based content been open to the 

21 public comment, we could have addressed it at that 

22 time. 
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1 Our concern is that the technology has 

2 been lost forever challenging discourse. Most 

3 recently, we wrote a public comment, 1760, 

4 regarding technical areas and misrepresentation of 

5 the 2016 Technical Evaluation Report. We 

6 recognize in the meantime that some of the 

7 problematic topics have since promulgated through 

8 the public comment in the current docket. So we 

9 ask you to consider the path forward, as proposed 

10 by the EPA and Biodegradable Product Institute in 

11 public comment 2040. We see three potential paths 

12 forward and this proposal as the best option. 

13 MS. ARSENAULT: Okay. Thank you very 

14 much. Tom, are you with us? 

15 MR. CHAPMAN: Yes, sorry. I was 

16 self-muting myself there. Tom, I have a question 

17 for you from Asa. Asa? 

18 MR. BRADMAN: Yes, hi. I'm educating 

19 myself on this issue. You said that some of the 

20 fully 100-percent bio-based materials are less 

21 sustainable than mixed materials, and I wonder if 

22 you could comment a little more on that or perhaps 
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1 there's going to be some additional comments for 

2 the meeting.

3 Then I think, you know, for example, 

4 synthetic pesticide, like organophosphate, is also 

5 consumable by microbes. They can certainly make 

6 use of those carbons. So I guess my question is 

7 related to that. If you were putting a synthetic 

8 material into an organic field, in other words 

9 material that's not 100-percent bio-based, you 

10 know, what percentage of this synthetic material 

11 you think is consumed by those microbes and what 

12 are we left with? 

13 MR. LAGINESS: Well, to do, I guess, to 

14 do it justice, you'd have to actually look at each 

15 of the materials. I mean, what I'm talking about, 

16 the biodegradable mulch films, you'd have to look 

17 at each individual film and then you'd have to look 

18 at potentially different areas of the country to 

19 see what the biodegradation or the makeup of the 

20 microbes, the take-up of the microbes would be in 

21 those areas because everything, you know, 

22 temperature, water, all those things have an effect 
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1 on the take-up of that.

2 We actually do analysis studies, and we 

3 have currently some going on to determine, with our 

4 product, what's the impact of that to the microbes. 

5 But, you know, mainly, the biodegradable plastic 

6 will break down the CO2 water and then some biomass 

7 left over from the microbes. 

8 MR. BRADMAN: And what percentage of 

9 the materials you're using are bio-based versus 

10 petroleum-based? 

11 MR. LAGINESS: Well, our current -- and 

12 you're talking about our current product, or are 

13 you talking about --

14 MR. BRADMAN: Well, I guess so, if you 

15 could --

16 MR. LAGINESS: Okay. Currently, let 

17 me just talk about the market in general. 

18 Currently, there is no, not to my knowledge, 

19 there's no 100-percent bio-based biodegradable 

20 mulch film that is available. Most of the 

21 biodegradable mulch, or I should say most of the 

22 biodegradable mulch films contain anywhere from 
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1 10- to 20-percent bio-based material. The rest of 

2 the materials are fossil-based material, and that 

3 was my whole point. It doesn't necessarily have 

4 to be bio-based or fossil-based. It ends up being 

5 what the end product is will determine if it's 

6 biodegradable or not. You could have a bio-based 

7 product that's 80- or 90-percent bio-based that may 

8 not biodegrade. It just depends on the actual 

9 polymers and the things added with it and the bonds 

10 of those polymers. 

11 MR. BRADMAN: Okay, all right. Thank 

12 you for that clarification. And like I said, I'm 

13 kind of in the process of educating myself on these 

14 issues, and I look forward to seeing more 

15 discussion about it.

16 MR. LAGINESS: Okay, thank you. 

17 MR. CHAPMAN: Thank you, Asa. I also 

18 have a question from Harriet. 

19 MS. BEHAR: Hi. Yes, the polymers 

20 you're talking about, they are petroleum-based 

21 products; is that correct? 

22 MR. LAGINESS: The monomers are 
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1 actually petroleum-based, yes, correct. 

2 MS. BEHAR: Right. So I think part of 

3 our question, too, was, since we don't allow 

4 synthetic from a petroleum-based product, I think 

5 part of our search was to see, you know, is this 

6 a fertility input when it's breaking down, what 

7 does this product actually do? And I was wondering 

8 if we could get, perhaps in the future, if you have 

9 more research on this, then maybe we might say 

10 something with at least 60-percent bio and 

11 40-percent polymer or something like that that 

12 might mitigate the issue of breaking down of 

13 petroleum-based products in the soil. 

14 MR. LAGINESS: Yes, interesting. 

15 Next week, I believe, at your in-person meeting, 

16 we are actually, our BASF colleague from Germany, 

17 Katharina Schlegel, she's a soil microbiologist in 

18 our R&D group in Germany, she is going to be at that 

19 face-to-face meeting next week. So we should be 

20 able to answer, I'd guess, clearly exactly your 

21 technical breakdowns of that.

22 MR. BRADMAN: This is Asa again. 
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1 Another question I have is when you do studies of 

2 residues from these materials, are they done in 

3 fields, and how are they sampled? And is it also 

4 possible to do kind of smaller, almost, you know, 

5 physically smaller in laboratory studies? One 

6 thing I'm concerned about is that if you put it in 

7 a field and we, for example, dig down and collect 

8 a big soil sample, it could be diluting any 

9 contaminants to the point where they're not 

10 detectable but they still might be present perhaps 

11 in higher concentrations in the upper layers. So 

12 I'm curious if you've done any kind of 

13 in-laboratory degradation studies?

14 MR. LAGINESS: Again, I'd have to refer 

15 to my German colleague that's going to be their 

16 face-to-face meeting next week, Katharina. She 

17 would be able to answer that. I'm more of the 

18 sustainability and the environmental expert for 

19 BASF and the actual microbiology of the actual 

20 plastic.

21 MR. BRADMAN: Okay, thank you. 

22 MR. CHAPMAN: Thank you, Tom, for your 
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1 comments and answering our questions. Up next is 

2 Mabell. After Mabell, we have Davey Miskell. 

3 Davey, we found you, so no need to type in your 

4 number. Mabell, you're up. 

5 MS. RIVAS: Can you hear me?

6 MR. CHAPMAN: Yes, we can.

7 MS. RIVAS: Okay, good. Hello. 

8 Mabell Rivas. I'm a senior reviewer at QAI. 

9 Thank you for the opportunity to comment today. 

10 First, we would like to welcome the new 

11 NOSB members with a shout-out to David Mortensen 

12 who has come from my neck of the woods here in 

13 Central Pennsylvania. And thank you all for 

14 volunteering to serve on this board.

15 The document that was provided to you 

16 all this morning includes tables with information 

17 about the usage of crops, livestock, and handling 

18 materials. We hope that this type of information 

19 is useful to the Board as we deliberate on the 

20 totality of these materials. Please note that, 

21 for handling materials, we cover only those 

22 materials for which more information was requested 
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1 by the Board.

2 Today, I'll just quickly talk on three 

3 materials. First, chlorine. This is a 

4 widely-used material in the organic production. 

5 QAI has over 300 clients using chlorine, most using 

6 sodium hypochlorite. This is a decision with big 

7 impacts for sure.

8 Sometimes a function can be handled by 

9 peracetic acid or alcohol. But in other 

10 situations, usually the nature of the processes 

11 involved, operations have to rely on chlorine and 

12 even quaternary ammonia, which has higher residual 

13 characteristics. Also, it appears that for a new 

14 safety regulations format, more aggressive 

15 qualification measures need to be implemented. 

16 As we have commented in the past, we 

17 agreed that it would be wise to prioritize 

18 (inaudible) alternative to chlorine. NSF, our 

19 parent company, might be able to provide some 

20 assistance to our involvement in this research 

21 process.

22 Then on potassium acid tartrate and the 
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1 question as to how to classify this material, I am 

2 no expert in the process of making cream of tartar. 

3 However, based on the information about the 

4 manufacturing process of these materials, we sent 

5 in response a proposal. This substance is the 

6 byproduct of wine making, and, specifically, this 

7 substance is extracted from the sediment in the 

8 wine-making process. This means that the sediment 

9 contains not only plant material, that is grapes, 

10 but also non-agricultural materials. Thus, 

11 making this non-agricultural. As a result, the 

12 material might be considered non-agricultural, 

13 non-synthetic, and it should be listed in 

14 205.605(a).

15 And, lastly, on pectins, it appears 

16 that organic pectin is not readily available, at 

17 least on a couple of those use something called 

18 apple powder pectin that is ordinarily sold to 

19 consumers as a supplement, but we're not aware of 

20 any organic testing marketed for use in handling. 

21 We do not certify any handler who makes organic 

22 pectin.
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1 And that's it for me today. Thank you 

2 and have a great meeting. 

3 MR. CHAPMAN: Thank you, Mabell. I 

4 don't see any questions at this time. We will be 

5 moving on to the next speaker. 

6 Before we move on, I just want to note 

7 that we're about 45 minutes ahead of schedule. 

8 It's significantly ahead of schedule for us. If 

9 we are, if time allows, at the end, and I did skip 

10 over someone who had signed up for the webinar, we 

11 will go back and call on anyone at that point for 

12 people who had already signed up and if time does 

13 allow.

14 That being said, we're going to 

15 continue then ahead of schedule, and up next is 

16 Davey Miskell with Jane Bell on deck. And, Jane, 

17 it looks like we found you, so no need to type in 

18 your number. Davey?

19 MR. MISKELL: Yes. My name is David 

20 Miskell, and I'm a certified Vermont organic farmer 

21 and I'm growing greens and basil in greenhouses in 

22 Charlotte, Vermont. I used to grow organic 
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1 greenhouse tomatoes beginning in 1982. Our farm 

2 mission is to life and life soils (inaudible). My 

3 organic tomato-growing methods were not mainlining 

4 nutrients, so I got --- it actually yields a better 

5 taste. Recently, Al Franken, the lobbyist for 

6 hydro-organic farming, gave a figure of $1 billion 

7 of soilless organic production. 

8 Such production has been illegally 

9 allowed by NOP -- we did not establish a new rule 

10 through a public hearing process. Also, NOP has 

11 allowed no notice to consumers that they're buying 

12 soil-less organic hydroponic veggies, as they're 

13 only labeled USDA-certified. If the soil-less 

14 organic growers are so proud of the method, why not 

15 say it on the label?

16 The NOP set up a task force heavily 

17 weighted towards hydroponics proponents. The 

18 proponents never really tell how they fertilize 

19 their crops. Their testimony at the April and 

20 November NOSB meetings all talked about compost 

21 tea. Through my experience as an organic 

22 greenhouse tomato grower, compost teas do not 
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1 provide sufficient fertilization. It is 

2 politically correct, but tomatoes would die at such 

3 a regimen without intensive mainlining with 

4 sufficient very soluble liquid fertilizer. 

5 Any discussions during meetings or 

6 committees, you should get answers to the following 

7 questions before making any decisions on 

8 hydroponic container certification. One, what 

9 liquid fertilizers are they using and the 

10 solubility issues with such fertilizers? Two, 

11 what percentage of their nutrient program consists 

12 of liquid fertilizing? I recommend that no more 

13 than ten percent of the total certifiable organic 

14 fertilizing program should be allowed. My crops 

15 and most soil-based farms do not need such to 

16 continue. 

17 Three, how will you determine how much 

18 soil is allowed to container-grown plants? My 

19 recommendation is at least 50 percent of any 

20 container production must be based on soil compost. 

21 The present practice of allowing 100 percent 

22 substrate base in containers is a disgrace and does 
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1 not meet any of the OTA and NOP rules related to 

2 soil. 

3 Four, all soil-based organic farms must 

4 meet a three-year waiting period for any 

5 application of chemical fertilizers, fungicides, 

6 herbicide use on the soil. Soil, quote, 

7 hydroponics farms can pave over --

8 MR. CHAPMAN: We've come to the end of 

9 your time. Do you want to sum up in a sentence? 

10 MR. MISKELL: Yes. The best solution 

11 that meets the above-stated OEFFA and NOP rules is 

12 for the crop community to support the guidance of 

13 the European standards that all consumable 

14 vegetables and fruit must be grown on soil 

15 connected to the earth. Presently, EU is 

16 tightening their greenhouse standards by adopting 

17 --

18 MR. CHAPMAN: I'm going to have to cut 

19 you off. We're at the end of your time.

20 MR. MISKELL: Thanks for your help. 

21 MR. CHAPMAN: Yes. I do have a 

22 question for you. You recommended ten-percent 
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1 liquid fertilizing. How did you, what's the 

2 justification for a ten-percent number? 

3 MR. MISKELL: That is about what I use 

4 in my growing methods. I even use less than that. 

5 So that's been the justification.

6 MR. CHAPMAN: Thank you very much. I 

7 don't see any other questions from Board members, 

8 so we will continue on. Thank you very much for 

9 your testimony, Davey. Next up, we have Jane Bell 

10 and on deck Lynne Haynor and I believe, Jane, 

11 correct me if I'm wrong, we have -- I see it listed 

12 multiple times, so we don't need to type that one 

13 in. Jane, you are up.

14 MS. BELL: Thank you much. Thank you 

15 for having me this morning, this afternoon. My 

16 name is Jane Bell. I am part of the 

17 ninth-generation organic berry, poultry, beef, 

18 pork, and vegetable farm on the easternmost coast 

19 of Maine in Edmunds Township. Our family has 

20 farmed this land Tide Mill Farm since 1765. 

21 My comment today is regarding the 

22 marine algae proposal, especially, mostly number 
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1 two on whether NOP should provide further guidance 

2 on marine algae, to harvest it. There is no 

3 question that further guidance is, in fact, needed, 

4 and I strongly urge you to vote yes on motion two. 

5 I'm focusing today on the one point that 

6 there is a gross discrepancy between the rigor of 

7 inspections that we, as an organic farm, go through 

8 to obtain and keep our organic certificate that is

9 granted by Maine Organic Farmers and Gardeners 

10 Association. What I understand about the 

11 inspection for organic marine algae harvesting is 

12 it's more of an honor system. There's a wild 

13 harvest of seaweed in our Cobscook Bay. 

14 The difference in that inspection 

15 process appears to be this honor system of show how 

16 wild crop habitats in surrounding environments is 

17 preserved so that wild crop populations remain, and 

18 questions such as what rare, threatened, or 

19 endangered plants or animals are found in the wild 

20 crops. Those sort of questions are vague compared 

21 to what our farm endures and goes through each year. 

22 I'm holding a packet that is our 
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1 certificate, that resulted in our certificate from 

2 Maine Organic Farmers and Gardeners, and it's about 

3 an inch and a half-thick, very detailed questions. 

4 One of the questions that we have is describe 

5 distances, buffer strips, type of buffer, and 

6 efforts undertaken to reduce the risk of 

7 contamination. These buffers must be identified 

8 on their field maps.

9 In order for us to ensure that our 

10 organic product, which is certified each year, has 

11 not been contaminated, we have to provide detailed 

12 maps, papers and papers and papers, and go through 

13 a three-day inspection on our farm. 

14 So the difference here is we are looking 

15 at marine algae harvest within a two-country bay 

16 up here. And I find it hard to document and ensure 

17 that, in this two-country bay, that contaminants 

18 are not being exposed. 

19 So in conclusion, I would like to urge 

20 you to vote yes on motion two for the emphasis 

21 yearly, further emphasis is put on this evaluation 

22 process. I don't understand, as an organic 
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1 farmer, how the scrutiny that we undergo --

2 MR. CHAPMAN: Thank you, Jane. We've 

3 come to the end of your time. I don't see any 

4 questions here for you, so thank you for your 

5 testimony, and we will move on to the next 

6 presenter. We have Lynne --

7 MS. HAYNOR: Haynor.

8 MR. CHAPMAN: -- Haynor.

9 MS. HAYNOR: Can you hear me?

10 MR. CHAPMAN: Yes, we can. And hold on 

11 one second, Lynne. Up after you is Kelly Taveras. 

12 Sorry, I should have apologized up-front. I don't 

13 know how I will butcher your name, but I do 

14 guarantee I will butcher your name. So, Kelly, 

15 you're up next. Lynne, go ahead. 

16 MS. HAYNOR: Good afternoon. My name 

17 is Lynne Haynor, and I'm a certification team 

18 leader at MOSA, an organic certifier for 

19 approximately 2,000 operations located in Viroqua, 

20 Wisconsin. 

21 Today, I'm commenting on the proposal 

22 on strengthening the organic seed guidance. Thank 
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1 you for the opportunity.

2 MOSA has submitted written comments on 

3 this proposal guided by the principles of fostering 

4 and enforcing organic integrity, cultivating 

5 consumer trust in the organic label, considering 

6 the impact on the organic operator, and striving 

7 to not overburden organic operations or certifiers 

8 with additional record-keeping requirements when 

9 compliance is not in question. I'll highlight 

10 part of our written comments today.

11 The proposal put forward in amendment 

12 to NOS 205.204(a), which states "the producer must 

13 use organically-grown seed, annual seedlings, and 

14 planting stock with the proposed addition of A1I, 

15 improvement in sourcing and use of organic seed and 

16 planting stock must be demonstrated every year 

17 until full compliance is achieved."

18 This proposed language implies that, 

19 once a producer uses only organic seed, that 

20 producer can never again source non-organic seed. 

21 And while we appreciate the intent of this proposed 

22 addition, we caution that this requirement may 
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1 disable organic farmers who need specially-adapted 

2 seed. Particularly, it may hamstring organic 

3 farmers who have been early adopters of sourcing 

4 organic seed from being able to flexibly adapt to 

5 changing markets or environmental conditions.

6 We do support strengthening the need 

7 for continuous improvement within the organic seed 

8 guidance and specifying the enforcement tools 

9 available to certifiers. And in our written 

10 public comment, MOSA proposed additions to Section 

11 4.4.4(a), role of certifying agents.

12 MOSA's comments also note portions of 

13 the proposed additions may be challenging to 

14 interpret from an enforcement standpoint. For 

15 example, the proposed addition 4.4.5 states 

16 "certifying agents should review the preventive 

17 measures taken to avoid contamination for seeds of 

18 at-risk crops." While we appreciate the spirit of 

19 the addition, the language is vague. All organic 

20 operations are required to have strategies for 

21 prevention of contamination and co-mingling, and 

22 certifiers evaluate this compliance annually. 
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1 The term "at-risk crop" is not clearly defined, and 

2 certifiers need additional guidance regarding what 

3 to do when GMO contamination is found, yet all 

4 organic production and handling practices appear 

5 compliant. 

6 I would also express concern that the 

7 current responsibility for preventing GMO 

8 contamination unfairly burdens organic and non-GMO 

9 producers. And while the organic community 

10 continues productive work to guard against GMO 

11 incursion, USDA leadership is critical for 

12 ensuring that the responsibility for preventing 

13 GMO contamination is shared. Without meaningful 

14 shared responsibility, coexistence cannot work and 

15 the organic label is harmed.

16 Thank you for your work on this 

17 challenging issue. 

18 MR. CHAPMAN: Thank you very much. I 

19 don't see any questions, but thank you for your 

20 testimony. And up next, we'll have Kelly. After 

21 Kelly, I have Herman Freiesen. 

22 MS. ARSENAULT: We have Herman. We're 
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1 good. He's on. 

2 MR. CHAPMAN: Okay. Herman after 

3 Kelly. Kelly, you're up. 

4 MS. TAVERAS: Great, thanks. Good 

5 afternoon. My name is Kelly Taveras, and I serve 

6 as the digital specialist for the Organic Trade 

7 Association. On behalf of OTA, I'd like to welcome 

8 the new Board members and thank you for beginning 

9 the journey of critical and greatly-appreciated 

10 service to the organic sector.

11 My colleagues will speak on specific 

12 agenda topics at the in-person meeting, and you 

13 have our detailed written comments. So my remarks 

14 will focus on an introduction to OTA and its 

15 membership, our NOSB common process, and the work 

16 we've been doing to present that material review.

17 A bit about the Organic Trade 

18 Association. One of OTA's strongest assets is the 

19 diversity and breadth of our membership. Unlike 

20 many trade associations, OTA is uniquely 

21 structured to include the full-value chain of the 

22 organic industry, ensuring that all segments, from 
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1 farm to marketplace, have strong voices in the 

2 organization.

3 OTA brings farmers and growers and 

4 suppliers, processors, manufacturers, 

5 distributors, retailers, and many others together 

6 to promote and protect the growing organic sector. 

7 We represent over 9500 businesses in all 50 states. 

8 Half of OTA members are small businesses reporting 

9 less than a million in organic sales per year. 

10 OTA's members are represented either through 

11 direct membership or through strategic 

12 partnerships with regional organic farmer 

13 organizations across the U.S. through our Farmers 

14 Advisory Council, or FAC is what we call it. 

15 Smaller organic farmers that have current 

16 memberships with one of the participating 

17 organizations belonging to FAC are able to obtain 

18 full OTA membership with all its associated 

19 benefits for a minimal fee through our farm fed 

20 membership category. 

21 OTA's membership is completely 

22 transparent. You can find our complete member 
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1 list at OTA.com. On our website, you'll see 

2 clearly stated information on how to become a 

3 member, what the benefits of membership are, and, 

4 even more importantly, how we engage members in our 

5 advocacy work. 

6 Our membership is governed by a 

7 democratically-elected board of directors, 

8 ensuring that we are accurately representing our 

9 stakeholders. 

10 The comments OTA submitted to NOSB was 

11 our membership. In order to do this, our 

12 regulatory staff carries out an extensive 

13 engagement process so we can understand how NOSB 

14 recommendations will impact certified farmers and 

15 handlers on a day-to-day basis. The feedback 

16 collected informs our draft comments that are 

17 distributed to the full membership at least a week 

18 in advance of the comment deadline. 

19 Although OTA was very challenged by the 

20 shortened comment period, we were able to convene 

21 a task force on the topic of bioponics and, as well, 

22 organic seed usage. And members were provided 
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1 with an opportunity to weigh in and informed all 

2 of the final comments we submitted. 

3 With respect to the 2019 sunset materials, to 

4 help facilitate a thorough comment review process, 

5 OTA created an electronic survey for each 

6 individual under review. The surveys are 

7 confidential, user friendly, available to every 

8 NOP certificate holder, and includes seven to ten 

9 questions addressing the necessity or essentiality 

10 of the input under review.

11 Our written comments include all the 

12 survey responses we received to date, and we are 

13 proud to have collected a total of 65 unique 

14 responses. And we'll continue to collect 

15 responses to inform that will take place in the 

16 fall. 

17 Thank you to the Board for your hard 

18 work and commitment to furthering organic. And 

19 that's it for me today. 

20 MR. CHAPMAN: Thank you very much, 

21 Kelly. I don't see any questions, so we'll move 

22 on to the next presenter. Next up is Herman, and, 
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1 after Herman, we have Guillermo Martinez. If you 

2 could type in your phone number, that would be 

3 appreciated. Herman, are you on the line? 

4 MS. ARSENAULT: He was on. We found 

5 him. 

6 MR. CHAPMAN: Herman, are you muted on 

7 your end? Your number is here, but we don't hear 

8 you. We're not hearing you, Herman. Right. We 

9 will keep going down the list then. Guillermo, are 

10 you on the line? 

11 MR. MARTINEZ: Yes, I am.

12 MR. CHAPMAN: All right. Go ahead. 

13 And after Guillermo, we have Nathan. 

14 MS. ARSENAULT: This one has a slide 

15 show, so if you are online monitoring, if you've 

16 been multi-tasking, you can switch over to the 

17 slide show. And please tell us when you're ready 

18 for us to advance to the next slide.

19 MR. CHAPMAN: Thank you. And, Nathan, 

20 if you could type in your phone number, that would 

21 be appreciated. Guillermo, you're up. 

22 MR. MARTINEZ: Hi. I'm Guillermo 
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1 Martinez. I'm the general manager of Kingdom 

2 Fresh. We are a grower and marketers of organic 

3 tomatoes. And I would like to thank you in advance 

4 for the chance to comment today.

5 Next. With respect to specific 

6 conditions, container growing is a lot more 

7 sustainable for environment than growing in soil. 

8 Water is a scarce and precious resource where our 

9 farms are located. A hundred-percent of the water 

10 that we use comes from deep wells. Using 

11 containers for growing assure us that we use the 

12 water efficiently. We nurture each plant with the 

13 right amount of water, so there is no waste. We 

14 recycle all the containers to use it again in crops, 

15 helping to reduce water consumption.

16 Next. We use a rich soil in our 

17 containers. We combine certified organic 

18 materials that helps us achieve better yields and 

19 reduce the use of inputs. The materials that we 

20 use are certified organic compost from different 

21 sources, such as corn and vegetable residues with 

22 high nutrients, plus microorganisms that create an 
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1 active biology in the container.

2 At the end of our cycles, we use those 

3 materials from our containers to incorporate into 

4 corn and soybean fields to help those fields 

5 re-establish their active soil biology to improve 

6 the fertility and totality of the fields. So using 

7 container-growing methods do not just help us 

8 maintain the richness and naturalness of the soil 

9 where the crop has been cultivated, but it also 

10 maintains the richness and naturalness of other 

11 fields as part of our process of continually 

12 recycling materials and nutrients. This is 

13 sustainable and helps the environment in the most 

14 efficient and natural way. 

15 Next. Using containers in greenhouse 

16 growing methods help us to achieve better yields 

17 per acre, assuring more supply for the growing 

18 demands for organic produce. We believe it's the 

19 obligation of organic producers to strive to make 

20 organic produce affordable for American families. 

21 If organic growth methods are restricted, yields 

22 will go down, prices will go up, and many of our 
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1 existing consumers will no longer be able to 

2 consume organic produce. We, as organic 

3 producers, have the responsibility to supply 

4 high-quality organic produce, assuring the most 

5 healthy, fresh produce using just organic inputs 

6 at an affordable price for every family. 

7 Container growing methods help us achieve all these 

8 important priorities. 

9 Next. 

10 MS. ARSENAULT: That's the last slide 

11 we have. 

12 MR. MARTINEZ: Yes, I know, I know. 

13 Regulators must continue to allow growers with the 

14 flexibility to meet their site-specific 

15 requirements to face the evolving challenges in 

16 farming food with respect to limit the resources, 

17 such as water, land, labor, and natural resources. 

18 They are more severe than ever before. We urge the 

19 NOSB to further evaluate how container growing 

20 methods, including hydroponic and aquaponic, can 

21 help meet those challenges for sustainability 

22 while fulfilling the legitimate and the original 
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1 intent of the organic movement to use biology to 

2 cycle natural inputs while avoiding prohibited 

3 substances.

4 And that's basically it. And I 

5 appreciate it. Thank you very much. 

6 MR. CHAPMAN: We have several 

7 questions. We have Emily, Francis, and Steve. 

8 We'll start with Emily. 

9 MS. OAKLEY: Hi, Guillermo. Thank you 

10 for your comments. I was wanting to ask you, you 

11 mentioned that you recycle the materials that are 

12 in your containers at the end of each growing season 

13 back onto other fields. 

14 MR. MARTINEZ: Yes.

15 MS. OAKLEY: So where do you source 

16 your materials for those containers on an annual 

17 basis? 

18 MR. MARTINEZ: Well, we source from 

19 different, you know, vendors of the materials. 

20 But all of them are, you know, certified organic 

21 materials that we use, but they come from different 

22 parts. I mean --
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1 MS. OAKLEY: Maybe can I clarify that 

2 a little bit better? What materials do you use in 

3 your containers?

4 MR. MARTINEZ: We use a mix of 

5 different materials. We use coconut husk. We use 

6 mixed up soil with -- I want to say it's a rare thing 

7 that we use. I don't have the specific of that as 

8 of now in terms of the specifics, but, basically, 

9 it's the coconut husk.

10 MS. OAKLEY: Okay, thank you. 

11 MR. CHAPMAN: Francis?

12 MR. THICKE: Yes. What percent would 

13 soil be of that container mix? 

14 MR. MARTINEZ: What was that again?

15 MR. THICKE: What percent of the 

16 container mix is soil?

17 MR. MARTINEZ: I think it's 15 percent 

18 of the mix, but I don't have the information with 

19 me at the moment but I can definitely send it out.

20 MR. THICKE: And what percentage of the 

21 nutrients do you think come from the soil in the 

22 container and what percent come from liquid 
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1 feeding? 

2 MR. MARTINEZ: It's hard to determine 

3 that because we do incorporate microorganisms into 

4 the mix, so it's a combination between the input 

5 from liquid and soil-based nutrients.

6 MR. THICKE: Okay. 

7 MR. CHAPMAN: Steve? 

8 MR. ELA: Francis just asked the same 

9 thing I was going to ask about the amount of liquid 

10 inputs compared to soil. So I don't have anything 

11 further. 

12 MS. OAKLEY: Can I just ask a follow-up 

13 question, Tom? I just wanted to ask if you said, 

14 Guillermo, that the percent of the container mix 

15 that is soil is 15 or 50? 

16 MR. MARTINEZ: 1-5.

17 MS. OAKLEY: Okay, thank you.

18 MR. MARTINEZ: Fifteen, yes.

19 MR. CHAPMAN: Okay. Thank you very 

20 much. Up next is Nathan Brown. We haven't been 

21 able to find your phone number, Nathan. Are you 

22 on our line? Hearing nothing, we'll move on down 
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1 the list. Next up, I have Aviva Glaser. Aviva, 

2 are you on the line? 

3 MS. ARSENAULT: We haven't seen that 

4 number either. 

5 MR. CHAPMAN: Yes. 

6 DR. TUCKER: We're so far ahead, Tom, 

7 maybe a lot of people haven't joined the call yet. 

8 MR. CHAPMAN: Yes. How about Freeman 

9 Allen? Are you on the line? Hearing none, let's 

10 keep moving down that list. We'll come back later, 

11 time permitting. Is Steve Branch on the line? 

12 MR. BRANCH: Yes, I'm here. 

13 MR. CHAPMAN: Okay. Steve, you'll be 

14 next. Hold on a second. Jaydee Hanson is on deck 

15 after that. Jaydee, if you could type in your 

16 phone number if you're on the line, that would be 

17 appreciated. Steve, go ahead. 

18 MR. BRANCH: Good afternoon, and I 

19 appreciate the opportunity to speak about the vital 

20 need for chlorine materials in organic production 

21 and handling. My name is Steve Branch, and I 

22 provide support for organic compliance at Zirkle 
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1 Fruit Company. We grow and pack organic apples, 

2 cherries, blueberries, pears, and wine grapes in 

3 Central Washington State.

4 There are three things I'd like to focus 

5 on. The first is the retailer requirements in 

6 federal regulations, the second is the prevention 

7 of deadly food-borne pathogen outbreaks, and third 

8 is the lack of alternatives for chlorine materials.

9 Chlorine materials are widely used in 

10 organic production and handling. And in our 

11 industry specifically, chlorine is used to clean 

12 and sanitize equipment, floors, storage rooms, and 

13 we also utilize chlorine in dump tanks and water 

14 transfer flumes to limit cross-contamination. 

15 When it's used in direct contact with 

16 fruit, our goal is not to eliminate but rather to 

17 reduce pathogens, and a fresh-water rinse 

18 immediately follows any direct contact. We do all 

19 of this, in part, because we're required to. 

20 Chlorine materials are critical to comply with 

21 retailer requirements and, most importantly, the 

22 federal Food Safety Modernization Act. These 
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1 programs and federal regulations all require 

2 extensive cleaning and sanitizing. Most organic 

3 facilities use chlorine-based materials to meet 

4 these regulations. 

5 Non-chlorine based products may be 

6 used, but it's only in a rotation of sanitizers to 

7 limit pathogen resistance. There are no 

8 substitutes to fully replace chlorine materials in 

9 the cleaning of lines and equipment. 

10 Even out in our orchards, they must 

11 comply with similar regulations. Our orchards 

12 must sanitize food contact surfaces and harvest 

13 equipment. Chlorine is, by far, the most 

14 efficient, effectively, and widely-used material 

15 to meet these regulations.

16 The proper cleaning and sanitizing of 

17 lines and equipment is more than simply a 

18 regulatory compliance issue. And that brings me 

19 to my second point: sanitization is required 

20 because it limits food-borne pathogen outbreaks. 

21 E.coli and listeria monocytogenes can be deadly, 

22 and these pathogens must be eliminated from 
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1 facilities. The elimination of these deadly 

2 pathogens outweighs any intangible potential 

3 benefits of keeping benign microbes.

4 And so, lastly, I'd like to point out 

5 the lack of alternatives. The chemical database 

6 mentioned in written comments do not provide 

7 chlorine material alternatives for facilities. 

8 These databases do not have alternatives for dump 

9 tanks, water flumes, direct product application, 

10 or equipment sanitization. 

11 The chlorine materials remain critical 

12 to organic production. Chlorine materials must 

13 remain available in organic production and 

14 handling. Chlorine materials are necessary to 

15 meet federal food safety regulations, protect the 

16 public from pathogen outbreaks, and there are no 

17 commercially-available alternatives. 

18 So thank you again for your time and 

19 consideration. 

20 MR. CHAPMAN: Thank you, Steven. I 

21 don't see any questions for you. I do. David, do 

22 you have a question? David, are you on mute?
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1 MR. MORTENSEN: Yes, sorry. Could you 

2 just say a little bit more about water flumes? 

3 MR. BRANCH: The water flumes? 

4 MR. MORTENSEN: Yes, and the use of 

5 chlorine there. I'm not familiar with that.

6 MR. BRANCH: So we use water to 

7 transfer fruit from one area of the line to the 

8 other one, and we have to eliminate the 

9 cross-contamination that can happen if we have a 

10 contaminated piece of fruit, getting that then, the 

11 pathogen then into the water system and 

12 transferring that back in on other fruit. So we 

13 use the chlorine in the water at relatively low 

14 levels. It's higher than the drink and food 

15 standards, the drinking water standards but still, 

16 nonetheless, pretty low. We do that in order to 

17 limit that cross-contamination that can exist from 

18 one piece of fruit to the other. And then we also 

19 follow that with a fresh-water rinse to ensure that 

20 we're removing any of the excess chlorine that 

21 could be on the product itself. 

22 MR. MORTENSEN: Thank you. 
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1 MR. CHAPMAN: We're getting a 

2 significant amount of background noise. If 

3 someone could mute where that's coming from.

4 MS. ARSENAULT: Thank you. 

5 MR. CHAPMAN: Okay. Thank you, 

6 Steven, for your comments. I don't see any other 

7 questions. Up next, we have Jaydee. Jaydee, we 

8 didn't hear from you and we can't see your number. 

9 Are you on the line? Hearing nothing, we'll move 

10 on --

11 MS. ARSENAULT: Somebody's in a 

12 kitchen. If you are in a kitchen banging around 

13 some dishes, if you could please put yourself on 

14 mute, that would be really helpful. 

15 MR. CHAPMAN: Up next we have Damon 

16 Seawright. Damon, are you here? 

17 DR. SEAWRIGHT: I am. Can you hear me? 

18 MR. CHAPMAN: Yes, we can. And hold on 

19 one second. After Damon, we have Douglas Doohan. 

20 And, Douglas, if you could type in your phone 

21 number, that would be appreciated. Damon, go 

22 ahead. 
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1 DR. SEAWRIGHT: Yes. This is Dr. 

2 Damon Seawright. I'm speaking on behalf of 

3 AmeriCulture, and I'm providing a dissenting 

4 position on the rule proposing to prohibit 

5 hydroponic and aquaponic producers from receiving 

6 organic certification.

7 AmeriCulture has developed an 

8 aquaponics method for producing 

9 organically-certified vegetables and it is for 

10 this reason that I am fighting this particular 

11 comment for the NOSB's consideration. 

12 The federal Organic Foods Production 

13 Act of 1990 does not prohibit the use of containers, 

14 and it does not require the use of soil for 

15 producers to be organically-certified. And it's 

16 for this reason that 52 hydroponic and aquaponic 

17 producers have applied for and received organic 

18 certification. 

19 The rules and regulations enforcing 

20 federal statute implement but are not to expand the 

21 scope of underlying statutes. The objective must 

22 be achieved legislatively, if it is to be done, 
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1 through a change in the law, not through changes 

2 in the rules that expand the scope of the law. 

3 In setting this issue, container 

4 opponents often state that the European organic 

5 certifiers do not certify hydroponic and aquaponic 

6 producers as evidence that the U.S. should follow 

7 their standard. And while even it being the case, 

8 even if they are philosophically and biologically 

9 correct, which we do not believe they are, the 

10 argument is legally and appropriate is European 

11 standards are based on European laws.

12 The U.S. standards are based on U.S. laws. In 

13 order for the containers to be prohibited and soil 

14 mandated, U.S. law must be changed, which is a 

15 legislative process.

16 Now, nearly all domestic lettuce, the 

17 nation's most popular vegetable, is produced in the 

18 states of California and Arizona. And the same 

19 states account for the same proportion of domestic 

20 organic lettuce production, and must of the present 

21 and substantial future growth and volume and 

22 geographical diversity of lettuce production will 
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1 be driven by the growth in the environment 

2 agriculture sector of the domestic agriculture 

3 industry. 

4 Substantial growth is taking place in 

5 both conventional hydroponic and aquaponic lettuce 

6 production in controlled environment agricultural 

7 environments, resulting in local food production 

8 having lower carbon, lower rates of spoilage, 

9 enhanced freshness, and greatly-diminished 

10 shipping costs. 

11 Many of these growers have established 

12 organic production processes and have sought from 

13 the organic certification the use of controlled 

14 environment agriculture is all but required 

15 outside the states of California and Arizona for 

16 reasons of economic liability. Furthermore, the 

17 use of hydroponics and aquaponics is required for 

18 lettuce production to offset the additional 

19 capital expenditure for greenhouses' costs not 

20 incurred by field growers up in those 48 states. 

21 Thus, the proposed rule will essentially convey an 

22 organic lettuce monopoly to the states of 
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1 California and Arizona prejudicially against the 

2 vast majority of the remaining 48 states by 

3 inserting the artificial suspension of soil and 

4 containers that are not promulgated in the 

5 underlying statute.

6 Lastly, and this has collective 

7 interest in the entire organic industry, there is 

8 a very real public perception challenge introduced 

9 by the proposed rule change that the access of 

10 customers to local organic produce is being 

11 diminished in exchange for products having a higher 

12 carbon footprint and additional fields that 

13 require more than 100 times the water to produce. 

14 MR. CHAPMAN: I'm going to have to stop 

15 you there. You've past your time. Thank you for 

16 your comments. It looks like I have a question 

17 from Ashley then Francis. Ashley? 

18 MS. SWAFFAR: Kind of the same line of 

19 the question I asked earlier. Do you know what 

20 percentage, since you talked about lettuce, what 

21 percentage of lettuce in the organic sector is 

22 produced hydroponically? 
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1 DR. SEAWRIGHT: I don't have that 

2 number on me. 

3 MR. CHAPMAN: Francis? 

4 MR. THICKE: Yes, you mentioned that 

5 you have evolved a system, AmeriCulture. Can you 

6 tell us a little bit about that? What do you use 

7 as a rooting medium? Do you use any soil? What 

8 percent of liquid feed does it use, and what is the 

9 liquid feed? 

10 DR. SEAWRIGHT: A hundred percent 

11 liquid feed, no soil, equivalent of water pressure. 

12 It's very much like conventional lettuce floating 

13 around in a hydroponic or aquaponic platform. But 

14 we use --

15 MR. THICKE: Basically minimal feed 

16 and not like any kind of organic materials in the 

17 feed? 

18 DR. SEAWRIGHT: It's aquaponic, and my 

19 doctorate was achieved in this area 25 years ago, 

20 and we've patented the technology, which allows to 

21 use -- to provide 100-percent of the nutrients 

22 available for the plants through the fish. This 
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1 is generally not achieved in the aquaponics 

2 industry. Aquaponics typically requires, in 

3 addition, certain nutrients to augment what is 

4 otherwise available from fish, and we have this 

5 device process where that is not required. And so 

6 100-percent nutrition can be achieved directly 

7 from fish, possibly being augmented by natural 

8 organically-certified sources of certain 

9 nutrients on an as-needed basis. 

10 MR. CHAPMAN: Thank you very much, 

11 Damon. I don't see any additional questions. 

12 Thank you for your time. Just as a reminder to 

13 everyone, when we have finished with the list, we 

14 will, time allowing, which it looks like it will 

15 be, start back through the list again where we 

16 skipped over commenters. And if they are here at 

17 that time, we'll take their comments. If they're 

18 not, then, once we run through that list, we'll be 

19 done.

20 Up next we have Douglas Doohan. Are 

21 you, did we find you? Are you on the line? 

22 MS. ARSENAULT: We have not found 
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1 Douglas yet. 

2 MR. CHAPMAN: Okay. Douglas, if 

3 you're there, speak now. Going once, going twice. 

4 Up next then we have Simi Summer. Simi, are you 

5 on the line? 

6 MS. SUMMER: Yes, can you hear me? 

7 MR. CHAPMAN: Yes. Hold on one 

8 second, Simi. And then after Simi, Colehour, 

9 you're up next, and I think we've found you so no 

10 worries about typing in your number. Simi, go 

11 ahead. 

12 MS. SUMMER: Good afternoon. It's a 

13 pleasure to have an opportunity to address the 

14 National Organic Standards Board. As someone who 

15 has favored natural and organic for close to 50 

16 years, I wanted to give some input about the need 

17 to maintain 100-percent organic standards and the 

18 importance of immediately replacing all 

19 non-organic materials with safe, pure, 

20 ecologically-sound, health-promoting 

21 alternatives. 

22 The health and environmental hazards of 
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1 conventional agriculture and food production are 

2 well documented. According to the National Center 

3 for Health Statistics, major diseases which can be 

4 traced to harmful food consumption, as well as 

5 environmental exposure to agricultural and 

6 industrial contaminants, are now a leading cause 

7 of death. Pardon? 

8 MR. CHAPMAN: Sorry. We're getting 

9 some background noise. Can people go on mute? I 

10 apologize, Simi. Go ahead.

11 MS. SUMMER: Therefore, I recommend 

12 that NOSB reduce the length of time involved in the 

13 sunset review process and immediately replace all 

14 non-organic substances with certified organic 

15 alternatives, encourage more extensive R&D 

16 regarding the health hazards, immediately form 

17 task forces to research and implement organic 

18 alternatives for all non-organic and synthetic 

19 substances, and encourage greater transparency at 

20 all stages of the supply chain.

21 It's acknowledged that growers and food 

22 companies need significant lead time to make 
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1 substantial changes in their production processes. 

2 However, I feel that the current process is too slow 

3 and, in some cases, may be overlooking the health 

4 hazards of use in any non-organic ingredient or 

5 chemical synthetic substance in certified organic 

6 production.

7 Pectin, as a prototype, since 1995, 

8 non-organic pectin has been on the allowed list as 

9 a synthetic ingredient in certified organic foods 

10 sourced from non-organic apples, which are number 

11 one on the dirty dozen for pesticides and gene 

12 silencing, and non-organic citrus fields with 

13 pesticides and fungicides. Industrial pectins 

14 are now making their way into more products than 

15 we may imagine. 

16 Currently, there's no USA pectin 

17 production and no certified organic pectin 

18 production anywhere in the world. The 

19 International Pectin Producers Association does 

20 not require that their members produce 100-percent 

21 pure fruit pectin. Most contain added sugars from 

22 corn and other chemicals. Transparency on 
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1 manufacturer websites is lacking. Sugar beet 

2 pectins high-risk for GMOs can also be used. 

3 Labeling is vague and does not indicate the fruit 

4 source or country of origin.

5 Although perhaps one of the lesser 

6 worries when considering non-organic ingredients 

7 in organic food, I recommend requiring 100-percent 

8 organic pectin in organic food and immediately 

9 transitioning to certified organic, inspiring 

10 current manufacturers to produce pectin from 

11 certified organic sources, as well as new organic 

12 manufacturing operations. 

13 Thank you. Did you hear me?

14 MS. ARSENAULT: Yes, we can hear you. 

15 Thank you for your comment. Tom, you're muted. 

16 MR. CHAPMAN: And you hear me? 

17 MS. ARSENAULT: Yes, we just un-muted 

18 you. 

19 MR. CHAPMAN: Thank you, Simi. I 

20 don't see any questions for you at this time, so 

21 thank you for your comments. Up next, we have 

22 Colehour. Colehour, are you on the line? 
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1 MR. BONDERA: Yes. 

2 MR. CHAPMAN: And then after Colehour, 

3 we have Robert Hoffman. Robert, if you could type 

4 in your phone number, that would be appreciated. 

5 Colehour, go ahead. Aloha.

6 MR. BONDERA: Aloha, NOSB members, 

7 both new and those who are aging. Note that there 

8 really haven't been more than a total of 80 of us, 

9 so we remain pretty unique. My name is Colehour 

10 Bondera. I'm an organic farmer whose NOSB service 

11 ended in 2016, and I'm here today to talk about how 

12 to protect organic.

13 What does organic mean? When my wife 

14 and I moved from Oregon to Hawaii 15 years ago to 

15 our certified organic farm, my mother told me that 

16 it was a little odd of me to pursue organic since 

17 certification does not really mean anything as all 

18 farms use organic production since everything 

19 growing is happening via organic means. Her point 

20 was that a formal definition is too rigid since 

21 everything changes, and how can we say that 

22 something is not organic, noting that if it can then 
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1 change, then it's simply organic growth.

2 The NOSB exists to be sure that the 

3 definitions within organics do not get watered down 

4 to mean nothing. If anything can be called 

5 organic, that's no definition. Arbitrary, 

6 political, or administrative pressure can mean 

7 that the NOSB isn't to be a keeper of the word use, 

8 and growth is simply for more who say that 

9 everything is organic without recognizing and 

10 acknowledging what is brought in to have a working 

11 definition of it which truly does have limitations 

12 but which must be used as the foundation, a place 

13 to build upon and not be unhealthy reality which 

14 means that holes could be made anywhere with no 

15 limitations to definitions as long as the right 

16 money is used to sow influence and financial 

17 impacts are not truly permitted to be included in 

18 consideration of a recommendation on materials or 

19 methods permitted by NOSB.

20 Remember that point when facing a 

21 decision that seem not to fit within the hole as 

22 outlined in OEFFA. Unique NOSB service is to 
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1 advise the Secretary of Agriculture to ensure that 

2 organic integrity is maintained, even when those 

3 not on the inside are applying pressure on 

4 administrations to allow interpretations which do 

5 not have a place but declare that organic grow if 

6 things not readily included in OEFFA could be said 

7 to help with the growth of organics.

8 The advice of NOSB to the NOP to the 

9 Secretary of Agriculture is not exclusively to

10 react to the public petitions seeking materials and 

11 listing modifications but includes advice about 

12 the means by which these considerations are made 

13 and, as materials can be reviewed, how to yield 

14 serious and complete consideration without having 

15 administrative oversight by NOP serve as the means 

16 to limit NOSB considerations of how a topical area 

17 is most effectively moved upon.

18 In my written testimony, the statement 

19 was made that the NOSB members can and should strive 

20 to figure out how to be advising the NOP on the 

21 management and prioritized decisions made and how 

22 to be directly involved. Note that in OEFFA it 
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1 states that, for this capacity, NOSB has its own 

2 executive director to serve as a liaison between 

3 NOSB and NOP to make determinations of how to handle 

4 the process with topics such as hydroponics, also 

5 mentioned in my written testimony.

6 If each of you ends up simply working 

7 individually upon these reflections, that alone is 

8 worthwhile. Remember that the process must begin 

9 at home and work from our own realities to make 

10 things better overall. So starting with ourselves 

11 is vital to recognize that, no, everything is not 

12 organic. Let's strive to define and protect in a 

13 healthy manner what organic means in a way that is 

14 strong and a healthy foundation to enough others 

15 that it maintains strength. 

16 Thank you. Aloha.

17 MR. CHAPMAN: Thank you, Colehour. At 

18 this time, I don't see any questions from the Board. 

19 Thank you for your testimony. Up next I have Bob 

20 Hoffman, and, after, Bob, we have Brian Lehmann. 

21 I think we found both of you guys, so, Bob, you are 

22 up. 
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1 MR. HOFFMAN: Okay. Hi, I'm Bob 

2 Hoffman. I'm the Chief Science Officer at 

3 Shenandoah Growers. Shenandoah Growers has 

4 essentially been a soil mix with NOP-approved 

5 elements to improve bonds between water holding 

6 capacity, foliage, aeration, retention and 

7 biological diversity to produce healthy and 

8 nutritious plants for our consumers.

9 It's biologically-active living 

10 organic soil. It's home to beneficial bacteria 

11 and fungi. This microflora and microfauna help to 

12 release the nutrients present in our soil, which 

13 allow our plants to thrive in our 

14 controlled-environment greenhouses and nurseries.

15 Our liquid organic nitrogen fertilizer 

16 is produced from vegetative waste. This 

17 fertilizer is diluted in water and a biofilter, 

18 where it is digested by beneficial bacteria into 

19 nitrites and then into nitrates. This nitrified 

20 water is then blended with other NOP-certified 

21 inputs to produce a balanced organic nutrient 

22 solution to supplement our soil nutrition. 
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1 Although this is not an easy process, 

2 over the years Shenandoah Growers has learned to 

3 manage the biological processes well. We use well 

4 water and rain water that is collected from the 

5 greenhouses to irrigate our plants. Our 

6 irrigation nutrient solution is recycled through 

7 filters and reused continuously, conserving our 

8 precious water resources. Then the nutrients are 

9 discharged into the environment. 

10 We use only NOP-approved integrated 

11 test management practices, such as scouting, 

12 mechanical trapping, exclusion, beneficial 

13 insects, and environmental controls to help our 

14 insect and disease tests. We utilize cutting-edge 

15 technologies such as moving gutter systems, energy 

16 curtains, LED lighting, to name a few, in our 

17 controlled-environment production facilities. 

18 This enables us to efficiently and sustainably 

19 produce our organic culinary herbs. It would take 

20 over 180 acres of land in our climate to produce 

21 the same amount of herbs that we can produce in our 

22 six acres of greenhouses and nursery rooms. This 
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1 conserves soil and wildlife habitat while 

2 producing quality food-safe organic year round 

3 for our growing population. 

4 Demand for our food-safe consistently 

5 high-quality living organic produce is growing 

6 rapidly. We can produce quality living organic 

7 crops year round in our controlled environments 

8 despite the changes in weather and the severity of 

9 climatic changes. 

10 Since 2007, we have built a productive 

11 business and employ over 1,100 people. A large 

12 part of the growth of our business is due to 

13 consumer demands and our living organic herbs. We 

14 accomplish this using NOP-approved organic inputs 

15 in a sustainable manner while preserving the 

16 environment for generations to come.

17 We urge you to continue to certify our 

18 containerized growing practices. Thank you. 

19 MR. CHAPMAN: Thank you very much. 

20 Bob, I have a question here from Emily. Emily?

21 MS. OAKLEY: Hi, Bob. Thank you. 

22 Could you tell us what materials are in your 
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1 containers and in what percentage? 

2 MR. HOFFMAN: I could. Some of that is 

3 proprietary, but I can give you a general rundown. 

4 We use coconut coir. We use organic fertilizers, 

5 so composted poultry litter. We use earthworm 

6 castings or buried compost. We produce other 

7 microorganisms, such as beneficial mycorrhizae, 

8 and we use dolomitic limestone. We also use 

9 gypsum. So all are NOP-certified salts and 

10 NOP-certified insects, but none of it works if you 

11 do not have the microbiology in the soil. So you 

12 have to have the proper aeration, the proper water 

13 content, and the spores to begin with. 

14 MS. OAKLEY: Can I just ask a follow-up 

15 question? 

16 MR. CHAPMAN: Yes, go ahead.

17 MS. OAKLEY: So if you use a composted 

18 poultry litter, is that meeting the NOP guidelines 

19 for compost, and what percentage would you consider 

20 the container to be composted poultry litter? 

21 MR. HOFFMAN: Percentage-wise, it's a 

22 very small percentage. Otherwise, your soluble 
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1 salts would be way too high and you would not be 

2 able to produce a good quality crop. So you have 

3 to keep your fertility high while keeping your 

4 salts low --

5 MS. OAKLEY: Do you also have -- sorry. 

6 Do you also have any idea of what percentage of your 

7 fertility needs are through liquid feeding? 

8 MR. HOFFMAN: It's probably pretty 

9 close to half and half because some of the elements 

10 are not immediately available through the soil, but 

11 the majority of our elements are available through 

12 the soil.

13 MS. OAKLEY: Okay, great. Thank you. 

14 MR. HOFFMAN: You're quite welcome. 

15 MR. CHAPMAN: Thank you very much, Bob. 

16 Up next, we have Brian, and then we'll be starting 

17 the list over at that point. Brian?

18 MR. LEHMANN: Yes, can you hear me? 

19 MR. CHAPMAN: Yes.

20 MR. LEHMANN: Okay, thank you. I'm 

21 Brian Lehmann, commenting as an organic consumer. 

22 Thanks to everyone who makes that possible, by the 
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1 way.

2 When I signed up for this webinar, I 

3 hadn't had a chance to see the documents, so I hope 

4 I don't stray too far off topic. But I just wanted 

5 to mention the aeroponics, hydroponics, and 

6 aquaponics issue. 

7 I'm not profoundly against including 

8 these within organic, but I would want to see them 

9 identified with additional labeling. Maybe 

10 that's a novel idea within the rules. I haven't 

11 heard it mentioned previously. But as far as I'm 

12 concerned, the organic consumer should be informed 

13 of the particular source media of an agricultural 

14 product: a logo; a couple of words, like 

15 hydroponically-grown; or even a QR code should 

16 suffice. 

17 But, otherwise, as a long-time organic 

18 consumer, I would object to the organic seal being 

19 conferred. So that is it for me. But, again, 

20 please identify organic products not grown in soil 

21 with additional labeling. Thank you and for the 

22 opportunity to speak. 
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1 MR. CHAPMAN: Thank you, Brian. I 

2 don't see any questions for you, so we'll -- that's 

3 all we have for you, so thank you very much. 

4 So that was our last scheduled. We 

5 will be now running through the list of the speakers 

6 we skipped over and that they are here in order that 

7 they joined. And if they're here, we will 

8 accommodate them, as well. Please bear with us 

9 because I've seen that we might have quite a few 

10 speakers that are not here, so we'll probably be 

11 calling on people not here.

12 First up is David Martinez. David, are 

13 you on the line? Hearing nothing, we'll be moving 

14 on. Kelsey Maben. Kelsey, are you here now? 

15 MS. ARSENAULT: Kelsey was on the line 

16 before so --

17 MR. CHAPMAN: Kelsey, I see you on the 

18 headset. Are you muted on your computer? Hearing 

19 nothing, we'll move on to Kye Witek. Kye? 

20 Next up is Dain Carver. Dain? 

21 Hearing nothing, Michael Collins-Frias? All 

22 right. Up next then with Karen Archipley. Karen? 
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1 MS. ARCHIPLEY: Hi, I am here. Thank 

2 you. And I apologize. You guys moved really 

3 fast. So my name is Karen Archipley. I'm with 

4 Archi's Acres, and we're also Archi's Institute for 

5 Sustainable Agriculture. We have been proud 

6 hydro-organic growers since 2006, and I want to say 

7 that, you know, we live in San Diego where it's the 

8 most expensive water in the world. We pay $2,300 

9 an acre foot. We have always proudly displayed 

10 photos of our productions. We put hydro-organic 

11 on our label, and it's increased our sales. So 

12 thank you for all of those that are really pushing 

13 thinking that we're afraid to put hydro-organic. 

14 It actually makes sense because we bear close 

15 inspection. And so we put photos up and then also 

16 label our products. 

17 Hydro-organics is a scalable system, so 

18 we teach transitioning military, as well as 

19 civilians, sustainable organic agriculture as a 

20 career. And I will tell you the majority of our 

21 students go on to do crop production, and many of 

22 them are hydro-organic. Some of them are 
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1 restauranteurs, etcetera. But the ones that have 

2 chosen this path, I fear inviting them to an NOSB 

3 meeting because of the sad representation of 

4 welcoming our new farmers. Are we really going to 

5 take certification away from these military that 

6 have chosen agriculture as a career and chosen to 

7 do it organically? 

8 Biology is the key to organics, and 

9 whether you're in dirt or whether you are in the 

10 aquaponics system, the hydroponics system, or the 

11 container system, it is all about biology, point 

12 blank. You can't get away from that. 

13 And so I just want to say, you know, 

14 we're here, we're not planning on going anywhere. 

15 I really am proud of our systems. We've invited 

16 other farmers that doubt the system to come see our 

17 farm, and we have very few people that take us up 

18 on that. There's a lot of critics but not enough

19 people that are willing to look at it.

20 I get it. This is about market share. 

21 But I'm going to tell you that even Timex has to 

22 deal with Rolex, and even Rolex and Timex had to 
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1 deal with our phones when it came to, you know, 

2 being able to tell time. Agriculture, this goes 

3 back to 600 BC, the hanging gardens of Babylon, 

4 floating Aztec gardens, and anywhere throughout 

5 the planet where you see a leaf that pools up with 

6 water, pours into another part of the plant, that's 

7 a form of hydro-organic unless you're putting 

8 chemicals on it, and we don't use chemicals. We 

9 use insects to control insects, and we're very 

10 proud of our process.

11 It was a pleasure to be here today. 

12 Thank you for circling back to us. I was mortified 

13 to think I missed my opportunity, so thank you. 

14 MR. CHAPMAN: Thank you, Karen. I 

15 have a question from Francis. Francis? 

16 MR. THICKE: Yes. Sorry to ask the 

17 same question, but we're trying to understand the 

18 systems out there. And so I want to ask the same 

19 question we've asked others, and that is what is 

20 your rooting medium and does it contain any soil? 

21 What percent of your nutrition from the plant comes 

22 from liquid feed, and what is the makeup of the 
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1 liquid feed? 

2 MS. ARCHIPLEY: Okay. So I'm going to 

3 answer what I'm comfortable answering because my 

4 husband is next speaking, and he's going to speak 

5 just to that. And so I will tell you that we use 

6 NFT, which is Nutrient Film Technique, which is a 

7 soil-less system. The water flows underneath the 

8 plant's bare root and delivers its nutrients, and 

9 so you put your nutrients into the main reservoir.

10 As far as our container system, we use 

11 coco coir, which is a byproduct of the coconut 

12 industry and it's used in most all organic farming. 

13 We actually use less than probably most farmers, 

14 but it's an excellent system. 

15 And when it comes to our nutrients, I 

16 know we brew our own nutrient tea, but that I will 

17 let my husband speak to better because I would not 

18 know how to explain that to you, other than it's 

19 live biology. I know that we have frogs in our 

20 system. I know we have all types of things that 

21 come up, which tells us that we're on track. And 

22 I know it's checked, you know, several times a day. 
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1 Does that answer your question?

2 MR. THICKE: Somewhat. But we'll wait 

3 until your husband gets on. Okay. 

4 MS. ARCHIPLEY: Yes, that's fine. No 

5 problem. He's next. 

6 MR. CHAPMAN: Okay. Thank you very 

7 much, Karen. 

8 MS. ARCHIPLEY: Thank you. 

9 MS. ARSENAULT: Karen, be sure you put 

10 your phone on mute. I'm assuming you guys are 

11 close to each other, and we don't want --

12 MS. ARCHIPLEY: No, he's driving. 

13 He's driving. We have 17 people graduating today, 

14 and the majority are active duty. 

15 MS. ARSENAULT: Thank you. 

16 MS. ARCHIPLEY: Appreciate it. 

17 Thanks. 

18 MR. CHAPMAN: Colin, are you there? 

19 MR. ARCHIPLEY: I'm here. Can you 

20 hear me? 

21 MR. CHAPMAN: Yes, go ahead.

22 MR. ARCHIPLEY: Yes. First, I just 
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1 want to thank you guys for the time. You know, I'm 

2 a proponent of hydro-organic, as you're well aware 

3 of. When this discussion first started, it was a 

4 question of using systems that are sterile. That 

5 was proven wrong. These systems are, some way or 

6 another, less organic and we're shooting them off 

7 (inaudible). If we're talking about liquid 

8 fertilizer, we're not even talking about a 

9 production system. We removed the discussion 

10 because we've been proving them wrong time and time 

11 again in regards to the opposition of 

12 hydro-organic. That's one of the reasons why CCOF 

13 voted to support hydro-organic growers because out 

14 here in California we're dealing with the future. 

15 We're dealing with climate change. We're dealing 

16 with increased costs of labor, access to natural 

17 resources with more mouths to feed, and we want to 

18 increase access to organic foods for everybody. 

19 So this is a matter of the future and not the past. 

20 What's happened is a small group of 

21 farmers from Vermont got an increase in pressures 

22 from greenhouse-growing tomato that occurs year 
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1 round. It's producing a higher-quality crop and 

2 less expensively and decided to get together and 

3 make a donation to a, quote/unquote, watchdog, 

4 which is really nothing more than a special 

5 interest group, and they have lobbied you to make 

6 this an issue. It's less organic; the science 

7 doesn't prove that. If there's consumer concerns, 

8 science doesn't prove that. Now we're talking if 

9 liquid organic fertilizers are less organic, is 

10 compost tea less organic than compost? Is fish 

11 emulsion in liquid form less organic than liquid 

12 lye emulsion? 

13 These issues are really about market 

14 share. Is it really less organic one way or 

15 another? The answer is no. We've created these 

16 standards nearly 30 years, and within that time 

17 we've complied with those standards while 

18 innovating, becoming more sustainable, becoming 

19 more efficient, getting closer to the consumer, and 

20 meeting consumer demands. And now you want to 

21 change those standards to protect special 

22 interests.
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1 Keep in mind, and I appreciate what you 

2 guys do, but keep in mind what the core job is. 

3 National Organic Standards Board. Your job is to 

4 maintain standards. And after 30 years and after 

5 innovation within those standards, you want to 

6 change those standards? That's not the role of 

7 NOSB, and that's why there's been discussion within 

8 Washington, which I know you guys are aware of, of 

9 is NOSB outdated for no longer maintaining 

10 standards or catering to special interests and this 

11 is nothing more than a political campaign. It's 

12 like the 2016 presidential race all over again with 

13 live and misdirection of the facts. I guess you'd 

14 call that alternative facts.

15 Lastly, in regards to labeling, my wife 

16 said (inaudible). I have no problem making our 

17 products --- we already do that. But I would just 

18 consider what happens when that product is put in 

19 the supply chain. If I label my basil, for 

20 example, as --

21 MR. CHAPMAN: Colin, I'm going to have 

22 to cut you off there. We're at your time. But I 
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1 do have two questions for you from members, so first 

2 let's start with Francis and then Steve. Francis, 

3 go ahead.

4 MR. THICKE: Yes, I want to come back 

5 to the question of what is the makeup of your liquid 

6 feed? Can you describe that for us? 

7 MR. ARCHIPLEY: The basis for our 

8 liquid feed is compost and worm castings. We also 

9 apply sea kelp and a rock mineral, rock dust, and 

10 molasses, and we put that in a compost tea brewer 

11 and brew that, and we apply that to our media and 

12 our reservoir system.

13 MR. THICKE: Is that sufficient for 

14 feeding the plant? Don't you have any other 

15 minimal, I mean, whatever kind of feed for the 

16 plant, too? 

17 MR. ARCHIPLEY: No, it is not. Now, 

18 sometimes we -- it is sufficient. There are some 

19 times, especially when we grow crops like tomatoes, 

20 where we may need additional nutrients, and that's 

21 where we might supplement with, A, additional 

22 molasses, which we prefer, but it depends on 
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1 accessibility or, B, additional fish emulsion in 

2 either powder or liquid form, depending on the 

3 type, the availability and the increase possibly 

4 in phosphorous and calcium and magnesium. 

5 MR. THICKE: Thank you. 

6 MR. CHAPMAN: Steve? 

7 MR. ELA: Yes. I'm curious -- I 

8 appreciate your comments, but the enabling 

9 legislation were the organic program that the NOP, 

10 one of the references is for the crop production 

11 farm plan in terms of soil fertility, an organic

12 plan shall continue provisions designed to foster 

13 soil fertility primarily through the management of 

14 the organic soil through proper tillage and crop 

15 rotation and manuring. And I'm curious how, given 

16 that that's the legislation we have to comply with, 

17 I'm curious about how you would say that your system 

18 would comply with that. 

19 MR. ARCHIPLEY: I can understand that 

20 interpretation, but in that same document it also 

21 says that these (inaudible) that doesn't preclude 

22 you from participating (inaudible) and food 
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1 companies worry about field fertility because that 

2 doesn't apply. So, legally, this has already been 

3 discussed (inaudible) if certain rules won't apply 

4 to you, that doesn't preclude you from becoming 

5 organic. 

6 And I'd just like to drive home the 

7 point is fish emulsion a liquid form or a powder 

8 form? Is one of those more organic than the other? 

9 Lastly, if we were to ban liquid nutrients today 

10 or, excuse me, if you were to ban hydroponics today, 

11 would these liquid nutrient companies go out of 

12 business? I just talked to someone recently that 

13 numerous companies take scrap from grocery stores 

14 and turns it into a liquid organic nutrient. I 

15 asked him are you seeing increased sales to 

16 greenhouses, and, because of discussions going on, 

17 he said no, but it's because that was such a small 

18 segment of their market share anyway, it doesn't 

19 matter. The vast majority of growers using liquid 

20 nutrients and it'd be great (inaudible) and he says 

21 because that's what we do. Well, we'd all like to 

22 be in that position and base our standards around 
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1 what we do on our farm and exclude everybody else 

2 and exclude that competition. We've got to look 

3 forward, not back. 

4 MR. CHAPMAN: Okay. Thank you very 

5 much, Colin. I don't see any other questions at 

6 this time, so thank you for your testimony. 

7 MR. ARCHIPLEY: Thank you.

8 MR. CHAPMAN: Up next, I have Larry 

9 Griffis. Larry, have you joined us? Hearing 

10 nothing, we'll move on to Reyna Ventura. Reyna, 

11 have you joined us? How about Tim Mann? Tim Mann, 

12 are you on the line? 

13 MR. MANN: Tim Mann is here. 

14 MR. CHAPMAN: All right, Tim. You're 

15 up.

16 MR. MANN: Okay, I'm up. Can you hear 

17 me well?

18 MR. CHAPMAN: Yes, we can.

19 MR. MANN: Okay. First, aloha from 

20 Hawaii. My wife, Suzanne, and I became the first 

21 organically-certified aquaponic farm in the world 

22 in 2008. We are just like any other organic 
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1 farmer. We use all organic inputs, beneficial 

2 insects, and no prohibited substances. The only 

3 difference between us and other organic farmers is 

4 that our plants use an extremely small amount of 

5 soil while other organic farmers use a lot. 

6 Neither do we use much water. Our 

7 irrigation water is contained in food-grade water 

8 containers instead of using irrigation pipes and 

9 canals. As a result, we only use about two to three 

10 percent of the water it takes to grow the same 

11 things in the soil. This makes aquaponics 

12 incredibly efficient at water use.

13 Now, the water efficiency aquaponics 

14 brings to the table is extremely important. We 

15 can't afford to be arrogant about water because we 

16 are living in a world where water is no longer the 

17 guaranteed commodity it used to be. Any water 

18 conservation technology with aquaponics we feel 

19 should be welcomed with open arms. 

20 Because we aquaponics farmers do not 

21 depend on the soil, we can use marginal land for 

22 farming that's not usable to organic farmers 
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1 growing in the soil. This actually helps them out 

2 because it conserves fertile land for their use.

3 Now, we have personally planted orchard 

4 and row crops into a patch of soil on our farm 

5 consisting entirely of gravel and fist-sized 

6 rocks. And that area turned into rich dark soil 

7 full of worms, mycorrhizae, and decaying organic 

8 materials within five years' time. It began by 

9 simply watering the plants in the gravel with 

10 aquaponics water. 

11 In fact, this facet of aquaponics 

12 ensures that it completely complies with Section 

13 205.200, production practices implemented in 

14 accordance with this subpart must maintain or 

15 improve the natural resources of the operation, 

16 including soil and water quality. Now, you guys 

17 have got that requirement, but you don't require 

18 that organic soil farmers can turn infertile sandy 

19 or gravelly soils back into fertile soils. We can 

20 do that easily with aquaponics.

21 Now, this is my last point, and this is 

22 kind of a hot button. There's some studies 
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1 starting to pop up that show as high as 40 percent 

2 of the organic produce items on the supermarket 

3 shelves have conventional non-organic, 

4 organophosphate pesticide residues higher than 

5 that could have gotten on them from accidental 

6 over-spray. In other words, some organic farmers 

7 are cheating and the public is becoming aware of 

8 it. This is not good for the organic movement in 

9 general.

10 Now, you can't cheat aquaponics. In 

11 fact, we can't even use some of the 

12 organically-approved sprays because they get back 

13 to our fish and it kills the fish. Because of the 

14 fish, aquaponics is more organic than conventional 

15 organic. It's guaranteed organic, and that's a 

16 marketing benefit. I can see why the soil-based 

17 organic producers don't want us advertising this 

18 stuff. 

19 What's the simple way to solve this 

20 problem? Require that all hydroponic, aeroponic 

21 --

22 MR. CHAPMAN: I'm going to need you to 
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1 --

2 MR. MANN: Pardon me?

3 MR. CHAPMAN: You're run through your 

4 time.

5 MR. MANN: This is the last sentence. 

6 The simple way to solve the problem is require that 

7 all of these producers put hydroponically-grown, 

8 aeroponically-grown, and aquaponically-grown on 

9 their organic packaging and marketing, and then let 

10 the consumer decide. What could be fairer than 

11 that? Let the consumer decide. 

12 MR. CHAPMAN: Thank you, Tim. I'm not 

13 seeing any questions from other folks. Tim, do you 

14 have a citation on that study that you referenced 

15 about the --

16 MR. MANN: Yes. Give me an email 

17 address, and I'll send you some scientific study 

18 citations. 

19 MR. CHAPMAN: Can you send it to 

20 Michelle? Do you have Michelle's email?

21 MR. MANN: Oh, sure. Got Michelle's. 

22 No problem. I've got it on my to-do list.
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1 MR. CHAPMAN: No other questions, so 

2 thank you for your time, Tim. And --

3 MR. MANN: Thank you and aloha.

4 MR. CHAPMAN: Aloha. Is Esteban on 

5 the line? Esteban? Hearing none, is Herman on 

6 the line? 

7 MS. ARSENAULT: We can see a number, 

8 but he doesn't seem to be, we aren't able to hear 

9 him. But his number is listed. Herman? 

10 MR. CHAPMAN: Herman, are you there on 

11 your line? Are you muted on your side? All right, 

12 Herman. Sorry about that. It's not working out.

13 Next up, Nathan. Nathan, are you on 

14 the line? Hearing nothing, Aviva Glaser. Aviva, 

15 are you on the line? 

16 MS. GLASER: Yes, I am. 

17 MR. CHAPMAN: All right. Aviva, 

18 you're up. 

19 MS. GLASER: Yes, hi. My name is Aviva 

20 Glaser, and I'm a senior quality specialist at the 

21 National Wildlife Federation based in Washington, 

22 D.C. I want to thank you all for the opportunity 
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1 to provide comments, and I wanted to comment 

2 specifically on a National Organic Standards Board 

3 discussion document on eliminating the incentives 

4 to convert native ecosystems to organic 

5 production.

6 I really appreciate that NOSB is 

7 keeping with science to consider this important 

8 issue. We also really appreciate that the organic 

9 programs faces a clear value on the conservation 

10 of biodiversity, which is, of course, so important.

11 As such, we think it's absolutely 

12 critical that organic certification does not 

13 incentivize, either intentionally or 

14 unintentionally, the conversion of natural 

15 ecosystems into agricultural production. 

16 Unfortunately, however, the organic program's 

17 three-year waiting period for transitioning to 

18 organic production has the potential to incur a 

19 conversion in the native ecosystem and now in crop 

20 land without a history of pesticide use offer an 

21 opportunity to bypass the waiting period. Without 

22 a clear disincentive for habitat conversation, 
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1 this can threaten native habitats across the world 

2 from the disappearing native grasslands in the 

3 Northern and Great Plains to tropical 

4 deforestation in South America.

5 And so we wanted to urge NOSB to act very 

6 quickly to close this loophole. We certainly 

7 appreciate the desire to specifically target 

8 high-value conservation lands, as outlined in the 

9 discussion document. We would actually recommend 

10 a rule change that will protect all native 

11 ecosystems without a reported cropping history 

12 against conversion. We think this can be done 

13 easily through a rule change in the land 

14 requirement section, and that would say that 

15 certified operations must not have cleared, 

16 burned, drained, cultivated, or otherwise altered 

17 lands that have no reported cropping history in the 

18 previous five years preceding the date of 

19 application for certification and that that can be 

20 documented by USDA, your other governmental 

21 entities, the Farm Service or USDA records. 

22 We know that there is a lot of 
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1 substitution programs out there internationally 

2 that actually have this in place. So we really 

3 urge you to act swiftly to close this loophole. We 

4 believe it compromises the integrity of the organic 

5 label and actually risks damage to the reputation 

6 of the organic program.

7 So thank you for the opportunity to 

8 provide comments on this. 

9 MR. CHAPMAN: Thank you, Aviva. I 

10 apologize for butchering your name. 

11 MS. GLASER: No problem at all.

12 MR. CHAPMAN: I don't see any questions 

13 for you from the Board, so thank you for your 

14 testimony. Next on the list, is Freeman Allen on 

15 the line? Freeman, are you there? Hearing 

16 nothing, moving down to Jaydee Hanson. 

17 MS. JORDAN: Yes, hi. This is Claire 

18 Jordan. I'm speaking on behalf of Jaydee Hanson 

19 at Center for Food Safety. Hello? 

20 MR. CHAPMAN: Yes, okay. Go ahead. 

21 MS. JORDAN: Thank you. This is on BPA 

22 and packaging. The continued allowance of BPA in 
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1 packaging use for organic products undermines 

2 consumer faith in the organic label. BPA's 

3 capacity to leach into food when present in 

4 packaging and the underlying disrupting impacts to 

5 consumers make it unsuitable for organic products. 

6 Studies demonstrate that avoiding BPA- packaged 

7 foods results in direct decreases in BPA levels in 

8 the human body.

9 Due to these concerns, the FDA no longer 

10 allows BPA in baby bottles, sippy cups, or infant 

11 formula packaging. It is highly likely that BPA 

12 is in packaging for some organic foods. A 2016 

13 study compared the presence of chemical 

14 contaminants in the urine of consumers in Israel 

15 and found that preferences for organic products did 

16 not have an impact on the levels of BPA in 

17 participants' urine. 

18 Due to the human health concerns, no 

19 organic product should be packaged in materials 

20 containing, lined with, or otherwise incorporating 

21 BPA. The NOP must exclude it from organic food 

22 packaging. 
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1 Additionally, CFS strongly urges the 

2 NOSB to prohibit other common packaging materials 

3 that have negative human health impacts, including 

4 orthophthalates and nanomaterials. CFS has 

5 petitioned the FDA to ban orthophthalates as food 

6 additives due to research showing that they are 

7 endocrine system-disrupting chemicals. There is 

8 evidence that organic food companies are using 

9 orthophthalates in their packaging and that these 

10 chemicals also leach into food products, 

11 especially fatty products like cheese. CFS is 

12 currently working with other groups to have organic 

13 cheeses in the U.S. tested to see if they are 

14 contaminated like the Belgian market.

15 CFS conducted an extensive review of 

16 animal and human studies for the 30 approved 

17 orthophthalates as part of our petition to FDA. 

18 Summaries of the scientific literature were 

19 submitted with our written comments. 

20 The use of nanosubstances in food 

21 packaging and in food contact substances 

22 represents a growing concern for organic 
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1 consumers. Food-related nanotechnologies are 

2 being deployed to extend the product shelf life, 

3 particularly using anti-microbials, like 

4 nanosilver, that are embedded in the packaging to 

5 serve as a preservative, anti-microbial, or 

6 anti-fungal. 

7 The authority already exists within the 

8 organic rule to prohibit nanomaterials, and it 

9 states that packing materials and storage 

10 containers that contain synthetics, fungicide, 

11 preservative, or fumigant are prohibited in 

12 organic. We urge the NOSB to seek clarification 

13 with NOP that nanomaterials in packaging are 

14 prohibited within the organic rule. The NOSB must 

15 reject the petition from safe tracers to add short 

16 DNA tracers to the National List. The production 

17 of the short DNA sequences involve use of excluded 

18 method, mainly in vitro nucleic acid technologies. 

19 The short DNA sequences are clearly nucleic acid 

20 and polymer chain reacts in technologies used to 

21 create large numbers of copies a specific short DNA 

22 sequence. The process of synthesizing huge 
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1 numbers of these short double-stranded DNA 

2 sequences entails the use of an in vitro nucleic 

3 acid technique and so must be considered an 

4 excluded method.

5 Other methods of traceability are 

6 available, such as using a paper trail. Moreover, 

7 approving the use of short DNA traces without 

8 requiring a paper trail could result in 

9 encouraging a kind of fraud wherein a DNA tracer 

10 approved to track organic products could be applied 

11 to a non-organic product. This would allow the 

12 non-organic product to pass as organic. Rather 

13 than detecting fraud, they then would be used to 

14 commit fraud.

15 Thank you. 

16 MR. CHAPMAN: Thank you very much. 

17 Asa has a question for you. Asa? 

18 MR. BRADMAN: Yes. Related to the BPA 

19 in food contact material -- and this question is 

20 also put out to the general community. We need to 

21 have more discussion about this. But have you 

22 thought about alternatives and, of course, the 
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1 concerns about, you know, BPF and some of the 

2 structurally-related compounds, but have you also 

3 looked more generally at other alternatives and 

4 have any input or thoughts about what would be 

5 preferred materials? 

6 MS. JORDAN: Yes. I think that, 

7 unfortunately, Jaydee wasn't able to give his 

8 testimony his today, but he would be best equipped 

9 to answer that. But I believe that was our 

10 comments that we submitted for this NOSB meeting, 

11 that we talked about that and put information into 

12 those comments.

13 MR. BRADMAN: Thank you. And just, 

14 you know, as you know, this really opens up, I 

15 think, a Pandora's box of issues that we're all 

16 going to have to think carefully about going 

17 forward. 

18 MS. JORDAN: Yes, absolutely. And 

19 thank you for the opportunity to testify. 

20 MR. BRADMAN: I'm done.

21 MR. CHAPMAN: Yes, okay. Thank you 

22 very much. Thank you. Next up, we have Douglas 
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1 Doohan. Douglas, have you joined us? 

2 MR. DOOHAN: Yes, I am on the call. 

3 Can you hear me? 

4 MR. CHAPMAN: Yes, we can, Douglas. 

5 Go ahead.

6 MR. DOOHAN: Thank you. My name is 

7 Doug Doohan, and I'm a professor of horticulture 

8 and crop science at the Ohio State University. 

9 I've been working with organic farmers in Ohio and 

10 other states for more than 19 years providing 

11 education, research results, and weed control. It 

12 is very clear to me that the organic farm industry 

13 needs access to new tools for weed control and that 

14 natural product and organically-based herbicides 

15 must be part of the toolkit. 

16 Organic farmers overwhelmingly rely 

17 upon physical methods of control to manage the many 

18 weeds that survive the crop rotation. The 

19 physical controls I'm referring to, natural and 

20 synthetic mulches, primarily plastic; thermal 

21 control; and, most important, the use of tillage 

22 in cultivation. 
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1 Simply stated, tillage and 

2 cultivation, along with weeding by hand, are the 

3 main methods of controlling weeds in organic 

4 agriculture. The net result is that weed control 

5 still tops the list as the number-one production 

6 problem of our industry. To make matters worse, 

7 the reliance on steel in the field as the primary 

8 method of control is degrading soils and minimizing 

9 the many beneficial environmental impacts of 

10 organic production.

11 As a board, you have an opportunity to 

12 improve organic production benefits to all of the 

13 industry stakeholders by enabling limited and 

14 appropriate use of herbicides. I'm certain that 

15 most organic farmers will only use herbicides in 

16 two situations: first of all, when weather 

17 conditions prevent the use of tillage, 

18 cultivation, or hand-weeding; and, two, when soil 

19 health dictates a reduction in the amount of soil 

20 disturbance.

21 I'm aware of nine herbicides that are 

22 approved for organic production, and I believe that 
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1 all of these are either vinegar, cinnamon oil, or 

2 limonene-based. Approving the use of soap-based 

3 herbicides would provide organic farmers with more 

4 effective and robust products and, for that reason, 

5 I support their addition to the approved list. 

6 I hope you will take this 

7 recommendation very seriously. By doing so, you 

8 will help many farmers and, ultimately, society. 

9 And I thank you for this opportunity.

10 MR. CHAPMAN: Thank you very much, 

11 Doug. I see a question from Francis. Francis, go 

12 ahead. Francis, are you on mute? 

13 MR. THICKE: I'm sorry. I was on mute. 

14 Thank you, Doug. And as a crop producer myself, 

15 organic, I understand what you're talking about. 

16 And the question that I have and that I contemplated 

17 about this is if we had some soap-based herbicide 

18 that was universal like glyphosate, would it become 

19 the magic bullet that we would be universally 

20 spraying that everywhere and what are the 

21 consequences of that? I don't know. I just raise 

22 that question. 
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1 MR. DOOHAN: I have wondered about the 

2 same thing because it's very clear that 

3 conventional farmers rely very heavily upon 

4 herbicides as risk reduction, risk management 

5 tools. That's really why they use them more than 

6 anything else. They reduce risk.

7 We can say that, at this stage of the 

8 game, that it's somewhat of a non-issue because 

9 there are no products on the horizon or any 

10 technologies on the horizon that will allow any of 

11 the herbicides that are currently approved, as well 

12 as soap-based herbicides that we're interested in 

13 seeing approved, in a selected way. These are 

14 non-selective herbicides that you cannot spray on 

15 a crop.

16 Selectivity of herbicides, either 

17 through the natural tolerance that certain crops 

18 have to particular chemicals -- corn is very 

19 tolerant to the herbicide atrazine, as you probably 

20 know very well, or through engineered tolerance in 

21 the case of glyphosate resistance and some other 

22 manmade resistances, those are the bases of 
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1 selectivities. Otherwise, if you spray it on the 

2 crop, it's going to kill it. And the materials 

3 that we have, you cannot spray them on a crop.

4 So I think, by their very nature, 

5 there's not going to be the degree of dependence 

6 upon them that we have seen in conventional. 

7 MR. THICKE: Thank you. 

8 MR. CHAPMAN: Thank you. I have 

9 another question from David. 

10 MR. MORTENSEN: Could you say a little 

11 bit about the efficacy and how they're used or would 

12 be used? 

13 MR. DOOHAN: We need products of better 

14 efficacy than we currently have, and the soap-based 

15 products, I believe, do have the potential to be 

16 more effective than the products that are currently 

17 available, which, for the most part, in my opinion, 

18 are just not adequate for the job that they're 

19 intended for for the use. 

20 So would you mind repeating your 

21 question? I'm sorry. 

22 MR. MORTENSEN: Yes. I was just 
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1 wondering in the testing and the work that you've 

2 done, like what the efficacy is like. Is it a 

3 significant improvement over other things? I've 

4 not seen them used in the field. 

5 MR. DOOHAN: I believe that, based on 

6 what I've seen, soap-based products are probably 

7 have the broadest activity compared to the products 

8 that are out there. Vinegar and cinnamon oil, in 

9 particular, have not proven to be very effective 

10 in the testing that I've been involved in. 

11 MR. MORTENSEN: Okay, thanks. 

12 MR. CHAPMAN: I don't see any more 

13 questions, so thank you, Doug. We appreciate your 

14 time. 

15 MR. DOOHAN: Thank you. 

16 MR. CHAPMAN: That concludes our list 

17 of public comment for this webinar. We're about 

18 ten minutes ahead of schedule. I want to thank 

19 members of the public for spending your time on the 

20 call with us and providing testimony. This is 

21 valuable to our process. I also want to thank the 

22 Board members for their time and listening to and 
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1 asking thoughtful questions. And I thank the 

2 program for managing and running this call nobly. 

3 MS. ARSENAULT: And congratulations to 

4 you, Tom. Beautifully done. Thank you so, so 

5 much. Thanks to everybody listening. That was 

6 the smoothest webinar for public comment we've had 

7 so far, so very nicely done all around. 

8 MR. CHAPMAN: Yes. Thank you all. 

9 And for those of you who will be there, I look 

10 forward to seeing you all in Denver if you can make 

11 it. Thank you again. Have a great day. 

12 (Whereupon, the above-entitled matter 

13 went off the record at 3:50 p.m.)

14

15
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1

 U.S. DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 MEETING

 + + + + +

 WEDNESDAY

 APRIL 19, 2017

 + + + + +

 The Board met in the Majestic Ballroom

of the Sheraton Denver Downtown Hotel, 1550 Court

Place, Denver, Colorado, at 9:00 a.m., Tom

Chapman, Chairperson, presiding.
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2

BOARD MEMBERS PRESENT

TOM CHAPMAN, Chair

SUE BAIRD

HARRIET BEHAR

ASA BRADMAN

JESSE BUIE, Secretary

LISA DE LIMA

STEVE ELA 

DAVE MORTENSEN

JOELLE MOSSO 

EMILY OAKLEY 

SCOTT RICE 

A-DAE ROMERO-BRIONES 

DAN SEITZ

ASHLEY SWAFFAR, Vice Chair

FRANCIS THICKE

STAFF PRESENT

MICHELLE ARSENAULT, NOSB Advisory Board

 Specialist, National Organic Program 

LISA BRINES, Ph.D., National List Manager, 

 National Organic Program 

PAUL LEWIS, Ph.D., Director, Standards

 Division, National Organic Program

MILES MCEVOY, AMS Deputy Administrator

JESSICA WALDEN, Materials Specialist, National 

 Organic Program

ALSO PRESENT

ISAURA ANDALUZ, Co-Founder, Cuatro Puertas 

CHRISTIE BADGER, National Organic Coalition

JO ANN BAUMGARTNER, Executive Director, Wild Farm

 Alliance

ANAIS BEDDARD, Lady Moon Farms

THOMAS BEDDARD, Lady Moon Farms

ROSEMARY BILCHAK

ALESIA BOCK, Managing Director, AgriSystems 

 International

NANCI BURTMAN, Volunteer, Food & Water Watch 

VANESSA CAMPUZANO, Intern, Food & Water Watch

DAN CARROTHERS, Global Business Director, Agro
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3

 Green Business Division, Emery Oleochemicals 

DAVE CHAPMAN, Long Wind Farm

CHRIS CIOLINO, Agro Green Business Division,

 Emery Oleochemicals 

THEOJARY CRISANTES TAMAYO, Wholesum Family Farms,

 Inc.

JENNY CRUSE, Accredited Certifiers Association

GREG CUNNINGHAM, Scotts Miracle-Gro Company

KELLY DAMEWOOD, California Certified Organic

 Farmers

BRUNNO DA SILVA CEROZI, Production Manager,

 Superior Fresh

GERALD DAVIS, Grimway Farms

JEFFERSON DEAN, Organic Grain Growers Chapter,

 Ohio Ecological Food and Farm Association 

ANTHONY DUTTLE, Director of Agronomic Services, 

 Tanimura and Antle

MARTIN EDDY, Kansas Organic Producers; OFARM

COURTNEY ELLIS

TINA ELLOR, Technical Director, Phillips Mushroom

 Farms

JAY FELDMAN, Executive Director, Beyond

 Pesticides

DARLENE FLORENCE, Research Manager, Agro Green 

 Business Division, Emery Oleochemicals

LEE FRANKEL, Executive Director, Coalition for 

 Sustainable Organics

CAROLINE FRONING, Innophos

NICHOLAS GARDNER, Manager of Regulatory Affairs, 

 International Food Additives Council

JIM GERRITSEN

MAX GOLDBERG, Founder, Organic Insider; Founder, 

 Living Maxwell 

TIM GORDON, Colorado Hemp Industries Association

TOM HARDING, Shenandoah Growers

CAMERON HARSH, Senior Manager for Organic and

 Animal Policy, Center for Food Safety

SHANNON HELMS, Global Regulatory Manager, CP

 Kelco

WIL HEMKER, Fellow, University of Akron Research 

 Foundation

ZAREB HERMAN, The Hain Celestial Group
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4

KIKI HUBBARD, Director of Advocacy, Organic Seed 

 Alliance

WANDA JURLINA, Technical Service Manager,

 CP Kelco 

MARNI KARLIN, Karlin Strategic Consulting

MARK KASTEL, Co-Director, The Cornucopia

 Institute

LORI KLOPF, Regulatory Affairs, ICL Food 

 Specialties

JESSICA KNUTZON, Marketing Specialist, CP Kelco

PHIL LAROCCA, LaRocca Vineyards

ALAN LEWIS, Natural Grocers

NATE LEWIS, Foreign Policy Director, Organic

 Trade Association

AMALIE LIPSTREU, Policy Coordinator, Ohio

 Ecological Food and Farm Association

PATTY LOVERA, Food and Water Watch

RICHARD MATHEWS, Executive Director, Western

 Organic Dairy Producers Alliance

PEGGY MIARS, Executive Director, OMRI; IFOAM 

 Organics International 

MADISON MONTY, Policy Advisor, Northeast Organic 

 Farming Association of Vermont 

DAVID MOORE, Neudorff 

GAIL NELSON, G&G Connections

JANEL RALPH, President and CEO, Palmetto

 Synergistic Research 

TERRY SHISTAR, Beyond Pesticides 

MICHEAL SLIGH, Rural Advancement Foundation 

 International 

LAUREN STANSBURY, Communications Director, Hemp 

 Industries Association

DEMETRIA STEPHENS, Stephens Land & Cattle 

ALBERT STRAUS, Straus Family Creamery

LISA TROPE, Food and Water Watch

BETH UNGER, CROPP Cooperative 

CHARLOTTE VALLAEYS, Senior Policy Analyst,

 Consumer Reports 

CHERYL VAN DYNE, International Pectin Producers 

 Association

DIANE WILSON, Director of Nutrition Services, 

 Nature's One

ABBY YOUNGBLOOD, National Organic Coalition 
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5

 CONTENTS

Call to Order. . . . . . . . . . . . . . . . . . . 6

Miles McEvoy

Agenda Overview. . . . . . . . . . . . . . . . . . 8

Tom Chapman

Introductions. . . . . . . . . . . . . . . . . . . 9

Secretary's Report . . . . . . . . . . . . . . . .17

Jesse Buie

USDA National Organic Program Report . . . . . . .18

Miles McEvoy

National Organic Program - Materials Update/

Summary of new and outstanding petitions . . . . .70

Dr. Lisa M. Brines

NOSB Report. . . . . . . . . . . . . . . . . . . .89

Tom Chapman

Public Comments. . . . . . . . . . . . . . . . . .95

Break

Public Comments (cont.). . . . . . . . . . . . . 215

Adjourn. . . . . . . . . . . . . . . . . . . . . 465
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6

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

2 10:08 a.m.

3 MR. McEVOY: Okay, I think we're going

4 to get started. 

5 Welcome, everyone. Nice to have

6 everybody here in Denver, beautiful day

7 yesterday. Mountains are sparkling out there. 

8 So, welcome, and we're opening the

9 Spring 2017 NOSB Meeting. Just a little bit --

10 just a very little bit about Colorado.

11 There are 491 certified organic

12 operations in Colorado. The Colorado Department

13 of Agriculture is based here in Colorado, and

14 certifies a majority of those operations, but

15 there are many other certifiers that are also

16 operating in Colorado and protecting the

17 integrity of the organic sector here in Colorado.

18 So, we want to thank all of them for

19 the work that they do to protect organic

20 integrity. We also want to thank all the farmers

21 and processors and handlers here in Colorado that

22 are -- are producing organic products and selling
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7

1 and distributing those products. So, thanks to

2 all of them, as well.

3 So, I am Miles McEvoy, the Deputy

4 Administrator of the Agricultural Marketing

5 Service's National Organic Program, and with me

6 here from USDA today I have Michelle Arsenault,

7 who is the NOSB Organic Advisory Board

8 Specialist.

9 I have Jessica Walden, who is with the

10 Standards Division and is the main technical

11 support for the subcommittees of the National

12 Organic Standards Board, and then in the back

13 over there, I have Paul Lewis, who is the

14 Director of the Standards Division. He is the

15 one that makes all the regulatory and guidance

16 type of activities happen at the National Organic

17 Program.

18 Then next to him is Lisa Brines, Dr.

19 Lisa Brines. She is our National List Manager.

20 So, thank you and welcome to everyone

21 that's here today. We look forward to a great

22 meeting. 
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1 I'm going to apologize now, that I am

2 going to have to step out a couple of times

3 during the next couple of days for some other

4 meetings that I have to attend. So, Paul Lewis

5 will be up here being the -- representing NOP at

6 that time.

7 So, with that, I'll turn it over to

8 the Chair, Tom Chapman.

9 CHAIR CHAPMAN: Thank you, Miles. 

10 Hello and welcome, everybody. Thank you for

11 traveling here today to participate and observe

12 the National Organic Standards Board meeting.

13 I hope everyone is well rested and

14 prepared for a few busy days. I'm going to

15 briefly review the agenda, and then we'll go onto

16 NOSB member introductions.

17 Then after that -- so, starting with

18 the agenda that -- we will then hear from an NOP

19 report from the Deputy Administrator Miles McEvoy

20 and a national list update from Dr. Brines.

21 I will then have an opportunity to

22 give a brief update and after that, we'll move
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1 onto public comment, and that's what we'll spend

2 the rest of today doing, as well as tomorrow

3 morning.

4 After that, we'll move onto the

5 subcommittees handling, livestock, and CACS

6 tomorrow, and after that on Friday, we'll start

7 with crops, followed by PDS and materials.

8 We'll finish the day recognizing the

9 new members and going through the work agenda

10 item and wrapping up any remaining business.

11 Most importantly, the wifi password.

12 It's Nosb2017, all one word, capital N lowercase

13 OSB.

14 With that, we'll start with member

15 introductions and we'll start here -- 

16 MS. ARSENAULT: I was just going to

17 say the password is not case sensitive, just so

18 you know.

19 CHAIR CHAPMAN: Not case sensitive,

20 there you go. NOSB, capitalized or not, your

21 choice.

22 We'll start with member introductions,
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1 and we'll start down here with A-Dae. A-Dae, if

2 you could just give a brief introduction about

3 yourself and your background.

4 MEMBER ROMERO-BRIONES: Good morning. 

5 I am A-Dae Briones. I currently work for First

6 Nations Development Institute. We work with

7 indigenous farmers across the nation.

8 MEMBER DE LIMA: Hi. I'm Lisa de Lima. 

9 I'm in the retailer seat. I work for MOM's

10 Organic Market. We're an organic grocery store

11 chain in the Mid-Atlantic, and this is my third

12 year on the board.

13 MEMBER BRADMAN: My name is Asa

14 Bradman. I helped co-found the Center for

15 Environmental Research and Children's Health at

16 UC Berkeley, and I'm a professor there. 

17 I've also worked for a few decades in

18 issues around environmental health in agriculture

19 communities. We get pesticides exposures, child

20 health and development. A new member of the

21 board. 

22 This is my first meeting, of course,
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1 and early in life, I also spent some time

2 working, taking care of chickens and chicken

3 production, and then in Oregon, packing them off

4 for slaughter, and I picked apples and grapefruit

5 commercially, and also worked commercial

6 beekeeper, and have spent a stint of time also

7 looking at issues around acid rain and impacts on

8 vegetation and soil chemistry and surface water

9 chemistry.

10 MEMBER MOSSO: Good morning. Joelle

11 Mosso. I work at Olam Spices and Vegetable

12 Ingredients, Olam SVI is what it's known for. We

13 process organic tomatoes and do retail co14 manufacture items for organic, as well as are a

15 large manufacture of dehydrated onion and garlic

16 and imported spices from our origin facilities.

17 Prior to Olam, I worked at Earthbound

18 Farm for many years, from organic integrity

19 through quality and food safety.

20 I'm a pathogenic food microbiologist

21 by training and I serve currently as the Director

22 of Purees and Natural Products for Olam.
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1 MEMBER ELA: Steve Ela. Ela Family

2 Farms, here in Colorado, over on the western side

3 of the state. I'm a new member. I'm an organic

4 tree fruit grower, fourth generation, here in

5 Colorado.

6 I also have background in soil science

7 and other biology and geology and so, that's

8 pretty short. 

9 MEMBER MORTENSEN: Good morning. Dave

10 Mortensen. I am from Pennsylvania. I have been

11 conducting research and teaching and outreach

12 teaching at farmer workshops on sustainable and

13 organic methods for the last 30 years, 15 in

14 Nebraska and 16 -- 31 -- 16 at Penn State.

15 I also serve on the Pennsylvania

16 Association for Sustainable Ag Board there and my

17 area is ecologically-based pest management, and

18 we've done a lot of systems work on farm over the

19 years, where we do a lot of the ecosystem service

20 assessments and that sort of thing.

21 Happy to be here. It's my first

22 meeting, as well. 
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1 MEMBER BUIE: Good morning. Jesse

2 Buie. Ole Brook Organic, Brookhaven,

3 Mississippi. I'm certified in mixed vegetables

4 and melons, turmeric and ginger.

5 I've sat in the producer's seat and

6 I'm Secretary of the Board. 

7 MEMBER SWAFFAR: I am Ashley Swaffar. 

8 I sat in the farmer's seat. I own a small

9 certified mixed vegetable farm in Arkansas and I

10 do a lot of animal welfare inspections and

11 organic inspections all over the country, and I'm

12 the chair of the livestock committee and vice13 chair of the board.

14 MEMBER SEITZ: Good morning. My name

15 is Dan Seitz. I'm a public member on the board,

16 and this is my second year.

17 I serve as the Executive Director for

18 the Council on Naturopathic Medical Education,

19 which accredits doctoral programs in naturopathic

20 medicine, and I'm also the board president of a

21 food co-op and I serve as the chair of the policy

22 development subcommittee.
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1 MEMBER RICE: Good morning. I'm Scott

2 Rice. I sit in the certifier seat and I am with

3 the Washington State Department of Ag Organic

4 Program, where I've been for about 10 years, and

5 currently the accreditation and outreach lead

6 there, and also chair the CACS subcommittee, and

7 this is my second year on the board. 

8 MEMBER BAIRD: Good morning. I am Sue

9 Baird. I am the Executive Director of the Mid10 America Organic Association. I have been

11 involved with organic since it's -- before it

12 became a law. I've served as certifiers. I've

13 served as inspectors and reviewers.

14 I am happy to be here. I have no

15 commercial vested interest in anything, anymore. 

16 I used to at one time, and I think that puts --

17 Steve is laughing at me.

18 I'm here to protect in my mind, my

19 grandchildren's health. So, that's why I'm here.

20 This is my first time here and I am

21 now the vice president of the livestock

22 committee. So. 
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1 MEMBER OAKLEY: I'm Harriet Behar. I

2 live in Gays Mills, Wisconsin. I'm the chair of

3 the materials committee. This is starting my

4 second year.

5 I work for the Midwest Organic and

6 Sustainable Education Service, which is not a

7 membership organization, but we work with

8 literally thousands of organic farmers around the

9 Upper Midwest and actually, the whole country and

10 even the world.

11 I am the main person who answers the

12 organic info line, and believe me, I get just

13 about every question you can imagine, and in

14 addition, I have my own certified organic farm,

15 certified since 1989. I am a beekeeper. I'm happy

16 to hear Asa, that you are a beekeeper. So, maybe

17 we'll be able to get the apiculture standards

18 once things loosen up there at the federal level,

19 because you have two people on the board that

20 could maybe give some good input.

21 So, besides having a commercial

22 beekeeping operation, we also grow vegetables for
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1 Organic Valley at times and I sell to a local

2 food co-op. 

3 I also grow and process medicinal and

4 culinary herbs on my farm, and I sell those to

5 manufacturers and to retailers and what else do I

6 do? I do a lot of different things.

7 I'm on the Wisconsin Organic Advisory

8 Council. I'm also on the NRCS State Technical

9 Committee. I have written certification --

10 transition to organic conservation plans, so, and

11 I sit in the environmentalist seat. 

12 MEMBER OAKLEY: Good morning. My name

13 is Emily Oakley, and I have Three Springs Farm in

14 Northeastern Oklahoma. We're a small scale,

15 basically three acre vegetable farm. We have

16 other land, but the rest is basically a wildlife

17 habitat.

18 We sell directly to our consumers

19 through farmer's markets and CSAs, and I've been

20 certified organic for 10 years and I've been --

21 this is my 14th season of farming. First three

22 years were on leased land that couldn't be
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1 certified yet. Thank you.

2 MEMBER THICKE: Good morning. My name

3 is Francis Thicke. I sit in environmentalist

4 seat, and the chair of the crop subcommittee, and

5 this is my last year on the board, and I am an

6 organic dairy and crop farmer in Iowa and

7 actually started organic farming in 1975. 

8 CHAIR CHAPMAN: Thank you, Francis. 

9 I'm Tom Chapman from Clif Bar & Company in

10 Emeryville, California. I sit in the handler's

11 seat. This is my third year on the board and I

12 am currently chair of the NOSB.

13 Thank you, members, for spending your

14 time here with us today, and all the time you

15 spent getting prepared for this meeting.

16 Up next is the Secretary's report. 

17 Jesse? 

18 MEMBER BUIE: Mr. Chair, the minutes

19 of the November 2016 biannual public meeting have

20 been distributed behind the reference tab in your

21 binder. Are there any comments or corrections?

22 CHAIR CHAPMAN: Seeing no objection,
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1 we'll approve the Secretary's report by

2 consensus. So approved.

3 MEMBER OAKLEY: Yes.

4 CHAIR CHAPMAN: So approved. Up next

5 is the USDA NOP Report with Miles McEvoy. Miles. 

6 MR. McEVOY: Okay, good morning. Nice

7 to be here. Need my little cue sheet here, oh,

8 and I have the controls. Good.

9 Okay, so, I'm going to cover a number

10 of different topics today, if I can get this to

11 work. Do you want to do the slides, since I can't

12 seem to get this to go? Great, thanks.

13 Okay, so, first of all, these are --

14 this is what I'm going to cover today. First of

15 all, accomplishments. There is a lot to

16 celebrate in the organic space.

17 First of all, the Organic Livestock

18 and Poultry Practices Final Rule was finalized in

19 January, and I think it's really a pretty amazing

20 accomplishment that -- lot of work by the organic

21 community, by this board, the National Organic

22 Standards Board to come up with 
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1 comprehensive recommendations and if you

2 remember, that was in December 2011, and it took

3 us -- took AMS to finalize that a number of

4 years, and that was finalized last year.

5 So, a lot to celebrate there, in terms

6 of the finalization of that organic livestock and

7 poultry practices rule.

8 You all know that that is -- that the

9 effective date of that has been delayed to May

10 19th, and the rule is under review. But

11 nevertheless, the rule is published as a final

12 rule.

13 The other thing I'm going to mention

14 is increase in the number of organic operations. 

15 So, there's a lot of -- a lot of things to

16 celebrate there, in terms of more and more

17 farmers and processors and handlers are involved

18 in organic production. 

19 There is some information from Penn

20 State University that shows that organic

21 production, these are organic hot spots around

22 the country, lead to greater economic viability
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1 and prosperity in these counties where there's a

2 lot of organic production.

3 So, the growth of the number of

4 organic producers and handlers is good for the

5 rural economy and for U.S. agriculture.

6 I'm also going to cover a little bit

7 of the organization of USDA, AMS and NOP, kind of

8 just how USDA is organized and what's happening

9 with the new administration.

10 Then talk about NOP's strategic goals

11 and activities, global organic control systems,

12 what we're doing in terms of protecting organic

13 integrity and what our priority areas are for the

14 upcoming year. Next slide. Give it a try. Oh,

15 did I do that? Okay.

16 Okay, so, there is an announcement

17 coming out today, a press release today, about

18 the increase in the number of certified organic

19 operations. At the end of 2016, almost 25,000

20 certified organic operations in the U.S. This is

21 a 13 percent increase over the last couple of

22 years.
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1 Double-digit growth, in terms of

2 number of certified organic operations. So, we

3 have seen large increase in the sales of organic

4 products over the last few years. It's also nice

5 to see that there's increase in number of farmers

6 and businesses involved in organic production and

7 handling.

8 There is a lot of things we do to

9 support this growth. We do a lot of training. 

10 We have our sound and sensible initiatives that

11 provide technical assistance. But I would say

12 that the thing that really supports growth is

13 protecting organic integrity, ensuring the

14 integrity of the seal, so that consumers have

15 confidence in the -- in the organic products that

16 they purchase.

17 The Organic Integrity Database, which

18 I'll talk about in a little more detail later on,

19 that -- the -- that -- the success of that

20 project enables us to get counts on the number of

21 operations a lot earlier than in the past, than

22 in our past methodology, and so, we hope as we
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1 increase the quality of the information submitted

2 by the certifiers into the database, that we'll

3 be able to publish these -- this information

4 about the size of the organic sector earlier and

5 earlier every year.

6 So, visually, this is what it looks

7 like. There was a huge amount of growth in

8 number of operations between 2005 and 2008, and

9 then it leveled out for a few years there, and

10 then you see in the last few years, a significant

11 growth in the number of certified organic

12 operations in the U.S.

13 Okay, so, moving onto USDA. So, USDA

14 is a huge federal department with many agencies

15 within it, and it had over 100,000 employees in

16 the -- the last administration, and has around

17 that now. We will see over the next few years,

18 how that all works out.

19 So, currently at USDA, we do not have

20 a Secretary. The Secretary has had his -- his

21 hearing, but his confirmation session is next

22 Monday. We have heard that it's likely that he
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1 will be confirmed on Monday and will start work

2 next week, which is great. It's nice. It will

3 be nice to have some political leadership at

4 USDA.

5 There have been people from the new

6 administration at USDA, but they are basically

7 just keeping the wheels on the bus and keeping

8 things rolling along, as we're waiting for the

9 political folks to come into USDA, and there are

10 many of these political folks that will be coming

11 into USDA over the coming months. I think it's

12 over 400 people that fill political positions at

13 USDA. It's a huge department.

14 So, all those various offices that are

15 in the Office of the Secretary that report to the

16 Office of the Secretary, those have political

17 appointees.

18 So, you have the Deputy Secretary,

19 which is the next big appointment, and then

20 Director of Communications, Inspector General,

21 General Counsel, those -- there is all political

22 appointees there.
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1 Then you have the seven mission areas

2 at USDA and under-secretaries for each of those

3 mission areas.

4 So, Natural Resources and Environment,

5 which includes the Forest Service and Natural

6 Resource Conservation Service, Natural Resource

7 Conservation Service, of course, does a lot of

8 work to support organics through there --

9 through their EQIP program and transitions

10 program. 

11 Under-Secretary for Farm -- Foreign

12 Agricultural Services. So, that's FSA, the Farm

13 Service Agency which the cost-share program is in

14 that agency for organic certification cost-share,

15 as well as the Foreign Ag Service that we work

16 very closely with on our international

17 arrangements, equivalency and recognition

18 agreements.

19 Then we have rural development, food,

20 nutrition and consumer services, where you have

21 the SNAP program or food stamps. Food safety,

22 which is the meat inspection. Research,
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1 education and economics and finally, on the right

2 here, you have marketing and regulatory programs,

3 where the National Organic Program is.

4 So, there need -- so, it -- the point

5 here is that there's a lot of political people

6 that still will be nominated and have to go

7 through the confirmation process and get

8 appointed to these various positions, and that

9 takes time. It's going to take quite a bit of

10 time.

11 So, within the marketing and

12 regulatory programs, we have three agencies. 

13 Agricultural Marketing Service, where the

14 National Organic Program is. APHIS, the Animal

15 Plant Health Inspection Service that we work with

16 very closely on looking at some of the organic

17 imports issues, in terms of ports of entry, and

18 then the Grain Inspection, Packers & Stockyards

19 Administration.

20 Okay, so, now, we go to AMS. So,

21 within all that -- within the department and all

22 those various agencies and offices, we have the
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1 Agricultural Marketing Service with it -- which

2 in the scheme of USDA, is a relatively smaller

3 agency, and it has nine programs, dairy,

4 specialty crops, cotton and tobacco, the National

5 Organic Program, of course, livestock, poultry

6 and seed, transportation and marketing,

7 compliance and analysis and science and

8 technology.

9 The National Organic Program is the

10 newest and the smallest program within AMS. So,

11 within a small agency within USDA, we're also a

12 small program within USDA.

13 Some of the services that USDA

14 provides. They do a lot of the standardization

15 and grading and quality verification for a

16 variety of different fruits and vegetables,

17 cotton, livestock products, as well.

18 They do a lot of price reporting

19 through market news, including a lot of organic

20 price reporting, which is a very important

21 service that's provided to the organic sector.

22 Commodity procurement, which is where
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1 USDA is buying commodities, mostly for the school

2 lunch program. So, that's a big activity within

3 AMS. All the check-off programs, research and

4 promotion and marketing orders and agreements,

5 that's part of AMS's portfolio. The National

6 Organic Program, transportation services,

7 wholesale and farmer's markets.

8 So, a whole bunch of stuff in a small

9 agency, and the National Organic Program in and

10 of itself has a whole bunch of things that we do.

11 So, now, let's move to the National

12 Organic Program. Our mission is to ensure the

13 integrity of the USDA organic products throughout

14 the world. Organic integrity from farm to table,

15 consumers trust the organic label, the concept,

16 and we're protecting that integrity from the

17 farm, through all the handling, distribution and

18 all the way to the marketplace.

19 Our authority is under the Organic

20 Food Production Act and the USDA Organic

21 Regulations.

22 So, how we're organized is in four
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1 divisions. We have the Office of the Deputy

2 Administrator, which is overall administration

3 and priorities, communication, handling the FOIA

4 requests, budget and personnel things, and then

5 the three divisions.

6 Standards Divisions, which the

7 National Organic Standards Board mostly interacts

8 with. They're the ones that work on rules and

9 guidance, instructions and the national list and

10 deal with the recommendations directly from the

11 National Organic Standards Board.

12 We have the Accreditation and

13 International Activities Division. They do the

14 accreditation oversight of certifiers and handle

15 most of the work with the equivalency

16 arrangements and our recognition of foreign

17 governments conformity assessment systems.

18 Then the Compliance and Enforcement

19 Division that handles complaints, conducts

20 investigations and initiates enforcement actions. 

21 So, that's a general overview of how

22 NOP is organized and how we fit into the overall
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1 USDA and AMS structure.

2 So, in terms of leadership at the

3 National Organic Program, I report to Bruce

4 Summers, who is the acting administrator of the

5 Agricultural Marketing Service, and then my

6 direct report is Associate Deputy Administrator

7 Dr. Jennifer Tucker, and within the Office of the

8 Deputy Administrator there is a total, including

9 Jenny and myself, of eight people.

10 We have the Standards Division, who

11 the director is Dr. Paul Lewis, and there is nine

12 staff in that division. We have the

13 Accreditation and International Activities

14 Director Cheri Courtney, and she has eight staff

15 total there.

16 Compliance and Enforcement has nine

17 staff, and then we have a FOIA office that has

18 two staff with three contractors.

19 So, relatively limited personnel to do

20 a lot of stuff, and we feel like we -- we get a

21 lot of stuff done with a limited amount of

22 people.
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1 So, our strategic plan has five core

2 focus areas. People and process, making sure

3 that we have great people to do the work, that

4 they're properly trained and that they have the

5 equipment they need to effectively do their work,

6 and that we're always looking at our process and

7 how to most efficiently and effectively get the

8 work done and look at how to improve it, to make

9 improvements over time.

10 Protecting organic integrity, that is

11 our focus. A lot of our activities focus around

12 how do we protect organic integrity through the

13 global control system, working with certifiers,

14 doing enforcement, very much a focus of the work

15 that we do.

16 Market access has to do with ensuring

17 that there are opportunities for farmers and

18 ranchers and processors and handlers to

19 participate in the organic market if they choose

20 to do so, so they have the information they need,

21 the information about the standards and how to

22 comply, if they want to sell in the local market,
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1 regional market, and then for international

2 markets, working with other countries to ensure

3 that U.S. organic products have access to foreign

4 organic markets, as well.

5 Clear standards is ensuring that the

6 organic regulations are clear and enforceable,

7 always making improvements to those, based on

8 implementing recommendations from the National

9 Organic Standards Board.

10 Then finally, build technology that

11 advances organic integrity. I'll talk a little

12 bit more about that. That's primarily around the

13 organic integrity database, but we have some

14 other initiatives on that area, as well.

15 So, we currently have around 36

16 employees. If you've been paying attention over

17 the last few years, that's significantly less

18 than we have had in the past. We've had a number

19 of people move onto other jobs over the last year

20 or so.

21 We have a number of vacancies

22 currently, but we have a new administration that
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1 had a hiring freeze in place until very recently,

2 and now we have a new order from the Office of

3 Management and Budget about reorganizing

4 government, that we have to address before we can

5 move forward with any hiring.

6 So, we have a vacancy in terms of our

7 assistant director in the Accreditation and

8 International Activities Division. Renee Mann

9 has left federal service to go hike the

10 Appalachian Trail, which sounds really appealing

11 at the moment, and had some other changes, as

12 well.

13 So, our budget has been -- is a

14 relatively modest budget, 2012, 2013 under $7

15 million, went up to $9 million in 2014 and has

16 stayed fairly stable for the last three years,

17 through 2016. We are funded through next week at

18 the 2016 level. So, we'll see what happens after

19 next week, but that's -- our funding runs out

20 April 28th, and for next year, we don't know. 

21 So, stay tuned.

22 Our responsibility is 82 accredited
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1 certifying agents worldwide. So, we have had a

2 couple of new certifiers that we've accredited

3 over the last year. There are certified organic

4 operations in over 120 countries and $43 billion

5 in U.S. organic sales.

6 So, we used to like to say that we had

7 one employee for every billion dollars in sales.

8 Now, we even got a better return on your

9 investment, with going down to 36 employees, and

10 I'm sure the sales are way over $43 billion now. 

11 So, we should get something, some credit for that

12 or some kind of benefit.

13 Anyway, in terms of process

14 improvement, there is a lot of things that we do

15 in this area, in terms of quality management

16 systems. We do internal audits every year. We

17 do the management review, where we're looking at

18 all the various audits that we have and looking

19 at things that we want to focus on, in terms of

20 improvement.

21 Our real focus area in terms of

22 improvement this year is in our quality systems. 
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1 There were some findings about some weaknesses in

2 our record keeping, in quality systems, so we

3 have a concerted effort to make some improvements

4 in our document control and our records

5 management.

6 We also have a number of external

7 reviews and audits that are done. We have peer

8 review that's being conducted through ANSI. We

9 had a report to the board last Fall and our

10 corrective action report to that report is now

11 available on our website, and we have the start

12 of this year's review is happening right now.

13 We also have assessments by foreign

14 governments and those assessments that foreign

15 governments make of the USDA's organic program

16 are available on our website, once they are

17 finalized.

18 Finally, something to pay attention to

19 over the coming months. The Office of Inspector

20 General has been doing an audit on our organic

21 equivalence arrangements, as well as imports and

22 so, that report should be published in the next
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1 couple months and should have some very good

2 information for things that we can do to improve

3 oversight over imports.

4 We use a team approach. We used a

5 team approach, for instance, for the organic

6 livestock and poultry practices final rule. If

7 you remember that -- that -- the comment period

8 for that ended in July of last year, and we

9 worked -- had a lot of people working on that

10 project, both throughout the National Organic

11 Program. We had a number of people working on

12 it, as well as people throughout the department,

13 Office of the Chief Economist. We had APHIS and

14 FSIS and NRCS that were helping us with different

15 sections of that rule, as well as input from FDA

16 and EPA.

17 So, very much attribute our success

18 there to that team approach that we utilized. 

19 Okay, so, moving onto the core part of

20 protecting organic integrity. There we go. This

21 might be a little small print here.

22 But this is our quarterly report. We
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1 have not published this yet. But this is some of

2 the information that we will publish on our

3 quarterly update, in terms of compliance and

4 enforcement for fiscal year 2017, that starts in

5 October of 2016.

6 So, what I want to point out here is

7 that incoming complaints for the first two

8 quarters are getting close to 200 incoming

9 complaints, and the number of completed reviews

10 and investigations is less than 100.

11 You'll see this trend over the last

12 number of years, that we're getting significantly

13 more complaints than we're closing every year. 

14 So, we need to do something about that, because

15 it's not a sustainable system to be receiving

16 more complaints than we're able to handle. 

17 So, we're looking at ways that we can

18 reorganize or rethink how we're doing this

19 compliance work, because getting additional

20 resources is challenging at this time. So, we

21 have to think how we can be more effective at

22 handling these incoming complaints. 
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1 In terms of the kinds of actions that

2 we take, cease and desist orders. We've done six

3 of those over the last six months, notices of

4 warning, 29, and investigative referrals, 18 over

5 that time period, and then settlement agreements

6 which can be both from complaints, but also from

7 other actions that USDA AMS takes.

8 There's been 15 of those. We have not

9 had any consent decisions during this time period

10 and civil penalties were $45,000 in the first

11 quarter and $38,000 in the second quarter.

12 Another thing that is a big activity

13 that happens at the National Organic Program is

14 handling appeals. So, there's a number of

15 different types of appeals that are received. 

16 This is required by statute and regulation, that

17 we have and expedited appeals process within the

18 Agricultural Marketing Service, and so, that --

19 there's a variety of different things that can be

20 appealed.

21 So, certifier's actions can be

22 appealed, if they're proposing suspension or
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1 revocation of certification, then they can --

2 then that party that's being -- has that proposed

3 adverse action can appeal to AMS.

4 If a certifier is denying

5 certification, they can appeal that to AMS. 

6 Actions that NOP takes can also be appealed. 

7 Cease and desist notices are appealable, a denial

8 of reinstatement, a reinstatement of

9 certification is appealable, and then if we're

10 taking a proposed action to suspend or revoke

11 accreditation, that's also appealable.

12 Our goal here on appeals is to have an

13 average closure of 120 days. We are -- we're

14 pretty much meeting that goal. That is a

15 significant improvement from five years ago, six

16 years ago, when it was over two years was the

17 average time for an expedited appeal process. So,

18 we've made a lot of improvement in that area over

19 the last few years.

20 We've had 23 appeals come in over this

21 time period, and not that many that have led to

22 decisions or closures there. You can see the
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1 numbers, but there is a number that are working

2 through the process.

3 But, so, the point here is, this is --

4 this takes a lot of our resources to handle this

5 appeals process within the National Organic

6 Program.

7 The next thing that I'm pointing out

8 is administrative proceedings.

9 So, when there is an appeal, there's

10 many different things that can happen. An appeal

11 can be sustained. Appeal can be denied. It can

12 be dismissed or it can be settled. 

13 If an appeal is denied, that is we are

14 agreeing with the certifier or with the National

15 Organic Program's proposed adverse action. Then

16 the operation has the right to request a hearing

17 in front of an administrative law judge, and if

18 they do that, then there is a lot of work that we

19 have to do.

20 We work with our Office of General

21 Counsel and we have to prepare a complaint to get

22 that process started. 
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1 So, that complaint goes out to the

2 party. Then we work with the Office of the

3 Administrative Law Judge to schedule the hearing,

4 and that -- this leads to -- to eventually a

5 hearing or I'll -- in many cases, there will be a

6 consent order that's determined before it gets to

7 hearing.

8 A lot of work for us to do, to work

9 with OGC, to make sure that this is happening,

10 and we currently have a number of different

11 complaints and things that are working through

12 that process, that are in process at the National

13 Organic Program.

14 Freedom of Information Act is also

15 something that we have a lot of resources that

16 are devoted to, a very important part of the work

17 that we do. We're required to disclose

18 information that's requested under FOIA, except

19 for things that fall under one of nine

20 exemptions, and that protects the interest of 

21 personal privacy and for law enforcement. FOIA

22 requests are processed within 100 -- within 20
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1 days and NOP staff are responsible for

2 identifying what we consider responsive records,

3 what are things that could be included in that

4 request.

5 Then those records, once those are

6 identified, they have to be -- ensure that they

7 are complete and then redact any information that

8 falls under one of those nine exemptions.

9 Some FOIA requests are very straight

10 forward. But many are -- involve hundreds or

11 thousands of pages and years of records through

12 that process.

13 We have two NOP staff members full

14 time that work on FOIA. We also have three full

15 time contractors working on FOIA and additional

16 staff is used as needed.

17 Currently, we have 12 open FOIA

18 requests, two that are under appeal and we have

19 seven that are under litigation. So, there is a

20 significant amount of resources that are devoted

21 to our FOIA responsibilities and efforts.

22 We are trying to post the --
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1 everything that is released through FOIA on --

2 through the AMS FOIA reading room. So, you can

3 go to the AMS FOIA reading room to see those

4 documents. You won't see all those documents

5 there, because we have -- it takes us a while to

6 get those things through the process, but that's

7 the intent, is to get everything that's released

8 into that FOIA reading room.

9 Okay, moving onto accreditation of

10 certifiers. This is a very critical part of the

11 work that we do, the oversight of certifiers to

12 ensure that they're -- they're complying with the

13 requirements.

14 We do the five year -- they have a

15 five year accreditation cycle. So, we do the

16 renewal audits every five years. They have a

17 midterm audit. We also do compliance audits,

18 when we feel it's necessary to ensure that their

19 corrective actions from an audit are being

20 implemented.

21 We also do witness inspections, where

22 we are observing an inspector in the field doing
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1 the work, and we do review audits where we go out

2 to operations, to see that the inspection was

3 complete and thorough.

4 There are 82 accredited certifiers and

5 the audits that we're conducting in 2017 are

6 quite extensive in terms of foreign audits, 

7 Brazil, Australia, Vanuatu, which I guess is

8 somewhere in the Pacific and does a lot of

9 coconut, Haiti, Ukraine, Bolivia, Peru, Turkey,

10 Germany, Holland, Canada, Mexico, and Greece. 

11 So, lots of audits in foreign countries.

12 Domestic audits are -- many states are

13 included there. So, you might wonder with such a

14 small staff, how do we go to all these various

15 places.

16 Our auditors are quite busy. They are

17 on the road a lot, conducting these audits. All

18 these audits tend to take at least a week. So,

19 this is a lot of time. Often, there is more than

20 one auditor that's involved, and but we also

21 utilize auditors from the livestock and seed

22 program that help us to conduct this work.
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1 So, that -- lots of activities in this area.

2 We also have the recognition and

3 equivalency work. So, we have recognition of

4 foreign governments, New Zealand, Israel and

5 India. We did assessments of those government

6 programs in 2016 for India and Israel and we just

7 completed the assessment of New Zealand, just a

8 few weeks ago.

9 We also have equivalency arrangements. 

10 We have five of those and so, we also conduct

11 assessments to ensure that those equivalency --

12 the terms of those equivalency agreements are

13 met.

14 We have equivalency discussions

15 underway with Mexico and Taiwan. Mexico is

16 implementing their Mexican organic regulations by

17 the end of the month. So, that's -- a lot of

18 attention is there. There is a lot of trade that

19 we have with Mexico. It's a big market for U.S.

20 organic products. So, lot of attention on Mexico

21 right now.

22 Argentina has officially applied for
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1 equivalency and we understand that Chile is going

2 to apply for equivalency very soon.

3 Okay, moving onto the technology area. 

4 We do have the organic integrity database. This

5 was part of the 2014 Farm Bill. We had $5

6 million to support the work to develop this

7 database. Contains up to date information,

8 increases supply chain transparency and enhances

9 the integrity of the organic controls system.

10 Hopefully, you all are using it. It's

11 really an amazing resource and we continue to

12 make improvements to this database, though we are

13 running out of funding for the improvements to

14 the database, we do have funding to maintain the

15 database. We do have a lot of ideas of how to

16 make further improvements to the database. But

17 resources are becoming limited.

18 There is a feature, a relatively new

19 feature, advanced search. So, you have a way of

20 finding the information you're looking for, in

21 terms of what part of the world, a country or

22 state that you're looking for a product. You can
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1 look for specific products. You can look for

2 things that are certified or suspended. It

3 allows you to really refine the search that

4 you're looking for.

5 One of the things that we're really

6 working with is with certifiers, in terms of the

7 quality of the information that they're

8 submitting, and you'll see as you work with this

9 database, that the quality is a little mixed. 

10 Some certifiers provide much better quality

11 information than others, and we're trying to get

12 certifiers to use the -- a taxonomy of products,

13 so that these search engines will work much

14 better and there is more consistency in how the -

15 - the database works.

16 So, a lot of work and a great team

17 that's been developing this database.

18 We also have a new feature which is a

19 federal certificate. So, we do offer to

20 certifiers that they can use this federal

21 certificate.

22 So, one of the challenges in
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1 conducting inspections is that there are 82

2 different types of organic certificates, because

3 there are 82 different accredited certifiers and

4 they all have their -- their separate forms and

5 they all look a little different. They're

6 required to have certain information on there,

7 but they don't have a standard look and feel. 

8 So, we've been advocating that there

9 should be one USDA certificate that certifiers

10 use. We don't have the regulatory authority to

11 require that, but we are certainly offering this

12 -- this service.

13 There are two certifiers that are

14 using this certificate, and when they use this

15 then you can go to the integrity database and see

16 the certificate and the certificate has various

17 features. I'm not really good at these kind of

18 things, but like that QFR thing or QR thing, that

19 some kind of link back to the database, so it's

20 supposed to help with security and veracity of

21 the certificate.

22 Okay, so, so, new features for
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1 integrity database.

2 In terms of clear standards, I already

3 talked about some of the regulations and

4 guidance. Organic livestock and poultry

5 practices. The effective date has been delayed

6 until May 19th. It is currently under review by

7 the administration. The administration is -- as

8 I said, is not really settled yet. So, stay

9 tuned on that one.

10 Sunset 2017 Proposed Rule, the comment

11 period for that closes today. So, that's a

12 proposal to remove 11 substances from the

13 national list, and then we did have open for

14 public comment, the calculation of the percentage

15 of organic ingredients in multi-ingredient

16 products. That comment period was extended to

17 April 7th, and that is now closed.

18 Normally, when I am talking about

19 rules and guidance, I have a lot of things about

20 things that we're working on. But there is not a

21 lot that we're working on because we don't have a

22 new administration and we have some new executive
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1 orders that we have to kind of understand what

2 they mean, before we can move forward with rule

3 making.

4 We are working on organic import

5 instructions. These are instructions to

6 certifiers and to importers, because that's not

7 rule making. So, we have some authority to get

8 instructions out to certifiers.

9 We did post a short video on organic

10 integrity in the supply chain a couple weeks ago,

11 really encourage the certifiers and any handlers

12 to take a look at that. This is an area that

13 we'll be putting a lot of focus on, in terms of

14 ensuring that we use our existing regulatory

15 authority to ensure integrity in long and complex

16 supply chains, and we are working on grower group

17 instruction based on the NOSB recommendations

18 from 2002 and 2008. 

19 This would be instructions for

20 certifying grower groups, which are very common

21 way of certifying groups of farmers in Latin

22 America, Asia and Africa.
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1 Okay, that's all I got on standards. 

2 That way? Thank you. That's not working either. 

3 Oh, there we go.

4 Okay, so we have a global organic

5 control system. We work with many different

6 foreign governments and certifiers. As we all

7 know, organic trade is expanding, over $80

8 billion in just the U.S. and EU organic market. 

9 Those are the largest markets around the world,

10 but we're seeing it -- emerging markets in places

11 like Mexico and other countries, as well.

12 Many governments have established

13 organic standards and control systems. We are

14 working to -- with those governments, some of

15 those governments to improve the quality of the

16 work that they do. We're actually doing training

17 next week in Chile with Latin American countries

18 on ISO-17011 and competent authorities in

19 procedures, under organic systems.

20 Fraudulent certificates continued to

21 be identified. We just announced this morning,

22 some additional fraudulent certificates. So,
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1 that's still a problem, and we have alleged

2 violations in foreign countries, and they can be

3 quite complex and challenging.

4 We have an ongoing investigation of

5 the increase in the amount of organic corn and

6 soy that's coming in from Eastern Europe,

7 especially from Turkey. It's a lot of questions

8 on how did over a few years, such an increase in

9 the amount of organic corn and soy get produced

10 and distributed from that region.

11 So, we have a lot of activities

12 looking into that and investigating that.

13 So, the organic control system is --

14 starts with the organic standards, ensuring that

15 they are comprehensive and clear, enforceable,

16 and then it's the certifiers that verify that

17 organic farmers and handlers are complying with

18 those organic standards. 

19 So, they're the critical component

20 that verifies that the system is working, and

21 then the accreditation body and in our case, it's

22 AMS's National Organic Program, we ensure that
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1 the certifiers are doing their job properly, that

2 they're doing thorough and complete inspections,

3 that they have qualified personnel, that they're

4 meeting all of their responsibilities as

5 certifiers, because certifiers are really the

6 ones that are doing the bulk of the work. We

7 can't -- we certainly can't do it with 35 people,

8 when there's tens of thousands of operations

9 around the world.

10 Certifiers are very important, in

11 terms of the enforcement of the standards. They

12 enforce the standards by -- under their

13 authority, by issuing notices of non-compliance

14 and ensuring that corrective actions are taken,

15 and then when they are not adequate, that they're

16 -- that they do proposed -- or suspensions and

17 revocations for those operations that do not meet

18 the requirements.

19 Then competent authorities, which are

20 the governments. We also have our authority and

21 responsibility, in terms of oversight of

22 certifiers, and we also do enforcement, as well.
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1 So, all those various things work

2 together for this organic control system.

3 So, this is just an example of that in

4 action. This is a grain and rice operation in

5 Argentina. You can see part of the process where

6 there is an interview out in the field, and

7 looking at records. So, this system of

8 inspection and certification is operating

9 worldwide because organic is a worldwide system.

10 So, certifiers, as I said, are central

11 to the control. They are the ones that are

12 really the basic folks that are ensuring

13 compliance with existing regulations. So, go

14 certifiers.

15 This is some of the things that they

16 do. They first and -- they look at the organic

17 system plans. They review those organic system

18 plans for all kind of components, that the inputs

19 are complete, the inputs are compliant, that the

20 materials are compliant, and when we talk about

21 inputs, it's also any -- for a handler, it's the

22 inputs that they're buying organic ingredients or
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1 organic products that they're buying, ensuring

2 that they are verified, that they're coming from

3 a certified organic source and meet the

4 requirements looking at the record keeping

5 systems, and then looking at the production and

6 handling systems within the plan.

7 Then they conduct the inspections, at

8 least an annual inspection. In addition, they

9 also do unannounced inspections and when they're

10 doing those inspections, they're seeing that the

11 organic system plan is accurate, that it's

12 complete and that it's fully implemented, and

13 they're reviewing the records and ensuring

14 traceability of product through the audit trail

15 and conducting mass balance audits. 

16 All certifiers are required to do this

17 and they should be doing this, and we're ensuring

18 through our role, that they are doing this.

19 They also issue certificates. Those

20 annual certificates and then in certain cases,

21 transaction or import certificates are involved,

22 for specific shipments, and attestation
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1 statements they may be issuing when we're talking

2 about Canada. So, these are some of the core

3 activities that certifiers do.

4 In terms of the product movement, it

5 can be quite complex and quite long. Again, I

6 apologize, this is a little small. But on the

7 far right, there are a lot of growers and the

8 growers may be submitting product to various

9 elevators, and then there's brokers and handlers

10 involved, and another broker, another warehouse,

11 then an exporter, then you have a ship that's

12 taking all the product over to the U.S. It goes

13 through a port of entry and then gets distributed

14 in the U.S., and this is just for one supply

15 chain.

16 One of the challenges that we have is

17 that there are operations that are excluded from

18 certification. They're not required to be

19 certified. So, anyone that sells labels or

20 represents products as organic is required to be

21 certified with some exemptions and they can be

22 excluded from certification if they're only in
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1 handling already packaged product, but anybody

2 that's re-labeling or packaging or re-packaging

3 product has to be certified, and we're trying to

4 make sure that that is happening throughout this

5 complex supply chain.

6 So, in terms of record keeping, this

7 is one of my favorite parts of the National

8 Organic Program final rule. So, this is 205.103. 

9 So, my favorite part, bedtime reading every

10 night. 

11 Certified operation must maintain

12 records concerning the production, harvesting and

13 handling of agricultural products that are sold,

14 labeled or represented as organic. So,

15 everybody's got to keep records if you're a

16 certified organic operation and then such records

17 must be adapted to the particular business.

18 So, this is really nice. Really

19 beautiful because it allows that flexibility for

20 businesses to use their existing record keeping

21 system to comply with the requirements. But the

22 next part is really, really critical.
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1 It has to fully disclose all

2 activities and transactions of the certified

3 operation in sufficient detail, as to be readily

4 understood and audited.

5 So, certifier comes in, an inspector

6 comes in, readily understood and audit-able, and

7 if not, that's a violation, and certifiers need

8 to make sure that if this is not true, that these

9 operations are not getting certified or are

10 improving their systems, so that this is true,

11 that the records are in sufficient detail to be

12 readily understood and audited. So, anyway, my

13 favorite part.

14 So, here are some of the records that

15 may be part of this process. Records verifying

16 that incoming product is organic with the amount

17 of the product, organic certificates for all

18 incoming products and ingredients, invoices,

19 purchase orders, bills of lading, scale tickets,

20 handler organic certificates and contracts that

21 handlers have with others. Those are important

22 to review and are important records.
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1 Certificates of analysis, product

2 specification sheets, raw product inventory

3 reports and records, weigh tickets, receipts and

4 tags, clean truck affidavits or clean ship

5 affidavits.

6 So, many different types of records

7 may be relevant and are part of that organic

8 control system that are inspected and audited by

9 certifiers.

10 So, we -- I already mentioned the

11 excluded operations that may not be certified. 

12 So, what happens for these non-certified

13 operations? Who keeps those records, if the

14 supplier is non-certified?

15 We don't have a lot of authority,

16 direct authority over these non-certified

17 operations. So, the real authority and the real

18 area that we have that leverage is on the

19 certified operations.

20 So, they are the ones that are

21 responsible for the product, whether they're a

22 buyer of the product or a seller of the product,
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1 and in those cases, under the regulations they --

2 those records must be -- have sufficient detail. 

3 They must maintain that traceability,

4 demonstrated through that audit trail, they must

5 prevent contamination and commingling, and they

6 must be available at inspection. Very important

7 components of this whole process that these

8 records are available.

9 Okay, so, that's a little bit of a

10 focus on that, but I know there's been a lot of

11 concern about that. This will be a lot of our

12 focus this coming year, is working on organic

13 integrity and supply chain, and with this -- one

14 of the other things that we're doing is training

15 and if this works, we're going to show you a

16 little bit of a video here, and if it does not

17 work, we won't show you the video.

18 This is a video that we created

19 primarily for certifiers and inspectors about the

20 inspection process, and it's a choose your own

21 adventure video, where you get to make the right

22 choices in inspector and the wrong choices in
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1 inspector, and it's very, very well done, and

2 really what it will help inspectors and

3 certifiers do their job appropriately.

4 We're currently translating this into

5 Spanish, so we are making this available in

6 Spanish, as well.

7 So, it looks like it will not work,

8 but I encourage people going to the -- it does

9 work? Okay, or not? 

10 Okay, we will, in the interest of

11 time, I think we'll move on. So, but it's really

12 great. I really encourage people to take a look

13 at it. It's pretty -- it's very professionally

14 done and it's pretty fun and you get to play like

15 you're an organic inspector, which is one of the

16 best jobs ever.

17 Okay, all right. So, with that, I

18 just have -- so, our priorities for this coming

19 year, as I said, organic integrity in the supply

20 chain, training certifiers and handlers,

21 implementing better oversight system for imports

22 and auditing certifiers and ensuring adequate
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1 controls for long supply chains, especially those

2 involving imports.

3 So, we're aren't going to be doing a

4 lot of rulemaking this year, but we have a lot of

5 other work that we'll be focusing on and be able

6 to accomplish a lot. 

7 So, thank you very much for your time

8 and listening, and for all the work that the

9 National Organic Standards Board does and all the

10 work that the organic community does to protect

11 organic integrity, and with that, I'll open for

12 questions. Thanks.

13 CHAIR CHAPMAN: Any questions for

14 Miles? Harriet? 

15 MEMBER OAKLEY: I just want to

16 congratulate you for all the work that you're

17 doing in the enforcement area. As organic

18 continues to grow, we'll still have an -- at

19 times, it might be malicious intent, but many

20 times, it's just ignorance of our rules, that why

21 people use the word organic or are representing

22 things that, you know, they should not represent
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1 with the organic seal or the organic label, and I

2 really appreciate all the work you're doing in

3 that area and as an advocate for organic, I'll

4 try to see what I can do with the legislators to

5 increase, if we can, your budget and at the

6 least, hold it where it is.

7 MR. McEVOY: Okay, thanks.

8 CHAIR CHAPMAN: Any other questions? 

9 Ashley?

10 MEMBER SWAFFAR: As I'm really sad

11 that we're losing a really great board member

12 this year, but Miles, when will that posting be

13 up for our environmentalist open seat?

14 MR. McEVOY: Right. So, we did --

15 yeah, we will have a nomination coming out

16 relatively soon or applications for nomination

17 for the one open board position that will -- that

18 will be Francis's position that will be open

19 sometime in the next month or so, and that's a

20 long process, but the notice will be open for 60

21 days, 60 days, once that gets through the

22 clearance process.
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1 It's getting close but things go very

2 slow at this point in time with the new

3 administration.

4 CHAIR CHAPMAN: Any other questions? 

5 All right, I had a few, so, just wait till the

6 end. Which one to start with first?

7 The QR codes that you mentioned on the

8 certificates, do you know if those are available

9 to certifiers if they didn't want to use your

10 certificate, but used your QR code?

11 MR. McEVOY: I don't know. I could

12 find out. 

13 CHAIR CHAPMAN: Okay, and then you

14 talked a little bit about the import oversight

15 team. I was wondering if you could give us a

16 little bit more detail about that. Who was on

17 that and what was their scope of responsibility?

18 MR. McEVOY: Sure. So, the import

19 oversight team has a number of different

20 projects.

21 So, it includes people from all parts

22 of the national organic program, so compliance
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1 and enforcement, accreditation and standards, and

2 so, a lot of what they're doing is working with

3 other agencies.

4 So, we have entered into a memorandum

5 of understanding with the APHIS's 

6 plant production and quarantine to look at

7 instituting a check-off system for imports to

8 ensure that any organic imports that may be

9 fumigated don't get into the organic stream of

10 commerce.

11 So, we've been working very closely

12 with APHIS PPQ on developing systems that will

13 enhance the integrity of that system.

14 We're also looking at the various

15 types of databases that are used for imports. 

16 Currently, there is only -- there is the

17 harmonized trade code system that has about 40

18 organic codes and there are thousands of organic

19 items that are in trade.

20 So, there is also the ACE system that

21 the custom and border patrol is responsible for,

22 the automated controlled environment and so,
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1 we're looking at are there ways of having an

2 organic designation so that we could track all

3 organic imports, not just those that have the

4 harmonized trade code system.

5 We're working on mutual training with

6 APHIS PPQ, training them more on the organic

7 standards, so their agents at the ports of entry

8 have more information about what to look for.

9 We have the organic import certificate

10 project. So, we have developed a proposed rule

11 to require import certificates for all imports,

12 not just imports coming from certain countries

13 that we have equivalency arrangements with. So,

14 that's in process.

15 So, that's a quick overview of some of

16 the activities that that import team is doing,

17 but a lot of it is working with APHIS and CBP on

18 -- on the port of entry area.

19 CHAIR CHAPMAN: Thank you. One last

20 question. So, you mentioned you're working in

21 120 countries, 82 certifiers, $43 billion in

22 sales, double digit growth of operations with a
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1 staff of 36, two of which are dedicated to FOIA.

2 How are you managing? What impact is

3 this having on your priorities?

4 MR. McEVOY: What's -- well, it

5 doesn't impact any of the priorities. But it is

6 a lot of -- a lot of activities, a lot of work

7 that we are responsible for and that we do.

8 A lot of it, we are able to do because

9 of the great work that really, the certifiers do,

10 and then we also have in terms of overseas, we

11 have cooperation with foreign governments, in

12 terms of oversight.

13 But it is quite challenging. As I

14 mentioned, we are challenged especially on

15 handling the number of complaints that are coming

16 in. So, we're looking at ways to improve that

17 process to be more efficient and effective at the

18 same time.

19 Yeah, it is challenging, and we do

20 have a very heavy workload at the National

21 Organic Program. 

22 CHAIR CHAPMAN: Emily? 
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1 MEMBER OAKLEY: Can you share with us,

2 some of the ways that you're looking to make the

3 complaint process a little bit easier to deal

4 with or is that still in the works? But anything

5 that you could share with us, I'd love to hear.

6 MR. McEVOY: Yeah. It's really very,

7 very, very much in the beginning stages. 

8 Betsy Rakola, who is our new

9 compliance and enforcement director, she just

10 came back from maternity leave about a month ago. 

11 We have started an outside analysis of the

12 current process, to look if there is

13 efficiencies.

14 What we are looking at is improving

15 the intake process, because we identified that as

16 a bottleneck that our intake process is -- has

17 some, I guess quick wins of ways that we can get

18 things moving along a little more quickly in the

19 process. So, yeah, it's very preliminary at this

20 point. 

21 CHAIR CHAPMAN: Scott?

22 MEMBER RICE: Hi. Certifiers are
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1 always really excited about instructions coming

2 out and we're just wondering if there's a time

3 line for that, when we might see that organic

4 import instruction.

5 MR. McEVOY: Well, I have my time line

6 and then we have the clearance process. So, we

7 would hope to get that out some time early in the

8 summer.

9 CHAIR CHAPMAN: Harriet?

10 MEMBER OAKLEY: I know things are

11 moving very slow, but in the past, you've had a

12 list of things that were like in line, like

13 origin of livestock, apiculture standards,

14 guidance on pesticide drift and how certifiers

15 should deal with that.

16 I mean, those are things that are just

17 coming off the top of my head. I imagine those

18 things have not completely gone away, but I'm

19 wondering if there is still any movement or so,

20 when things start to free up, would we start

21 seeing some of those things move through for

22 comment or implementation?
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1 MR. McEVOY: Yeah. Well, we don't

2 have the new administration here and we have some

3 executive orders that we have to understand the

4 meaning and how -- of those and how they affect

5 rule making. 

6 So, all those types of activities,

7 there's a lot of things that have already been

8 done. There were some things that were in

9 clearance, like apiculture and pet food, origin

10 of livestock, there is a lot of things that are

11 in -- and aquaculture all have significant amount

12 of work that has been done.

13 So, that is not lost, it's just

14 sitting there. But there is no movement on

15 anything of a significant nature until we have a

16 new political leadership and we understand what

17 the administration wants to do around significant

18 rule making. So, that's going to, it could be

19 quite a while before we know what, if anything,

20 can move forward. 

21 CHAIR CHAPMAN: Any other questions? 

22 Seeing none, thank you very much, Miles,
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1 appreciate your time and the information you've

2 shared here today.

3 Up next on the agenda is the Materials

4 Update and Summary of New and Outstanding

5 Petitions by Dr. Brines.

6 DR. BRINES: Good morning, and for

7 those looking at the agenda, it looks like we've

8 skipped over something, but we actually

9 intentionally moved it until after my

10 presentation. So, don't worry, we're coming back

11 to the NOSB update.

12 Okay, all right. So, good morning. 

13 So, just a brief presentation today, giving the

14 board an update on the status of petitions and

15 technical reports that are in process, and I'll

16 talk a little bit today about some of the

17 procedures that will be used later in this

18 meeting to vote on specific materials.

19 This particular presentation will be

20 posted on the NOP website. So, for those that are

21 taking notes, the full presentation will be

22 available on the NOSB meeting page.
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1 Okay, so, at this meeting we are going

2 to be addressing two petition materials which are

3 on the agenda and there are also 35 materials

4 that are up for Sunset under 2019. 

5 So, this will be the first meeting

6 where the Board will be considering those 35

7 materials for Sunset. There will also be voting

8 happening at the second meeting, but that won't

9 be until Fall.

10 In terms of the criteria that the

11 Board will be looking at in terms of evaluating

12 the materials, whether those are petition

13 materials or sunset materials, all of those

14 criteria are provided for under the Organic Foods

15 Production Act of 1990. 

16 We also have clear petition guidelines

17 and questions in the technical report, that are

18 all derived from those OFPA criteria.

19 So, in looking at petition materials

20 that come in, the technical reports and the

21 documents that the NOSB puts together through the

22 subcommittees for review and for public posting,
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1 all of those elements are derived from the

2 criteria in the Organic Food Production Act that

3 give the basis for how material should be

4 evaluated for organic compliance.

5 There are different criteria that

6 apply materials, whether they use on the

7 production side for crop or livestock uses versus

8 handling or processing, and there are also

9 additional criteria in the regulations, in

10 addition to those in OFPA for synthetic

11 processing aids and adjuvants and those are at

12 Section 205.600(b).

13 Okay, so, for the crops portion of the

14 agenda, at this meeting there are no petition

15 crop materials on the agenda. There is a

16 proposal from the crops committee regarding

17 marine algae listings on the national list.

18 This was not related to a petition but

19 was an agenda item that the crops subcommittee

20 had asked to add to the work plan following the

21 Sunset 2017 review of certain substances, and

22 that was an agenda item that the NOP agreed to
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1 have on the work plan. So, it's not petition

2 related, but came through a different mechanism.

3 But there are some other petitions

4 that are outstanding and waiting for crop

5 subcommittee proposal.

6 So, currently we have under

7 subcommittee review, petitions for allyl

8 isothiocyanate (AITC). Some of those may remember

9 that that was a petition material that came

10 before the Board previously. So, this is a new

11 petition, including new information that's asking

12 for a Board to reconsider the petition material.

13 There's also a petition for ammonium

14 nonanoate, also as reviewed by this Board

15 previously. There is a new version of that

16 petition. The initial one was sent back by the

17 Board. So, we're working on getting that posted. 

18 It may happen this week or next week, but there

19 is a new petition seeking subcommittee

20 reconsideration.

21 In addition, there are petitions for

22 anaerobic digestate, fatty alcohols, natamycin,
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1 polyoxin D zinc salt, and that polyoxin D zinc

2 salt was also a re-petition and a petition for

3 sodium citrate. 

4 In support of this review, the

5 subcommittee has requested the development of

6 several third party technical reports that are in

7 various states of development, and once those

8 technical reports have been developed, and

9 approved by the crop subcommittee, they will be

10 posted on the NOP website and available to the

11 public.

12 Okay, so, for the livestock

13 subcommittee, they have several petitions that

14 are also under review that won't be addressed at

15 this meeting, but you can look forward on either

16 the Fall meeting or later, and we have petitions

17 pending currently for glycolic acid, sulfur, 

18 hypochlorous acid, thymol, and 10 aquiculture

19 petitions that have been on hold for a while. 

20 So, the petition for hypochlorous acid

21 was submitted after the most recent

22 recommendations from the Board on hypochlorous
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1 acid. So, it's seeking additional uses beyond

2 what was in the previous recommendations, and

3 again, we do have several technical reports that

4 had been requested from the livestock

5 subcommittee that are in various stages of

6 review, and those will be posted once they're

7 complete.

8 Okay, from the handling committee, at

9 this meeting, the Board will be considering

10 proposals for two petitions, Short DNA tracers

11 and L-methionine. Those petitions are available

12 on the NOP website. There were no new technical

13 reports that were developed for those two

14 petition materials in support of their review.

15 Then we do have several other

16 materials issues that are pending full Board

17 determination that came from the handling

18 subcommittee.

19 So, again, these are not things that

20 came from petitions, but separate materials

21 issues that were added to the handling

22 subcommittee's work agenda.
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1 Those include a potential annotation

2 change for Tocopherols, a list -- proposal for 

3 marine algae listings, which affect several

4 materials that are currently on the national

5 list.

6 A proposal for ancillary substances

7 used in cellulose, which is our -- cellulose is

8 already on the national list, and a discussion

9 document regarding the use of Bisphenol A in

10 packaging, and the BPA proposal is just a

11 discussion document, and as per the current

12 policies of the Board, discussion documents are

13 not voted on at the meeting. They're generated

14 for additional information from the public, but

15 could become a proposal at a future meeting.

16 In terms of other petitions that are

17 currently pending before the handling

18 subcommittee, there is a petition for Sodium

19 dodecyl benzene sulfonate, that petition was

20 considered at a previous NOSB meeting and

21 deferred for a future meeting. So, that's still

22 under review, but is not on the agenda for this
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1 meeting.

2 There is also a petition for silver

3 dihydrogen citrate and natamycin. Those two have

4 technical reports that have been requested from

5 the handling subcommittee.

6 There's also a petition for Sodium

7 chlorite for the generation of chlorine dioxide

8 gas which was on a previous agenda, but we don't

9 have any revised proposal out yet.

10 So, again, those proposals -- all the

11 petitions are available on the NOP website, and

12 the technical reports once completed, will be

13 posted there, as well.

14 There are a few other petitions on 606

15 or agricultural substances that are petitioned to

16 the handling committee, as well.

17 Two petitions that were submitted by

18 the same petitioner for Ethiopian pepper and 

19 Japones pepper, and the recent petition for

20 Tamarind seed gum that was submitted to the

21 handling committee. 

22 So, those are currently under review. 
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1 No technical reports have been requested for

2 those three materials.

3 In terms of other technical reports

4 that are in development, we have -- again, the 

5 Bisphenol A, we have a technical report that is

6 currently in development, as well as one for 

7 anaerobic digestate in crops. 

8 That anaerobic digestate report was

9 requested in response to a petition, but has a

10 broader scope beyond just what was requested in

11 the petition, and that is fairly close to being

12 finalized. So, I expect it to be on the NOP

13 website not too long.

14 There was a new technical report

15 associated as a follow-up from the Sunset 2017

16 review of newspaper and other recycled paper, and

17 that report was developed and is now currently

18 available for the public on the NOP website. 

19 There is not a proposal for that particular

20 listing on the agenda for this meeting.

21 Okay, so, in terms of voting

22 procedures, for the two petition substances that
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1 are on the agenda for this meeting, the Board

2 will take two different votes for each particular

3 petition material. 

4 The first motion will be a

5 classification motion on how the material should

6 be classified. That would be classified as

7 either synthetic or non-synthetic for crop and

8 livestock materials or agricultural and non9 agricultural for handling materials.

10 Second motion will be a motion,

11 whether material should be listed, removed or

12 amended from the national list. So, in this

13 case, the two petitions are asking that the

14 material be added to the national list. So, the

15 motion will be made to list the material on the

16 national list, and with the motion being made

17 that way, it will take a two-thirds majority to

18 add that material to the national list.

19 So, with a Board of 15 members here it

20 will take 10 votes for both the classification

21 motion and for the listing motion to pass.

22 Okay, so, just a little bit about the
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1 Sunset 2019 listing. 

2 So, there are 13 listings under

3 consideration by the crops committee, eight for

4 livestock and 14 for handling. 

5 In this -- it's a little bit novel

6 process for us in that many of those materials,

7 all except one, don't actually have a Sunset date

8 of 2019. So, they have been advanced earlier in

9 the Sunset process, based on the recommendation

10 that came out of the Board at the Fall meeting,

11 to more efficiently organize the Sunset 2017

12 workload.

13 So, rather than having close to 200

14 materials all reviewed in one year, they're being

15 re-distributed over the next couple of years. 

16 So, that's why these were sent to 2019, 34 of

17 those materials have been advanced for this early

18 review. But again, they won't be voted on until

19 the Fall meeting.

20 The one material that does have a 2019

21 Sunset date is the crops material biodegradable,

22 bio-based mulch film.
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1 Okay, so, I think mentioned that, so

2 again, these materials will be considered at this

3 meeting, voted on at the Fall meeting. 

4 For those interested, we do have in

5 the NOP program handbook on our website, a list

6 of all the materials on the national list, as

7 well as their sunset dates. So, those sunset

8 dates are updated with the publication of final

9 rules or final notices, under the NOP sunset

10 process.

11 So, again, these ones won't show a

12 sunset date of 2019, but they are being advanced

13 earlier, based on that NOSB recommendation, and

14 that's available on the website for those that

15 want to look at the current sunset dates. 

16 I think that is all that I have today,

17 but I'm happy to take any questions that the

18 Board may have. Thank you. 

19 CHAIR CHAPMAN: Any questions for Dr.

20 Brines? Dan?

21 MEMBER SEITZ: How -- let's say a

22 sunsetted material up for sunset is moved forward
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1 in this process, as you say most of them are, and

2 the board votes that material off the list.

3 How does the actual -- what is the

4 date when that would take effect, assuming that

5 the rule process goes forward?

6 In other words, you're re-distributing

7 all the sunset dates, but are you changing the

8 actual time when something would be sunsetted? 

9 DR. BRINES: It's a good question. 

10 So, there was some guidance in the recommendation

11 from the Board in the Fall, in terms of what the

12 intent was on when those materials would come off

13 the list.

14 On a practical manner, the material

15 will come off the list when AMS completes the

16 rule making to take it off the list. So, we'll

17 have to go through the rule making process,

18 propose removal, take public comment and then

19 implement a final rule, and that final rule will

20 have an effective date.

21 So, at this point, it will depend on

22 what comes out of the Board, in terms of what
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1 that effective date may be, but we do have some

2 more flexibility for those that have later sunset

3 dates. 

4 CHAIR CHAPMAN: But to clarify, the

5 recommendation was to align with the original

6 sunset date, and we can make that wording clear

7 in our sunset recommendations.

8 Any other questions for Dr. Brines? 

9 Thank you, Dr. Brines.

10 DR. BRINES: Thank you.

11 CHAIR CHAPMAN: Up next is the chair's

12 report. So, please bear with me, as I talk on

13 for a little bit.

14 Again, I want to welcome everyone here

15 in attendance. I know folks have traveled from

16 far and wide to come here. For some, this may be

17 your first meeting, for others, one of many.

18 But what brings us all here today is

19 that we deeply care about this organic movement. 

20 We have some weighty issues on our work agenda.

21 Some things have lingered for some time and we

22 have to integrate fissures in our organic
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1 community. 

2 I'm not Pollyanna enough to think that

3 we'll be able to make everyone happy, or even

4 equally unhappy, like good regulation normally

5 does. But I hope that we can at least respect

6 and agree that we all are starting from the same

7 place. That is we all care about this organic

8 movement, as we're nurturing it and developing it

9 through these years.

10 We might not all be able to agree

11 where it should go, but I think we can respect

12 that we call care deeply about the movement

13 itself.

14 Hopefully, we can build on the

15 starting place of mutuality to find greater

16 common ground.

17 I wanted to thank the public for

18 bearing with us in the program during this change

19 in administration. I recognize our proposals for

20 public comment were available woefully late, and

21 this was a product of the pains of a massive

22 administration change, something our community is
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1 fairly new to having deal -- to deal with, given

2 that we served under the same Secretary of

3 Agriculture for the last eight years, and have

4 only undergone one major administration change

5 since the standards were effective in 2002.

6 However, I look forward to working to

7 the appointment of the Secretary of Agriculture

8 and working on an line agenda that brings value

9 to organic farmers, handlers and consumers alike,

10 through these voluntary regulations.

11 I also look forward to working on an

12 agenda that continues to promote and grow the

13 organic marketplace, while maintaining strict

14 consumer confidence in that label.

15 So, despite this short period of time

16 that our proposals were available, we did receive

17 over 2,000 written comments and will have just

18 under 12 hours of oral comment here at this

19 meeting and through the webinar.

20 So, that represents about 55 percent

21 of our total time at this meeting, from those

22 numbers, you can tell that we have both a very
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1 engaged public and a Board that really

2 appreciates and values those comments. 

3 I'm always very impressed by the range

4 of comments and the thoughtfulness of those

5 received.

6 Also want to warmly welcome my fellow

7 NOSB members, especially our new ones who are

8 just realizing what they got themselves into.

9 Your service and commitment to the organic

10 community is invaluable and I thank you for your

11 countless hours, unpaid, away from your farm,

12 from your students, from your colleagues and

13 especially your family.

14 I would be remiss if I didn't

15 recognize a major accomplishment that occurred in

16 January of this year. The program finalized and

17 published the Organic Livestock and Poultry

18 Practices Rule, and really want to thank the

19 program for their tireless work on getting this

20 rule published.

21 This was the impressive of this

22 accomplishment cannot be underscored enough, and
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1 it was a product of several NOSB recommendations

2 over several years, culminating in the unanimous

3 recommendation in 2011.

4 After countless public comment and

5 input, this proposal was widely supported by both

6 the community and the industry, from major trade

7 associations, to non-profits, to small livestock

8 and poultry farmers that look forward to working

9 with the new Secretary on implementing these

10 necessary requirements to a voluntary standards

11 and we stand ready to answer any additional

12 questions that the administration may have with

13 that. 

14 MEMBER SWAFFAR: Tom, I just wanted to

15 chime in here and -- is that okay? 

16 CHAIR CHAPMAN: Yeah.

17 MEMBER SWAFFAR: I just want to also

18 echo how proud I am to see this rule come into

19 effect. 

20 I spent a lot of time at past NOSB

21 meetings, commenting in support of this rule.

22 This is -- this rule is critically
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1 important and especially for the poultry

2 industry. Every week, I'm out inspecting poultry

3 farms and I hear from those producers how excited

4 they are for this rule to go into effect, and

5 especially how critical this rule is for the

6 success of their business.

7 This rule will greatly improve the

8 lives of millions of organic animals, and most

9 important part is allowing those animals

10 significant access to the outdoors, and so, I

11 would also just like to say thank you to Miles

12 and the entire department for all your hard work

13 on bringing this rule forward.

14 CHAIR CHAPMAN: Thank you. Harriet? 

15 MEMBER OAKLEY: I would like to add to

16 that, that when I read that regulation, I could

17 really see how the department, the agency had

18 really read the comments, had taken into account,

19 the numerous stakeholder comments and feelings

20 and this -- our voluntary regulation is really

21 representing what the stakeholders want that

22 organic label to mean, and I totally agree with
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1 Ashley there, that this is what the producers

2 want. This I what they want and it's going to

3 improve their bottom line. It's going to improve

4 their farms and it's going to improve the trust

5 in the organic label, and I just think it was a

6 tremendous undertaking and a very excellent final

7 product. 

8 CHAIR CHAPMAN: Thank you. With that,

9 I am now going to take care of some housekeeping

10 items, and then we'll move onto a break, and

11 after that, public comment.

12 So, first off, I'd like to review the

13 NOSB conflict of interest policy, which is

14 written out in accordance to our policy and

15 procedures manual. This is going to be a little

16 bit of boring talk. I apologize in advance. 

17 NOSB members are classified as

18 representatives under the Federal Advisory

19 Committee Act. Each representative is appointed

20 to articulate their view points and interests of

21 a particular interest group.

22 The Organic Food Protections Act
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1 prescribes these interest groups, which includes

2 farmers and growers, handlers, certifiers,

3 environmentalists and conservationists,

4 scientist, consumers and public interest groups,

5 as well as retailers.

6 As such, NOSB members are expected to

7 provide independent or not expected to provide

8 independent expert advice, but rather advice

9 based on the interest groups served.

10 NOSB members represent the interests

11 of a particular group, as such many of these

12 interests are acceptable interests.

13 In the interest -- any interest is

14 acceptable if it's carried out on behalf of the

15 represented group, and if the Board member

16 receives no disproportionate benefit from

17 expressing that interest.

18 True conflicts arise when an interest

19 directly or disproportionately benefits a member

20 or a person associated with that member or could

21 impair the member's objectivity in representing

22 their group or has the potential to create an
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1 unfair competitive advantage.

2 The appearance of a personal conflict

3 and loss of impartiality while not a true

4 conflict must also be considered when conducting

5 NOSB business.

6 To manage conflict of interest our

7 procedures are, once a discussion document

8 proposals are posted for public comment, each

9 NOSB member is to review those documents from all

10 subcommittees and research any potential

11 conflicts of interests due to their affiliations

12 or relationships.

13 Prior to the meeting, the program

14 provides a matrix of all the NOSB members that

15 lists all the items being considered at that

16 meeting. That's what's being displayed right

17 now. Sorry, I just lost my place, and members

18 use this matrix to disclose conflicts of

19 interests, for us to reference for recusals when

20 voting on these items.

21 If an individual is unsure if they

22 have a conflict of interest, then the question is
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1 posed to the DFO, the NOP and working with the

2 USDA Office of Ethics as needed, determination

3 will be made whether a conflict of interest

4 exists.

5 The matrix is again, now being

6 displayed and as you can see, we have no recusals

7 on items before us.

8 If there were recusals, we would also

9 remind Board members at the start of each

10 subcommittee, but given that we have no recusals,

11 we will not be doing that at this meeting.

12 If Board members wish to disclose any

13 additional information about their interests,

14 they are welcome to do so at this time. This is

15 a general request and is voluntary. No specific

16 statements are required, but I do ask, does

17 anyone wish to make a statement at this time? 

18 Asa? 

19 MEMBER BRADMAN: Just a very quick

20 statement. I was remiss in my self-introduction

21 to mention that I'm also on the Board of Trustees

22 of the Organic Center. It's a volunteer
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1 position. Really, all my work around these

2 issues are volunteer and I have no vested

3 interested, but I wanted to also mention that. 

4 Thank you.

5 CHAIR CHAPMAN: Okay, and I for

6 myself, Clif Bar & Company, may use or have

7 suppliers who may use or may be under

8 consideration of using items up for sunset on the

9 handling lists, and our supply chain may use

10 items up for sunset on the crops list, but these

11 do not disproportionately benefit myself of my

12 company, and therefore, do not represent a

13 conflict of interest.

14 All right, moving on from conflict of

15 interests. 

16 I ask folks to be courteous of their

17 neighbors, public commenters and to the Board,

18 please, please silence your phones, your

19 computers, and take any conversations outside to

20 the hallway. 

21 Please try not to be distracting to

22 the Board or presenters if walking around the
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1 room or using media to document this meeting.

2 We do have a stand placed up here. 

3 We'd ask the public to refrain from coming behind

4 those, as it's distracting to the Board member

5 listening to testimony or deliberating on the

6 issues at hand. 

7 This is not to deter the public

8 interaction with individual members during the

9 break. We still encourage that.

10 Those being disruptive will be warned

11 and if disruption is continued, they will be

12 asked to leave the meeting.

13 I do plan on running a tight ship, but

14 with a bit of humor now and then and my only ask

15 is that you laugh at all my jokes, starting right

16 now.

17 For the -- those of you who don't have

18 a calendar, tomorrow is April 20th, and for those

19 of you who don't know, there will be a 4/20 rally

20 occurring in downtown Denver. There will be

21 additional security at this hotel and if you are

22 stopped, please do tell them that you're
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1 attending the NOSB meeting in the Majestic

2 Ballroom, and I do ask that you give yourself

3 extra time to arrive tomorrow. If you have public

4 comment and are not staying at this hotel, they

5 are expecting around 50,000 to 100,000 folks in

6 the downtown area.

7 All right, lastly, a reception is

8 being held tomorrow at 6:00 p.m. at the Whole

9 Foods Market, Rocky Mountain Regional Office. 

10 It's a little north of the ballpark, I believe. 

11 So, folks will likely need to cab there. 

12 But that's it for me right now. So,

13 we'll take a break and we'll start back up at

14 11:00. So, that will be about 25 minutes from

15 now. Little bit earlier than what's listed on

16 the agenda. Thank you, guys.

17 (Whereupon, the above-entitled matter

18 went off the record at 11:42 a.m. and resumed at

19 11:44 a.m.)

20 CHAIR CHAPMAN: So, we're ready to

21 about get started with the public comment section

22 of the agenda. 
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1 We're going to pull up some slides

2 real quick to go over the public comment policy

3 as it's taken from the NOSB policy and procedures

4 manual.

5 I just want to point out that all

6 persons wishing to comment here were generally

7 asked to sign up in advance. We will work with

8 folks that walk in, as time allows, and people

9 will be called to speak in order of the listing.

10 However, if we are running ahead of

11 schedule like we are now, or behind schedule,

12 which we will likely be later, your time may

13 shift. So, do be prepared to be early or late.

14 Michelle, can you go to the next

15 slide?

16 The time allotment for public comment

17 will be three minutes. You'll get a yellow light

18 when there is one minute left, and then it will

19 go red, as the time expires. 

20 Michelle, do we want to test the

21 system out, so folks can see it?

22 All right, tells some jokes. I got 
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1 no jokes. Jokes, anyone, from the Board? Jokes? 

2 Jokes, anyone? Miles? Nothing. That's pretty

3 weak.

4 All right, I'll actually just keep

5 yapping on, in the time period until the red

6 light goes off. 

7 So, when that red light goes off,

8 please finish up at your sentence. I do hate

9 interrupting folks. But in order to ensure equal

10 access, I will interrupt you. If you continue

11 for too long after that red light, but don't run

12 away quite yet from the podium. We will ask the

13 Board members if they have any questions for you

14 and proceed from there. 

15 If you have a presentation, there is

16 a remote for you to use, to click through the

17 slides, and then moving down. 

18 Persons are asked to give their names

19 and affiliations for the record. I'll be asking

20 everyone -- there we are. So, I guess I have to

21 stop talking now.

22 I will be asking everyone to start by
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1 saying their name and affiliation for the record. 

2 We ask that you disclose all relevant

3 affiliations pertaining to matters of business

4 before the Board.

5 If members of the NOSB want further

6 clarification, I do encourage you to ask

7 questions after the public commenter finishes

8 their comment.

9 I will be asking for this name and

10 affiliation before each commenter, to remind

11 folks and to also give you an opportunity to set

12 your name straight for the record, as I will

13 likely have butchered it when I called you up. I

14 apologize for that in advance. It was a joke you

15 guys were supposed to laugh at.

16 No proxies are allowed, and we also

17 ask that commenters refrain from making personal

18 attacks or remarks that impugn the character of

19 another individual. 

20 If I do hear something of the nature,

21 I will interrupt the commenter and ask him to

22 refrain from the activity, and we also ask that
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1 commenters be clear and succinct. It is your

2 three minutes to talk about what you wish,

3 previous point notwithstanding. 

4 But just because you may be able to

5 speed read does not mean that we are good at

6 speed listening. So, this is the guidance that

7 we give.

8 So, with that, that's all I have for

9 public comment introductions, and we'll start

10 with the first public commenter, Theo, and up on

11 deck after Theo is Les Frankel. 

12 Theo, for the record, can you please

13 state your name and relevant affiliation? 

14 MR. CRISANTES: Hi, Board members. 

15 Yes, my name is Theojary Crisantes. Just Theo

16 for short. I work for Wholesum Harvest. I'm a

17 grower, so, I'll start my comment now.

18 My name is Theojary Crisantes. I'm a

19 grower at Wholesum Harvest. We grow vegetables

20 in open field, shade houses, and greenhouses,

21 both in the ground and in containers.

22 I'd like to take this opportunity to
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1 comment on the crop subcommittee discussion

2 document about agriponic, hydroponics, aquaponics

3 from April 2017.

4 Specifically, the statement regarding

5 plant-based materials, like coconut coir, wood

6 shavings and peat, used as a growing medium and

7 defined as biologically recalcitrant, resistant

8 to biological attack, they will break down slowly

9 over time, but do not serve as a substantive

10 source of nutrients for plants being grown.

11 As stated in written comments, there

12 is ample literature that describes these plant13 based materials such as coconut coir, as a source

14 of nutrients for plant growth.

15 Together with micro-biological

16 activity, they're an excellent growing media. 

17 We've been growing vegetables in coconut coir for

18 more than 10 years and our own observations and

19 microbiological analysis coincides with this

20 literature.

21 Please refer to our written comments

22 for reference on the literature.
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1 Furthermore, I would like to comment

2 on the proposed definition of hydroponic systems.

3 To include in the definition, the

4 concept of biologically recalcitrant soil --

5 solid materials, in my mind, creates confusion

6 and departs from the previous definitions this

7 Board has put forward in the past.

8 I would like to suggest that more --

9 a classic definition of hydroponic growing

10 systems would be adopted to read the following:

11 The production of normal terrestrial

12 vascular plants grown in a medium that is only

13 constituted by inert solid materials, to which 

14 and inorganic nutrient solution is added.

15 To address some of the questions from

16 the discussion document, I would like to add that

17 regardless of the production method, liquid

18 fertility needs should be addressed by site19 specific conditions determined by the grower in

20 according with his or her organic system plan.

21 My comment on the Canadian standard is

22 that it's currently under revision, to address
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1 the volume requirements, and this standard does

2 not address site-specific conditions, that

3 generate different soil volume requirements --

4 requirements for different crops and growing

5 regions.

6 Thank you for the opportunity to

7 comment and at this time, are there any questions

8 from the Board? 

9 CHAIR CHAPMAN: Thank you. Thank you. 

10 Any questions? Francis?

11 MEMBER THICKE: Thank you, Theo. You

12 mentioned that the coconut coir does provide

13 substantial nutrition for your plants.

14 Can you tell me what percent of your

15 plant nutrition rely on for coconut coir? 

16 MR. CRISANTES: I didn't say that it

17 provided substantial. I said that it provided

18 nutrition for the plants.

19 So, in -- there is -- you know,

20 literature that states that it provides potassium

21 and other micro-nutrients.

22 So, I think there is no one single
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1 input that is like a -- that it will have every

2 single answer to all the questions.

3 I think to think that one single input

4 can actually provide everything is very, you

5 know, short-minded or something like that.

6 So, it's the combination of coconut

7 and other inputs that creates the -- that creates

8 the nutrition.

9 CHAIR CHAPMAN: Emily and then

10 Harriet.

11 MEMBER OAKLEY: Thank you. I believe

12 you stated that you've been growing in coconut

13 coir for 10 years. 

14 MR. CRISANTES: Correct. 

15 MEMBER OAKLEY: Have you been

16 certified organic that whole time? 

17 MR. CRISANTES: Yes, ma'am.

18 MEMBER OAKLEY: Okay.

19 CHAIR CHAPMAN: Harriet?

20 MEMBER OAKLEY: Is your operation

21 undercover or are you doing containers in the

22 field without covers, plastic covering? 
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1 MR. CRISANTES: It's -- we have it

2 under covers. So, it's a glass greenhouse. The

3 ones that we have our containers. Yes, it is

4 under cover. 

5 MEMBER BAIRD: You said you go both in

6 ground and container growing.

7 MR. CRISANTES: Correct, yes, ma'am.

8 MEMBER BAIRD: Do you -- could you

9 tell us a percentage of additional inputs that

10 you would use in in-ground versus container or is

11 there a difference?

12 MR. CRISANTES: I don't find any

13 differences. There is -- there is -- you know,

14 there is different inputs that are used in one

15 system and then the other. But there is not a --

16 not -- I wouldn't say there is more inputs used

17 in one or the other. 

18 I think that it becomes question of

19 site-specific conditions, and that's why we grow

20 both grow open field, shade houses, plastic

21 houses, because depending where we're at and the

22 conditions that we're growing those vegetables,
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1 you know, we find that most suitable system or

2 approach that would work for there.

3 You know, we have a greenhouse in

4 Arizona, which is, you know, very arid and I

5 would say, you know, the conditions there for the

6 soil are not the best, but Arizona has a really,

7 really good sunlight, for example, and so,

8 chasing sunlight, we decided to establish

9 ourselves in Arizona, and that's why we choose

10 containers in that particular situation.

11 MEMBER BAIRD: Could I do a follow up?

12 CHAIR CHAPMAN: Yeah.

13 MEMBER BAIRD: Okay, have you done any

14 type of research showing nutrient density of

15 those foods that are grown in the -- in the

16 ground versus those that are grown in your

17 container systems? 

18 MR. CRISANTES: No, ma'am. We're just

19 growers. You know, we're not --

20 MEMBER BAIRD: Okay. Okay. 

21 MR. CRISANTES: Exactly.

22 MEMBER BAIRD: Okay, thank you. 
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1 CHAIR CHAPMAN: Any other questions? 

2 Sorry, I didn't see you. We'll do Ashley and

3 then Asa, yes. 

4 MEMBER SWAFFAR: So, I have a question

5 that nobody can answer. But do you know that if

6 what percentage of like the tomatoes, cucumbers,

7 peppers, eggplant, squash, that you grow, as an

8 industry, what percentage of those are grown

9 organically in containers or hydroponically?

10 MR. CRISANTES: As far as I know, the

11 SCAN data is only divided between greenhouse and

12 open field, because it goes back down to the POU

13 number and there is no difference between POU

14 numbers for tomatoes in the ground or tomatoes in

15 containers.

16 So, it would be, you know, very

17 difficult to come down and explain, you know, and

18 pinpoint that, and I -- I -- you know, it's not -

19 - I wouldn't have information to comment really

20 on that, and that's why the data probably doesn't

21 exist.

22 CHAIR CHAPMAN: Asa?
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1 MEMBER BRADMAN: Looking at your

2 website, but do you produce any conventional

3 produce, as well? 

4 MR. CRISANTES: No, we don't.

5 MEMBER BRADMAN: So, it's all organic? 

6 MR. CRISANTES: Yes, sir.

7 MEMBER BRADMAN: Okay, then -- 

8 MR. CRISANTES: We produce, sell,

9 distribute organic produce. That's our business.

10 MEMBER BRADMAN: Okay, then the

11 question I have, perhaps for additional

12 presenters is, I want to hear the difference

13 between an organic container system and a non14 organic container system. I don't know if you

15 could comment on that. 

16 MR. CRISANTES: Well, I can comment on

17 what makes organic containers, and I think the --

18 you know, the grave challenge is the nutrition

19 piece, because it -- it requires you to be very

20 careful in providing a great balance between the

21 inputs that you use and the biology that is

22 created in the roots.
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1 So, for example, trying to have their

2 right balance of bacterial and fungi in the

3 roots, is quite important. Brewing teas, compost

4 teas, that are fungal or bacterial, depending on

5 the season, and so, turning -- I think the most -

6 - the biggest challenge is doing that, and I

7 think that's where the skepticism from some

8 members come from, because they don't understand

9 that piece, and I've had sent a letter to the

10 Board, inviting everybody on the Board to come

11 and visit our facilities in Arizona, so you guys

12 could, you know, see for yourselves, what it

13 takes to do it, that you can -- you know, we've

14 been certified for a long time and we've been

15 inspected many, many, many times. 

16 So, by our grade inspector, I would

17 say Quality Assurance International, and so, you

18 know, having you guys come over is something that

19 we would proud of, to show you guys how it's all

20 done, so you can understand that piece, which is,

21 I think the most compelling one.

22 CHAIR CHAPMAN: I'm going to wrap this
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1 up. So, Ashley and then I have a question and

2 we'll wrap it up.

3 MEMBER SWAFFAR: Sorry, I just wanted

4 to say thank you for answering the questions that

5 the crop committee posed. Not very many people

6 answered the question, and those are critical. 

7 MR. CRISANTES: Thank you. 

8 CHAIR CHAPMAN: And then I have one

9 last question for you, Theo.

10 Can you speak to how your operation

11 meets the soil ecology requirements under the

12 regulations as they're written today? 

13 MR. CRISANTES: And you're referring

14 to soil fertility, composting, manuring and --

15 okay, and crop rotation.

16 So, what we do specifically and it's

17 really site-specific. But I'll talk a little bit

18 about the one in Arizona.

19 So, we use the compost -- sorry, we

20 use the coconut coir to grow the tomatoes and

21 then once the cycle of the tomato is finished on

22 the coconut coir, we take that coconut coir and
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1 take it to our fields outside the greenhouse.

2 We introduce that coconut into the

3 soil. We do that because we want to be able to

4 continue the cycle of that -- of that -- of that

5 coconut coir and create the manuring process, and

6 be able from there to -- it has a lot of

7 biological activity. It has a lot of nutrients. 

8 It has a lot of life left into it.

9 So, we bring it in. We incorporate

10 into the soil and then we grow Sudan grass.

11 The Sudan grass is then used for

12 composting in our own facilities. But the great

13 majority of the production of that Sudan grass

14 ends up in a local -- with a local farmer there

15 that uses it to feed his cows.

16 With the trimmings of the tomatoes, we

17 use that as well, to create compost. Part of our

18 compost recipe includes the tomato leaves,

19 includes the coconut that we use to grow, as

20 well.

21 So, cycling is something very

22 important and it's something that's embedded in
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1 the way that we, you know, that we produce

2 tomatoes.

3 So, going back a little bit on the

4 nutrition piece inside the container, there is a

5 lot of cycling that needs to take place, for

6 those inputs to be available for the plant.

7 So, the presence of microbiology in

8 the roots creates that -- you know, helps create

9 that process. 

10 So, I don't know if I answered your

11 question to your satisfaction.

12 CHAIR CHAPMAN: Thank you. With that,

13 thank you for your time in answering our

14 questions, Theo. We'll move onto the next

15 speaker.

16 MR. CRISANTES: Thank you.

17 CHAIR CHAPMAN: Next up is Lee Frankel

18 and on deck is Christie Badger. 

19 Lee, please start with your name and

20 relevant affiliations. 

21 MR. FRANKEL: Sure. I'll take care of

22 that housekeeping first. Thank you. 
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1 My name is Lee Frankel, I'm the 

2 Executive Director of the Coalition for

3 Sustainable Organics. Thanks. 

4 On behalf of the members of the

5 Coalition for Sustainable Organics, I thank you

6 for the time you are volunteering to help

7 maintain the integrity and value of the USDA

8 organic program.

9 The first and foremost, I urge extreme

10 caution with the approach being proposed by the

11 crops committee to use Section 205.105 to ban

12 various production methods. 

13 The definition of hydroponics is

14 written in a way that will eliminate the use of

15 nursery trees, early generation sweet potatoes

16 and other critical important seeds by many

17 organic growers when Section 2508 of the OFPA is

18 applied.

19 Second, the NOSB has been presented

20 with data through the task force and written

21 testimony showing that all organic systems share

22 an active biology that ultimately helps to care
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1 and feed the plant in a symbiotic manner.

2 However, there is still questions

3 about the biology of organic container systems. 

4 So, I came up with an illustration of what this

5 may look like terms that we are more familiar

6 with.

7 Non-organic is represented by this

8 tasty meal from across the street, and the 

9 salad of mixed greens with tomatoes represents an

10 organic production system.

11 Both system provides calories, but

12 they interact with our bodies in very different

13 ways. 

14 Now, think of the bowl as growing in

15 the outer crust of the earth, and this platter as

16 a container system. Both systems are organic but

17 each has its advantages and disadvantages.

18 Likewise, other soil or containers can

19 be appropriate methods, depending on the site20 specific conditions a grower faces.

21 There are a few statistically

22 significant differences in between the biology of
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1 growing organic in containers or in the outer

2 crust of the earth, as has been documented and

3 prepared for publication by Dr. Martin Dufresne

4 of Agriculture and Agri-Food Canada.

5 Of those few differences found in the

6 research, it actually showed slightly higher

7 levels of biological activity in container

8 systems.

9 Third should be called the standards

10 of other countries. The Canadian standard does

11 not require being in the outer crust of the earth

12 and describes the parameters of how to use

13 containers and now, here is an example of the

14 recommended European standards where this plant

15 in its container is still organic. But if I cut

16 it, now it's no longer can be sold as organic.

17 So, are those other countries really

18 just regulating supplies in the market with their

19 regulations, rather than showing a deep belief in

20 the absolute necessity to only grow organics only

21 in the outer crust of the earth?

22 Ultimately, we should let the
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1 consumers of the United States help guide a

2 decision. In a survey of regular organic U.S.

3 consumers presented at the Fall NOSB meeting it

4 showed that U.S. consumers overwhelmingly support

5 the continued inclusion of containers in the USDA

6 organic program, and believe that the integrity

7 of the USDA program would decline if

8 certification were to be revoked for organic

9 production systems. Thank you. 

10 CHAIR CHAPMAN: Thank you, Lee. Any

11 questions for Lee? I see Francis, then Harriet,

12 then Ashley. Francis? 

13 MEMBER THICKE: Thank you, Lee. Can

14 you tell us a little bit more about your

15 organization, when it was formed and who are

16 members of it? 

17 MR. FRANKEL: Certainly. You know, I

18 think as the NOSB was starting to reactively

19 consider the question of, you know, what are the

20 roles of containers and production systems not on

21 the outer crust of the earth, you know, number of

22 growers that used those methods started to show
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1 up and testify a couple years ago at the Spring

2 NOSB meeting.

3 I think, you know, roughly then

4 shortly thereafter, the hydroponic task force was

5 formed, I guess people saw how that, you know,

6 got changed from its original vision of kind of

7 creating the nice data set for you guys to use,

8 to something much more policy oriented.

9 So, I guess growers got together, just

10 over a year ago, to come together and say, okay,

11 let's kind of pool our resources, do research,

12 try and serve the needs and answer the questions

13 of the NOSB.

14 So, there was roughly 40 growers that

15 are members, that are currently organic certified

16 producers that included containers as some part

17 of their production systems. 

18 CHAIR CHAPMAN: Harriet? 

19 MEMBER OAKLEY: I'm looking at your

20 produce there. It looks like it's mostly annual

21 crops. Is that correct? 

22 MR. FRANKEL: I guess for this
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1 demonstration, it's annual crops. But there's

2 perennial growers, as well.

3 MEMBER OAKLEY: Right, but for you --

4 so, if -- if we had a container standard that

5 required a certain percentage of soil or compost

6 to be in your substrate, could you transition

7 your operation over to that type of production? 

8 MR. FRANKEL: I guess different

9 members have different systems. 

10 So, for some, if you're looking at a

11 shorter crop that -- you know, does need lots of

12 aeration and maybe it's a good idea to put

13 earthworms in there. 

14 If you're growing berries in a

15 container, for five to seven years, you know,

16 that will ruin the aeration of the system, and

17 so, maybe it's not such a good idea to have that

18 level of biology. So, it kind of comes back to

19 each individual grower, kind of what they're

20 growing, how long they're growing it, and whether

21 they're just kind of doing it for a real purpose

22 of if they're just doing it to kind of hit a
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1 checkbox on the standard somewhere.

2 So, I guess that's -- if somebody

3 growing -- based on the system, you know, if

4 they're going to be harvesting that product in a

5 matter of weeks, you know, yes, they can throw a

6 pinch in there, but it's not necessary -- you

7 know, the biology that they're trying to support

8 in their root zone doesn't dictate that that

9 would necessarily be a best practice. 

10 So, some people can do it, but again,

11 it depends on the site-specific conditions. 

12 CHAIR CHAPMAN: Ashley?

13 MEMBER SWAFFAR: So, can you answer my

14 question? Do you know what percentage of each

15 organic vegetable or herb is grown in containers

16 or hydroponically? 

17 MR. FRANKEL: Sure. I can try and

18 elaborate on the data that Theo just referenced,

19 because I know some SCAN data, as he said, you

20 know, the current distinction is just between

21 greenhouse and in the ground, as opposed to in a

22 container and in a greenhouse, in the ground.
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1 You know, I guess that division is

2 roughly about 30 percent or 35 percent of retail

3 sales are now greenhouse grown in the organic

4 category, and their growth rate was two or three

5 times the rate of -- in the field product for

6 tomatoes, cucumbers, bell peppers, and I haven't

7 seen data for the other products. 

8 MEMBER SWAFFAR: Follow up to that. 

9 So, that's not specifically for organic. That's

10 for all?

11 MR. FRANKEL: No, that's for --

12 specifically for the organic POU.

13 MEMBER SWAFFAR: Okay, but one thing

14 I would like to see, since you're speaking for

15 that industry is, I would like to see those

16 numbers, if you can somehow gather them. 

17 You know, what percentage of tomatoes

18 are grown --

19 MR. FRANKEL: Certainly.

20 MEMBER SWAFFAR: -- hydroponically or

21 containers, you know, we'll have the Fall meeting

22 to -- I would love to see that.
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1 MR. FRANKEL: Okay, I'll try and

2 follow up sooner than that, to see if I can get

3 access to some of the SCAN data. 

4 CHAIR CHAPMAN: Emily? 

5 MEMBER OAKLEY: Ashley, I was just

6 going to note that those would be retail sales in

7 a grocery store setting, but they wouldn't

8 necessarily -- well, they wouldn't reflect

9 direct-to-consumer sales, and a lot of organic

10 farmers do do direct-to-consumer sales. 

11 MR. FRANKEL: And then, I guess again,

12 one of the other weaknesses of that data set is

13 Costco isn't necessarily a regular supplier of

14 data to that system, but they do have in their

15 spec, that for the organic tomatoes, cucumbers

16 and peppers, that it needs to be container grown. 

17 So, I guess you lose some and gain

18 some in different places. 

19 CHAIR CHAPMAN: I think we'll go with

20 Francis and then we'll end the questions here. 

21 Francis?

22 MEMBER THICKE: A question about your
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1 graph. I remember looking at the full survey and

2 the survey said that previous to this question,

3 they listed all of the benefits of container

4 growing and hydroponics and then came back and

5 asked, do you think it's good, and could you tell

6 us what that paragraph was, that was -- 

7 MR. FRANKEL: I had provided a copy of

8 that full report one more time --

9 MEMBER THICKE: Okay.

10 MR. FRANKEL: -- in a written

11 comments.

12 MEMBER THICKE: Well, I just wanted to

13 point out that first there was a series of

14 statements given to the person -- people being

15 asked the question about all the benefits of

16 hydroponics and then came back and answered the

17 question, if it's good.

18 So, it would seem a little bit loaded,

19 I would have to find out. 

20 MR. FRANKEL: We can try to write the

21 information in a -- as non-biased way as

22 possible, but again, I guess everybody has to say
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1 something at some point. So. 

2 CHAIR CHAPMAN: Thank you, Lee. Up

3 next we have Christie Badger and following that

4 is Jacob Moore. 

5 Christie, if you could speak -- say

6 your name and affiliation for the record. 

7 MS. BADGER: Christie Badger. 

8 National Organic Coalition. Ready? Okay.

9 Thank you for the opportunity, as

10 always, to be a part of this exciting process,

11 and thank you to you for the important work that

12 you do to further strengthen the organic label

13 and the organic integrity.

14 I want to thank the handling

15 subcommittee for providing transparency into the

16 ancillary substances in cellulose. The list

17 includes some substances, but should not be used

18 in organic production.

19 The presence of these materials on a

20 list of materials used in organic products

21 reveals problems with the process that

22 identifies, but does not evaluate ancillary
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1 substances.

2 Due to the objectionable

3 characteristics of these, the NOSB should

4 prohibit their use and the proposal should be

5 turned down. The proposal raises larger issues

6 and shouldn't make it clear that a policy of

7 allowing additional ancillary substances based on

8 functional class as proposed by the handling

9 subcommittee does not make sense.

10 The integrity of the organic label

11 depends on the NOSB performing its role in

12 evaluating substances as a gatekeeper of the

13 national list. It is imperative that the NOSB

14 develop a process for reviewing ancillary

15 substances that allows the Board and the public

16 to evaluate hazards of the materials.

17 NOC does not support the petition to

18 add short DNA tracers to the national list

19 because they were created using excluded methods

20 and do not meet the OFPA criteria of

21 essentiality.

22 We do, however, support the need for
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1 a verification system to strengthen organic

2 integrity and would request that the CACS take up

3 the issue by adding certification for exempt

4 handlers to the work plan.

5 Indeed, from our conversation with Mr.

6 McEvoy at the NOC pre-NOSB meeting, it would

7 appear that this is an issue on which the NOP

8 would welcome additional recommendations.

9 As Miles pointed out, the current

10 focus of the NOP will be on organic integrity and

11 supply chain, and what can be done in the short

12 term to address issues created by exempt handlers

13 until further rule making can take place.

14 We strongly encourage the NOSB to take

15 advantage of this opportunity to further explore

16 implementing existing organic requirements to a

17 broader range of current exempt organic handlers.

18 NOC thanks the crop subcommittee for

19 the good work done on the proposal to strengthen

20 and clarify the requirements for the use of

21 organic seed. It's clear that much consideration

22 was put into the proposal and much progress made. 
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1 However, we feel there is still work to be done. 

2 Here again, we would point to concerns

3 around uncertified seed dealers and handlers that

4 are not being addressed.

5 In addition to my work with NOC and an

6 organic inspector, performing approximately 200

7 inspections a year, I see issues around

8 uncertified seed dealers and handlers regularly. 

9 As the subcommittee noted, it's very

10 clear that this has turned into a loophole, when

11 it comes to the use of organic seed. 

12 CHAIR CHAPMAN: Thank you. Any

13 questions for Christie? Dan? 

14 MS. BADGER: Be kind.

15 MEMBER SEITZ: Could you elaborate a

16 little bit more on the concerns about ancillary

17 substances?

18 As I read about them, apparently these

19 are used but then kind of disappear from the end

20 product or they leave trace elements. On the

21 other hand, it seems to me sort of intuitively

22 that you would to take a look at every substance
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1 that somehow is involved in producing an organic

2 product.

3 So, just if you could explain a little

4 bit more about your concerns about that. 

5 MS. BADGER: Okay. Sorry, I'm just --

6 I have a couple notes here, I wanted to put up,

7 in case that question came up.

8 So, specifically, on -- on this

9 proposal, vinyl chloride and Kymene were both --

10 are both genotoxic carcinogens, which are

11 considered to have no threshold below which they

12 do not cause cancer.

13 Vinyl chloride is classified as a

14 Group 1 carcinogen by the IARC and Kymene is a

15 brand name product whose ingredients are

16 considered trade secret. However, so, IARC

17 doesn't have a rating, but the MSDS sheet for

18 Kymene states that it is genotoxic carcinogen.

19 So, given that the fact -- given the

20 fact that there is no threshold below which they

21 do cause cancer, whether or not they -- you're

22 saying that they at some point, disappear from
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1 the product?

2 MEMBER SEITZ: No, I'm just trying to

3 understand a little bit, how we look at them as a

4 Board because they seem to -- the indication that

5 I get is that somehow they're used in processing,

6 but then they more or less disappear, maybe

7 leaving trace elements. But I'm trying to

8 understand what is really happening with these --

9 these ancillary substances from your perspective. 

10 MS. BADGER: If they do leave trace

11 elements, that's obviously a huge concern for

12 these two products.

13 I know when we were discussing this,

14 I said as a consumer of organic products, it

15 makes me extremely angry to think that I could

16 have been feeding this to my child.

17 Frankly, these two products from a

18 Google search came up, to show that they were

19 Group 1 carcinogens.

20 So, I'm perhaps, not even suggesting

21 that there is a lot of work to be done on this. 

22 Perhaps a Google search before we post something
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1 would be a good idea. Our consumers do it. So.

2 CHAIR CHAPMAN: Thank you. 

3 MEMBER MORTENSEN: Christie, could you

4 -- could you finish the last point on the

5 loophole and just -- 

6 MS. BADGER: Under -- I'm sorry?

7 MEMBER MORTENSEN: On the seed

8 guidance loophole that you were referring to.

9 MS. BADGER: Thank you. I appreciate

10 that.

11 Yes. Okay, so, I ended -- and that

12 was from a quote from the subcommittee's work

13 about the loophole.

14 As noted previously, given the stated

15 current focus of the NOP, it would appear that

16 it's just an opportune time for the CACS to add

17 this certification of exempt handlers and seed

18 dealers to their work plan, and based on these

19 comments along with other issues presented in our

20 written comments, NOC would request that the NOSB

21 not pass the seed proposal as written.

22 If you would like more information
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1 about how it creates a loophole, I'd be happy to

2 answer that, as well, if that's what you're

3 asking, Dave, or I'd be happy to talk with you

4 more about it. 

5 MEMBER MORTENSEN: Maybe we could talk

6 about it later, but I think you answered what I

7 was asking.

8 MS. BADGER: Okay.

9 MEMBER MORTENSEN: Yeah. 

10 MS. BADGER: Great. 

11 CHAIR CHAPMAN: Thank you, Christie. 

12 MS. BADGER: Thank you.

13 CHAIR CHAPMAN: We'll be moving on now

14 to Jacob Moore and on deck is Mark Kastel. We're

15 working on getting an on deck chair over here,

16 but if the people on deck could go hang out near,

17 Dr. Brines, that would be appreciated. So, we

18 can quickly move between folks. 

19 Is Jacob Moore here? Jacob Moore

20 going once. Jacob Moore going twice. Mark,

21 looks like you go from on deck to on. 

22 So, the new on deck is Tom Harding. 
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1 Tom Harding could go over by Dr. Brines. That

2 would be appreciated. 

3 MR. KASTEL: I didn't have a chance to

4 warm up. She's not starting me yet, and I hope

5 you'll have as many questions for the public

6 interest community as some of the corporate

7 lobbyists and industry folks. Thank you.

8 My name is Mark Kastel. I'm the --

9 CHAIR CHAPMAN: I'm sorry, Mark, can

10 you also for the record, state your name and your

11 affiliation? I apologize. 

12 MR. KASTEL: Okay, start over again. 

13 Okay, good morning. My name is Mark

14 Kastel. I'm the Co-Director of the Cornucopia

15 Institute. We have a staff of 12 from Portland,

16 Maine to Portland, Oregon, including attorneys

17 with backgrounds in environmental and animal and

18 agricultural law, experts in farm policy and

19 agricultural economics and scientists.

20 Organics is a values-based industry. 

21 Cornucopia's focus is on protecting the

22 fundamental ethical precepts that this -- that
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1 has garnered strong support in the marketplace

2 and made this an economically successful

3 industry. Much of this success is now at risk.

4 Organic family farmers who milk cows

5 are having their milk checks cut and some are

6 losing their businesses. Families who produce

7 eggs can't compete with organic farms with a

8 million birds in confinement, in automated aviary

9 systems, and in some commodities like soy beans,

10 80 percent or more of the opportunities for

11 families to make a living here in the U.S.

12 benefitting from the success of organics has been

13 lost.

14 At this meeting, we will discuss

15 whether or not to throw out some of those

16 fundamental values and whether we are going to

17 continue the economic opportunities that we've

18 gained by shifting diets to healthier fare here

19 in the United States, or whether we're going to

20 hand that over to the agroindustrial sector.

21 I can remember back in the 70s and

22 80s, one of the mantras of the organic movement
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1 was feed the soil, not the plants. The focus was

2 on building organic material, biological activity

3 and nutrients that would create long term, truly

4 sustainable mediums to grow our food in, better,

5 more nutritious food, more flavorful food, while

6 protecting the earth.

7 Now, corporate lobbyists in this room

8 are going to tell you that feeding plants

9 continuously with a liquid fertilizer solution is

10 either pure water, sprayed through the air or in

11 containers filled with mostly inert ingredients

12 is organic.

13 This is a gross betrayal of the

14 organic movement. Stare decisis is the legal

15 axiom that guides the United States Supreme Court

16 in not overturning rulings, after issues have

17 been thoroughly and carefully vetted. 

18 Just because the major organic

19 industry lobby group and the hydroponic industry

20 now want to apply the term organic to hydroponic

21 fruits and vegetables should not justify

22 overturning prior NOSB deliberations with the
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1 public's input and running roughshod over

2 language in both the existing regulations and the

3 enabling legislation that require careful soil

4 stewardship as a pre-requisite for organic

5 certification.

6 There is a higher authority in the

7 U.S. There is a higher authority than the USDA

8 or even a higher authority that the federal

9 courts, and that will decide these issues, the

10 organic consumer. Thank you.

11 Oh, thank you. I did speak to the

12 chair briefly. I'd like to close just by saying a

13 few words about Dave Engel, who many of us know. 

14 Dave recently passed away. He was a

15 pioneer in this movement and attended many NOSB

16 meetings over the years. Dave was one of seven

17 founding farmers who launched the crop

18 cooperative that later became Organic Valley and

19 served on its first Board of Directors.

20 He ran Wisconsin's OCIA chapter and

21 would later be instrumental in forming MOSA and 

22 MOSES, which now runs the largest organic farming
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1 conference in the country.

2 In recent years, he's also operated

3 Nature's International Certification Services,

4 blessed be the memory of Dave Engel and Maarten

5 Sampson, who also recently passed away and was a

6 pioneering inspector. Thanks for that

7 opportunity.

8 CHAIR CHAPMAN: Thank you, Mark. 

9 Thank you for bringing up Dave Engel's memory. 

10 His loss was felt by our community. 

11 MR. KASTEL: So, if there is any

12 questions. 

13 CHAIR CHAPMAN: Any questions for

14 Mark? Dan and then Ashley. 

15 MEMBER SEITZ: Just to try to

16 understand the essence of your comment, would you

17 say that there is any issue with how the law and

18 the regulations are written, from your

19 perspective, in terms of protecting what you

20 could consider the integrity, or is it more how

21 they are enforced? 

22 MR. KASTEL: Yes. I think it's current
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1 enforcement problem.

2 The USDA National Organic Program very

3 quietly allowed a select group of certifiers to

4 decide to certify hydroponic production without

5 the use of soil. 

6 It's very clear in both OFPA and the

7 initial regulations, the current regulations,

8 that soil stewardship building soil, maintaining

9 and improving soil fertility is part of the pre10 requisite for gaining certification.

11 If somebody tells you that you have to

12 have a certain components on your automobile, 

13 Federal Highway Transportation Safety

14 Administration, or it's not road worthy or a

15 state administration, and you don't use part of

16 those components that are required, you're

17 operating illegally, and you know, in terms of

18 this comparison, we don't have the science

19 either.

20 You asked the representative from

21 Wholesum Harvest, which is a multi-billion dollar

22 corporation and to answer a question they didn't,
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1 number one, a minute percentage of their

2 production is in soil. Almost all of it is

3 hydroponic under glass or plastic, and when you

4 asked -- and I can't remember if it was you, Dan,

5 that asked about the nutritional content and they

6 said they didn't know, I'll quote Jesse Jackson

7 who once said, "If you want the right answers,

8 you have to ask the right questions."

9 So, if you want to depend on plausible

10 deniability, don't ask those questions.

11 The Cornucopia Institute doesn't have

12 the resources to do that kind of testing. The

13 industry could have done it a long time ago, if

14 they wanted. We're looking into right now.

15 But, you know, certainly we shouldn't

16 sanction hydroponic production, until we know

17 whether part of the promise in organics which is

18 not just lessening the toxic load on our bodies

19 and our blood streams, but it's also documented

20 to increase nutritional level.

21 There is a lot of peer-reviewed

22 science that supports that, but nothing that's
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1 been peer-reviewed that supports hydroponics as

2 being on a par with that organic production. 

3 CHAIR CHAPMAN: Thank you. Thank you,

4 Mark. Any other questions for Mark? 

5 MEMBER BRADMAN: I had a question. In

6 some of the comments, there was a suggestion that

7 there could be perhaps, another label for

8 hydroponic, and then I think when I think of

9 compromise, I also think of, if there was an

10 environmentally sustainable hydroponic or

11 container system, if it were labeled properly, do

12 you think that could fit in with the NOP or would

13 require some other kinds of label? 

14 MR. KASTEL: We haven't asked our

15 legal team to take a look at whether or not

16 labeling -- an extra label in addition to

17 organics, would be legal.

18 I think it would be quite confusing to

19 the consumer. We're not fundamentally opposed to

20 organic production, and I buy organics once in a

21 while that are labeled organic. I don't consider

22 that on a par with traditional organic
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1 production.

2 But once in a while in the winter, I

3 might want a tomato that's not available locally

4 and I don't have a greenhouse grower. It's an

5 exception.

6 But to take the organic label and put

7 it on that production and it's happening right

8 now, there is no consumer information right now. 

9 You won't know, unless you look for that Wholesum

10 Harvest sticker, and that's just one brand,

11 whether your Driscoll's brand berries are from

12 hydroponics or whether your tomatoes -- and they

13 don't say it's hydroponic on there. Just happens

14 to have their trade name.

15 So, certainly, the sustainable -- call

16 this Coalition for Sustainable Agriculture -- Mr.

17 Frankel is a contract lobbyist who works for

18 them. They form this to try to convince you

19 folks that that production was on a par.

20 They could certainly develop their own

21 label and sell the public on the superiority of

22 their products, in their mind, and we would be
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1 happy in the organic community, to compete with

2 that and there is nothing wrong. That's what our

3 capitalistic system is all about, is giving

4 consumers choice and accurate information, so

5 they can make discerning purchasing decisions.

6 CHAIR CHAPMAN: Thank you, Mark. Any

7 additional questions? Thank you. 

8 MR. KASTEL: Thank you, Mr. Chair.

9 CHAIR CHAPMAN: Up next is Tom Harding

10 with Nancy Burtman on deck. Tom, if you could

11 start with your name and relevant affiliations. 

12 Thank you. 

13 MR. HARDING: Tom Harding and I'm

14 speaking on behalf of Shenandoah Growers in

15 Harrisonburg, Virginia, who is a certified

16 organic greenhouse producer. They produce

17 organic living herbs in containers.

18 Good morning to everybody, and thank

19 you for all the good work on the NOSB and the

20 NOP.

21 I will not reiterate in detail what I

22 will be passing around, which was also on the
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1 webinar the other day. But I wanted to highlight

2 some points about, first of all, the components

3 of the soil mix.

4 Our blend of soil mix is put together

5 all through -- through compost and a number of

6 other materials, all of them approved by the NOP. 

7 The nutrient solution is composed from vegetative

8 matter, which is then utilized again, approved

9 NOP materials, and to increase the biological

10 capability of that material, and at the same

11 time, provide nutrition to the plant and

12 hopefully to the consumer.

13 This biological activity is very

14 critical and making sure that it produces that

15 type of plant is critical to us.

16 The other thing is the water system.

17 Our whole water system is either from the well,

18 not much of it is collected from the greenhouses,

19 through the root system. None of it is again,

20 exited to the outside. It goes through a

21 filtration system. It is cleaned and it is

22 reused.
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1 The pest management system is an

2 organic integrated pest management system using

3 all aspects of integrated pest management that

4 are approved for organic use, including pests

5 that we release.

6 The technology is a cutting edge

7 technology. It's a gutter system. It has been

8 approved both in Europe and in America. It's been

9 certified organic for a number of years, and the

10 important thing about that is we're on six acres

11 down in the Shenandoah Valley. That same six

12 acres, in order to produce what they produce

13 annually there, would take 180 acres of actual

14 field grow.

15 The important thing here is to

16 recognize that we employ over 1,100 employees

17 throughout the company and each of them are very 

18 proud of the living herbs they produce in pots,

19 that go to retailers, directly to consumers to

20 finish their growth and for utilization.

21 We believe there is plenty of room in

22 the organic market for certified organic
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1 container units that in fact, meet the

2 requirements of the National Organic Program. 

3 It's critical that we hold those standards and

4 clearly define what is truly a hydroponic system,

5 what is a containerized system and even what

6 those components, whether it be soil, a soil mix,

7 a compost or other materials, that all of it

8 meets the requirements.

9 You must clearly define what that term

10 means and all of the components that make up

11 what that system will be defined as.

12 Please remember that in the next 20

13 years, based on FAO, container or I should say

14 greenhouse and protective systems will grow at

15 least 40 percent and that most of that will be

16 done in urban and suburban areas, utilizing old

17 buildings and a number of other things. 

18 Do not cut the technology off because

19 it's an opportunity for us to clearly define that

20 they will all be under certified organic

21 provisions. Thank you all very much. 

22 CHAIR CHAPMAN: Thank you, Tom. Any
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1 questions for Tom? Harriet?

2 MEMBER OAKLEY: So, Tom, did you say

3 that the Shenandoah growers are growing in soil,

4 is that correct, or soil mix and what percentage

5 -- 

6 MR. HARDING: It's a composite mix of

7 compost --

8 MEMBER OAKLEY: -- what percentage of

9 the mix is soil or compost? 

10 MR. HARDING: I don't know. I don't

11 think much of it is soil. I think most of it is

12 compost and other materials that they blend

13 together.

14 MEMBER OAKLEY: And then what

15 percentage of the nutrient requirements -- these

16 are annual plants? 

17 MR. HARDING: These are grown on a

18 routine basis. They mature to a degree and then

19 they're sold to the consumer for further growth

20 and utilization. 

21 MEMBER OAKLEY: Oh, so, they're

22 growing plants for sale? It's a bedding plant
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1 business?

2 MR. HARDING: No. It is a living herb

3 business --

4 MEMBER OAKLEY: I see. 

5 MR. HARDING: -- in pots.

6 MEMBER OAKLEY: So, they sell basil

7 plants. Somebody can take it home and --

8 MR. HARDING: Correct, and finish off.

9 MEMBER OAKLEY: -- and take off leaves

10 and the plant keeps growing?

11 MR. HARDING: Exactly.

12 MEMBER OAKLEY: Okay, what percentage

13 of the nutrient requirements of the plant are

14 provided by outside liquid fertility inputs?

15 MR. HARDING: I think it's about a

16 50/50 mix. 

17 CHAIR CHAPMAN: Thank you. 

18 MEMBER ELA: I'm curious, given that

19 that's a living thing that you're selling to the

20 consumer, and presuming the consumer is not

21 adding any other fertility, once they take it

22 home, how long will that plant continue to -- to
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1 -- I'm going to say thrive or survive in that --

2 in that soil or compost, once the consumer has

3 it? 

4 MR. HARDING: Good question. 

5 Normally, between 30 and 60 days, depends upon

6 the husbandry of the consumer.

7 CHAIR CHAPMAN: Thank you. Emily?

8 MEMBER OAKLEY: So, depending upon the

9 husbandry, does that mean if the consumer adds

10 liquid fertility themselves, it will last longer

11 or if they add nothing to it, how long will it

12 live? 

13 MR. HARDING: Important is adding

14 water to it. 

15 CHAIR CHAPMAN: A-Dae?

16 MEMBER ROMERO-BRIONES: Just curious.

17 You mentioned at the end of your presentation, 30

18 to 40 percent of these operations will be in

19 urban areas. I mean, I didn't catch that last

20 part. Can you speak to that? 

21 MR. HARDING: That's a good point. 

22 FAO has put out a report based on what they see
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1 the future being in trying to feed a hungry

2 world, and one of the things that was said in

3 that report was that in the next -- by year 2020,

4 more or less, we will have grown 40 percent of

5 protective or greenhouse types of systems.

6 Many of those will be grown in

7 suburban and urban areas, particularly if you go

8 to New York City right now, there are a number of

9 these type of greenhouse systems, many of them

10 under artificial lighting of course, but some

11 not, that are growing plants for local

12 consumption in those cities, and I don't see that

13 trend stopping at the moment.

14 MEMBER ROMERO-BRIONES: Can you

15 mention the report title one more time? 

16 MR. HARDING: It's an FAO report. I

17 would be glad to send it to you, so you have the

18 access to that FAO report. It's a composite

19 report with a lot of different other things, and

20 looking at the future of agriculture and how it

21 feeds the world.

22 MEMBER ROMERO-BRIONES: Thank you.
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1 CHAIR CHAPMAN: Please send that

2 report to Michelle. 

3 MR. HARDING: Thank you.

4 CHAIR CHAPMAN: We'll be looking at

5 that. Tom, thank you for your comments. Up next

6 --

7 MR. HARDING: Thank you.

8 CHAIR CHAPMAN: -- we have Nancy

9 Burtman and on deck is Michael Sligh. Just so

10 people realize, we are running about 15 minutes

11 behind the schedule at this point. Nancy, please

12 state your name and record -- name and

13 affiliations for the record. 

14 MS. BURTMAN: Okay, my name is Nancy

15 Burtman. I am volunteer for Food and Water

16 Watch, and I'm here as a consumer who is directly

17 impacted and extremely concerned about the use of

18 oil and gas drilling waste water on organic

19 crops.

20 Federal regulations prevent drillers

21 from disposing of this wastewater in rivers and

22 streams, yet this water can sometimes meet state
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1 quality standards, for what I don't know, and it

2 doesn't cover dangerous chemicals used in

3 fracking like benzene, a cancer causing chemical

4 which can stay in the water.

5 Farmers in some parts of California

6 are irrigating their organic crops with water

7 from districts that accept drilling wastewater. 

8 Some farmers know this and some do not.

9 We know California has more organic

10 farms than any other state and makes up 40

11 percent of all organic sales in the country.

12 Consumers have no way of knowing if the food they

13 buy has been irrigated by drilling wastewater and

14 it uses 175 different chemical constituents. 

15 This is why I am here today.

16 So, what can you and your Organic's

17 Board do about this? We need your help. You

18 need to admit this is an issue and address it.

19 That organic label on a food product

20 has to mean something. I'm one of a growing group

21 of the population who must, due to medical

22 reasons, do something and eat organic foods only.
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1 I can't eat at restaurants or a

2 friend's houses. I can't buy any organic crops

3 from California at all. I get very sick.

4 I special order seeds for my garden. 

5 I take a lot of supplements, vitamins, and when I

6 find something "good", I buy as much as I can.

7 Even though I'm so careful, I still

8 get sick two to three times a week, and I only

9 buy organic foods.

10 So, there is a part of the population

11 that has to deal with this daily, that have

12 reaction to the chemicals in our food, and you

13 need to help us know that organically labeled

14 foods are organic only.

15 Two, you need to consider the impacts

16 of fracking and using wastewater as discussions

17 are held on how to prevent contaminating organic

18 production.

19 Three, you need to help spread the

20 details about OFPA's efforts to address fracking

21 in their area and share this plan with other

22 certifiers and the USDA, to help organic farmers
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1 defend themselves from fracking.

2 Four, you need to talk, and talk

3 loudly about the impact fracking on organic farms

4 and call for it to end. I go to Whole Foods,

5 Natural Grocer's, Sprout's, Trader Joe's, and no

6 one at these stores knows about this and how long

7 has this been going on? At least two to three

8 years I've been reading about it.

9 So, the time is now for the Organic

10 Board to help us, so when we buy something

11 organic, we know it really is organic because we

12 depend on that label to mean that these things

13 aren't getting into the foods that we're eating

14 and making us sick and other people sick, and

15 they're not even aware of it. Thank you for your

16 time. 

17 CHAIR CHAPMAN: Thank you, Nancy. Any

18 questions for Nancy? Dan?

19 MEMBER SEITZ: I'm curious. How do

20 you know for sure that there are organic farmers

21 that may be using water that comes out of a

22 fracking operation? 
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1 MS. BURTMAN: Well, I've read a lot of

2 articles that state that they've been selling

3 that water to the farmers, and it's been stated

4 as fact.

5 I've read a lot of articles. I could

6 pass them along to you. Some of the farmers

7 don't know it is that kind of water, because it's

8 been "treated". Yet a lot of the chemicals still

9 come through in the treating of it, and I just

10 assumed I was fine because I was buying organic. 

11 But I was still getting sick.

12 I went back to the doctor and got

13 treated, and discovered that -- I don't know if

14 I'm addressing your question. I might be going

15 around it but -- 

16 MEMBER SEITZ: No, that's fine. That

17 -- you've read a number of articles and it might

18 be good to forward those.

19 MS. BURTMAN: I would be happy to do

20 that.

21 MEMBER SEITZ: Thanks. 

22 CHAIR CHAPMAN: Please share those
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1 with Michelle and she can --

2 MS. BURTMAN: Okay.

3 CHAIR CHAPMAN: -- circulate them to

4 the Board. Any other questions? Emily? Emily,

5 Sue and then Miles.

6 MEMBER OAKLEY: I just wanted to ask

7 if you'd read part of OFA's public comment, which

8 was a fact sheet from the California Water Board

9 regarding produced water and irrigation water,

10 because I agree, this is definitely not something

11 that organic farmers want consumers to be

12 concerned about.

13 But according to that fact sheet

14 whether or not -- you know, I can't vouch for it,

15 but they say that they used produced water not

16 from fracking, but from oil and gas activities.

17 So, I just wanted to point you to that

18 fact sheet, and maybe contact the California

19 Water Board for potential further questions that

20 you might have.

21 MS. BURTMAN: Right, and I've read

22 it's from both sources, from both the oil and
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1 gas, and the fracking water. I've heard they've

2 used both those sources, and they have had a

3 water problem there. 

4 So, you know, they need to grow their

5 crops and use some kind of water, but isn't there

6 any other kind of water, and then the -- the

7 issue comes up, well, you're working so hard to

8 grow crops that are organic. You're getting the

9 soil. You're getting the crops, and then if

10 you're using water, that negates it as being an

11 organic -- you know, organic produce.

12 So, it's like how can you label it

13 organic when putting the water to grow it negates

14 is as being organic, because we know what the

15 organic label means. 

16 So, it's bringing in all the things

17 that you have kept away from it, and it kind of

18 makes it a moot point, and I wouldn't even know,

19 if it didn't make me sick.

20 CHAIR CHAPMAN: Thank you, Nancy. 

21 MS. BURTMAN: I mean, I have a lot of 

22 friends who do organic and they're fine. The
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1 chemicals don't affect them. I just happen to be

2 one of those group of people who reacts to those

3 chemicals and --

4 CHAIR CHAPMAN: Thank you, Nancy. We

5 have Sue and then Miles, and then we'll wrap it

6 up. 

7 MEMBER BAIRD: I am sorry for your

8 chemical imbalance. I've got a friend who is

9 incredibly, and I know that it's a real problem.

10 My question to you, as NOSB, are you

11 asking us to -- to perhaps write that as a

12 prohibition to organic farmers, that they can't

13 use fracking -- fracked water? What are you

14 asking us to do? 

15 MS. BURTMAN: Well, what I'm asking is

16 that how did this ever come to be, that we're

17 using water on organic crops that keep it from

18 being organic, because organic is free of

19 pesticides, chemicals and all those other things,

20 yet the water is now making those organic crops

21 not organic anymore. 

22 It's compromising it and it should not
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1 be labeled as organic, if we're allowing the use

2 of these water -- of this water, that's coming

3 from the oil and gas and the fracking waters, it

4 shouldn't be allowed to be labeled organic unless

5 a better water source is being used to grow those

6 crops. That's what I'm saying. 

7 CHAIR CHAPMAN: Thank you. 

8 MS. BURTMAN: It like negates it. It

9 shouldn't be allowed to be labeled as organic

10 because we've seen that label to mean something

11 very specific. The public sees that label and

12 thinks, oh, okay, this is a special food product

13 that we can rely on to buy and feed ourselves and

14 our families --

15 CHAIR CHAPMAN: Thank you. 

16 MS. BURTMAN: And --

17 CHAIR CHAPMAN: Thank you, Nancy.

18 MS. BURTMAN: -- that's what -- okay.

19 CHAIR CHAPMAN: Miles?

20 MR. McEVOY: Yes, water is really

21 interesting in the USDA organic regulations. 

22 It's not really addressed in much detail, in
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1 terms of water as an input.

2 There is the requirement under 205.200

3 about organic operations, organic producers in

4 particular have to maintain or improve soil and

5 water quality.

6 But in terms of water as an input, the

7 regulations are pretty silent on that, and there

8 is a wide diversity of water sources that are

9 used by organic farms around the world. It's

10 something that the Board and the program haven't

11 really looking into in a lot of detail.

12 In terms of fracking water, we have

13 looked at that, and we have not identified any

14 organic farms that are using any water from

15 fracking operations and I think we've also -- I

16 don't think it's allowed in farm production at

17 all to use any water from fracking operations.

18 Now, the produced water that you were

19 speaking about, there is some of that that is

20 being used that's from -- not from fracking, but

21 from oil production and that's the report that

22 Emily was referring to. 
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1 MS. BURTMAN: Talking about, yeah.

2 MR. McEVOY: Right. But fracking

3 water is not being used. 

4 MS. BURTMAN: Okay, well, I'd be happy

5 to get those articles and send them along to you. 

6 

7 CHAIR CHAPMAN: Thank you, Nancy. 

8 Please do.

9 MS. BURTMAN: Okay, thank you.

10 CHAIR CHAPMAN: Up next is Michael

11 Sligh, and Dave Chapman is on deck. Michael, if

12 you could start by stating your name and relevant

13 affiliations for the record. 

14 MS. SLIGH: My name is Michael Sligh

15 with the Rural Advancement Foundation

16 International, and a part of the ever growing

17 alumni of the NOSB.

18 I have six issues I am trying to bring

19 before the Board. I'll probably make it through

20 three.

21 The first is that now is the time for

22 us to be united in positive communications on the
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1 multiple benefits of organic to the U.S. economy. 

2 We must do a better job about reaching to the new

3 administration, the new Congress and especially

4 to the new Secretary of Agriculture, for them to

5 understand that organic is unique in the federal

6 regulatory framework, that we are built on the

7 idea of having regulation and in fact, we came

8 and asked for regulation. 

9 So, this is a critical understanding

10 for them to take home, and that the current

11 proposed USDA budget cuts pending ag

12 appropriations and the ongoing new Farm Bill

13 cycle require all of us to really fully engage

14 this because the outcomes of this will determine

15 our future growth and prosperity.

16 The NOSB must also play a role in

17 this, in communicating your research priorities

18 to the new Secretary as early as possible, so

19 that they understand specifically what our needs

20 are as we go into this new round of the Farm

21 Bill.

22 Secondly, new genetic techniques. We
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1 strongly urge the NOSB to reconvene this ad hoc

2 working group and to finish this work and bring

3 it to a final vote by the Fall meeting.

4 This is critical because this is

5 timely to similar activities happening in other

6 countries, as well as the IFAOM World Congress in

7 India in the Fall. It would be very, very

8 important for the NOP to be able to provide

9 either guidance or instruction to the organic

10 certification community about this issue, so that

11 we don't end up with market disruption and

12 problems in the near future.

13 Thirdly, the issue of organic seed

14 purity. I have gone into some detail in the

15 written paper, about the larger macro challenges

16 that we have in getting regionally adapted seeds

17 to farmers. I urge you to look at that as well as

18 our link to a larger paper on this topic.

19 But I also want to say was one of the

20 authors of the original allowance for non-organic

21 seed, that we did this on purpose to recognize

22 that this is something that will affect farmers
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1 in 120 countries, and that we also don't want to

2 inadvertently reduce agriculture bio-diversity on

3 agricultural farms, and that I would argue that

4 that is a better measure of our progress, as to

5 whether or not we are indeed increasing

6 agricultural bio-diversity on organic farms.

7 That was our intent with the

8 definition and that was our intent with allowing. 

9 You should think of it not so much as a loophole,

10 but more as a safety valve. 

11 CHAIR CHAPMAN: Thank you, Michael. 

12 Any questions? Harriet?

13 MEMBER OAKLEY: I'm kind of interested

14 in what your critical area of concern is. 

15 MR. SLIGH: Thank you for asking,

16 Harriet.

17 I guess this is an issue that I bring

18 to the new NOSB. This is the pattern -- we have

19 this re-occurring pattern that we have not

20 resolved, where the NOSB will make

21 recommendations, maybe over a long period of

22 time, and the USDA sometimes not really -- you
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1 know, able to move that recommendation fast

2 enough into regulatory clarity.

3 So, we fall in this kind of grey area

4 where the market goes faster than our ability to

5 have regulatory clarity.

6 So, some of the examples that are very

7 frustrating to all of us on all sides of the

8 issue, you know, the access to the outdoors, the

9 hydroponics, the aqua-culture, the long list of

10 things and potentially, the new genetic

11 techniques could be another one of these examples

12 where the market grows faster than our ability to

13 have regulatory clarity.

14 So, I challenge this Board to look at

15 this as a root cause analysis, to figure out what

16 it is that we can do different, to break this

17 pattern, so that we don't have so much division

18 that is across our community, because it hurts

19 people on all sides, if we don't have that

20 clarity in real time.

21 So, I just say we've tried many things

22 in the past. The department has tried many
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1 things, but I would say to date, we have not come

2 up with a solution to prevent that re-occurring

3 pattern. 

4 CHAIR CHAPMAN: Thank you, Michael. 

5 Any additional questions? Thank you.

6 MR. SLIGH: Thank you. 

7 CHAIR CHAPMAN: Up next is Dave

8 Chapman. On deck is Madison Monty. Dave, you

9 could start with your name and relevant

10 affiliation. 

11 MR. CHAPMAN: Hi. I'm Dave Chapman. 

12 I'm an organic farmer. I've farmed organically

13 at Long Wing Farm in Vermont for the last 37

14 years, and I also served last year on the USAD

15 Hydroponic Task Force, where I learned a great

16 deal about this subject.

17 I want to talk about a phrase that is

18 currently popular with hydroponic supporters. 

19 The circular firing squad.

20 This phrase implies that we all agree

21 on the important things and we are being divided

22 over a trivial side issue. But the current
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1 debate is actually about what organic stands for.

2 Some claim the foundation of organic

3 farming is just avoiding synthetic fertilizers

4 and pesticides. This is a misunderstanding.

5 The foundation of organic agriculture

6 has always been the development and maintenance

7 of fertile living soil. We believe all benefits

8 proceed from this starting point. Healthy

9 plants, healthy animals, healthy humans and we

10 now learn a healthy climate.

11 The outcome of this debate will decide

12 if the USDA is still worthy to serve and protect

13 organic integrity. If you decide that soil is

14 unimportant, certified organic will continue as a

15 brand, but it will lose its place as the world

16 leader of the healthy soil movement, and the

17 world needs that movement now, more than ever. 

18 We are running out of time.

19 The USDA had the legal right to define

20 organic in keeping with OFPA. But it has never

21 been given permission to reinvent organic in

22 order to serve the market needs of favored
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1 enterprises.

2 The NOP was created to serve and

3 protect, not to reinvent. Hard-won trust in the

4 organic seal is being destroyed and it will not

5 be easily won back.

6 This is the most important

7 recommendation you will ever make. You will

8 either tear apart the organic movement or you

9 will start to restore it.

10 When organic certification is reduced

11 to a marketing strategy that misleads consumers,

12 it loses its soul and it will soon lose its

13 followers, as well. How long will organic

14 flourish without those who have built it?

15 If certification no longer represents

16 soil health, many will move on. We will build

17 something that supports real organic with soil as

18 the center of a living system, that includes

19 plants, animals and microbes. The world needs

20 your leadership now, more than ever. So, please

21 choose well. Amazingly, I finished before the

22 bell. 
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1 CHAIR CHAPMAN: Thank you, Dave. 

2 Questions? I have Francis, Harriet, Ashley, Asa,

3 Joelle, Steve. We'll start with Francis and

4 Harriet, and then I'll go around again. 

5 MEMBER THICKE: Thank you, Dave. In

6 your work on the hydroponics, can you give us a

7 perspective, do you believe there is a difference

8 between hydroponic drilling and container

9 drilling and what that distinction might be, and

10 also this term biologically recalcitrant as a

11 medium, how that all -- what is your perspective

12 on that? 

13 MR. CHAPMAN: I'd say you know, the

14 task force was quite divided. About two-thirds

15 of the task force were ardent hydroponic

16 supporters and about one-third were ardent soil

17 supporters.

18 In the soil perspective, well, let me

19 give the real world perspective first.

20 In the real world, hydroponic

21 vegetable growing, most tomato, pepper, cucumber

22 and berry production takes place in containers,
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1 and the growing medium is either rockwool, which

2 is like fiberglass insulation or coco coir, and

3 they're used fairly interchangeably. Growers

4 might go one way or the other.

5 Some people like coco. Some people

6 like rockwool. They like coco because it doesn't

7 break down easily and it's very nice. It recovers

8 when you dry it out and the oxygen comes in for

9 the roots.

10 So, just because something is growing

11 in a container does not make it hydroponic. 

12 Hydroponic is whether or not you're feeding

13 liquid to provide the nutrition of the plant. 

14 Did I -- I think I missed part of your question. 

15 CHAIR CHAPMAN: Yeah, thank you, Dave. 

16 So, we have several folks here, so try to focus

17 on answering the specific question.

18 MR. CHAPMAN: I'm trying. Sorry.

19 CHAIR CHAPMAN: Yeah, no problem. 

20 Harriet, then Ashley, Joelle, Steve and Dan.

21 MEMBER OAKLEY: I'll follow up on

22 Francis's -- I'll follow up on Francis's
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1 question, and that is in a container, where there

2 is mostly compost or soil, and if the plant is

3 getting 90 percent of its nutritional needs from

4 that container --

5 MR. CHAPMAN: Yes. 

6 MEMBER OAKLEY: -- you know, it's a

7 big enough container and it has enough living

8 soil compost in there, would that be acceptable

9 for you to see that as -- as it not being

10 hydroponic --

11 MR. CHAPMAN: Right.

12 MEMBER OAKLEY: -- and instead being

13 an acceptable system for organic? 

14 MR. CHAPMAN: Yes. I believe there is

15 a problem in there. The task force report did

16 take that on, and our final recommendation from

17 the soil subcommittee was that from the point of

18 view of certification, we recommended to follow

19 the EU model of it must be grown in the ground

20 unless it's sold in the container in which it's

21 grown.

22 I believe it's possible to have a
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1 container system for sure, that is -- would have

2 90 percent of the benefits of soil grown and I

3 would call it hydroponic, but it's very easy to

4 game that system.

5 So, if you could ensure that there was

6 adequate soil volume and a limitation on the

7 liquid feed, so that the plant was actually

8 getting its nutrition from the natural biological

9 processes in that soil, I think that would be

10 acceptable, just hard to do from a regulatory

11 point of view. 

12 CHAIR CHAPMAN: Thank you. Next I

13 have Ashley.

14 MEMBER SWAFFAR: So, I have two

15 questions. First question is can you describe

16 your crop rotation practices in your greenhouses?

17 MR. CHAPMAN: Sure. Yeah. So, she's

18 been reading my mail.

19 So, we don't rotate our crop in my

20 greenhouse. We rotate the soil and it's quite

21 interesting, actually.

22 We're starting to cover crop the soil
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1 when we take it out and we'll grow a legume grass

2 mix for three or four years and then bring it --

3 add it -- let it rot down in the pile, add it to

4 our compost when we change the soil.

5 We have a very expensive greenhouse. 

6 We are not Luddites, contrary to popular stories. 

7 We have high level of technology and it's

8 expensive.

9 So, we need to have a high return for

10 that. We can't cover crop in our greenhouse

11 economically. But we want the benefits. So,

12 we're rotating the soil.

13 MEMBER SWAFFAR: Okay, and my next

14 question, you said in your comments just to

15 Francis that hydroponic, you define that as if

16 you're feeding liquid to the plant.

17 What percentage of nutrients come from

18 liquid fertilizers in your facility?

19 MR. CHAPMAN: None, and I actually

20 have grown in containers in the past, and I also

21 fed zero liquid. So, it was all coming from the

22 compost. We use a little organic Alfalfa meal. 
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1 Yeah. It's very possible. The conversation

2 about our choice being a choice between

3 hydroponic or not having that kind of level of

4 production is -- it's not a true choice. 

5 CHAIR CHAPMAN: Thank you. Joelle? 

6 MEMBER MOSSO: My questions have

7 already been asked.

8 CHAIR CHAPMAN: Okay, Asa, did you --

9 sorry, I missed you. 

10 MEMBER BRADMAN: I had -- I was kind

11 of repeating a question earlier --

12 CHAIR CHAPMAN: Sure.

13 MEMBER BRADMAN: -- although I have a

14 second. The first being, you know, I think I've

15 read some of your comments related to labeling,

16 and the possibility of another label, and I

17 wonder if you see if there were an

18 environmentally sustainable system that could be

19 container, or even hydroponic, or water based,

20 I'll even go further than just hydroponic.

21 Do you think that could fall within

22 the NOP program if there was a distinction, so
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1 consumers who are concerned about these issues

2 could make a choice? 

3 MR. CHAPMAN: My personal opinion,

4 Asa, is that organic means fertile soil.

5 So, I believe the appropriate way for

6 the bioponic industry to proceed is to do a PVP

7 with the USDA, that's a process verified program. 

8 They create their own label. They advertise it

9 to the customers. The USDA inspects and says,

10 yes, you are meeting your standards. We verify

11 that, and then you have total integrity.

12 I think that they could do a booming

13 business. I agree, many consumers don't care. 

14 But unfortunately, many people do, and the way

15 it's going now, it's not going to go well. They

16 could do that. It would work.

17 CHAIR CHAPMAN: Thank you. 

18 MEMBER BRADMAN: I have a follow up,

19 but we're using too much time.

20 CHAIR CHAPMAN: Is it brief?

21 MEMBER BRADMAN: I'll ask the

22 question.
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1 CHAIR CHAPMAN: Go for it.

2 MEMBER BRADMAN: You can interrupt if

3 it's not brief. 

4 CHAIR CHAPMAN: Go for it, Asa.

5 MEMBER BRADMAN: The question is about

6 liquid feeding.

7 It seems like one of your real

8 concerns is about the use of liquid fertilizers

9 in greenhouse or container systems as kind of

10 pushing it over into organic -- into a non11 organic model, paradigm.

12 What about if we're using liquid

13 feeding systems in a soil based systems, perhaps

14 if there's very low fertility, then we may

15 actually lose it -- using a large percentage of

16 liquid feeding in that environment, potentially.

17 I don't know --

18 MR. CHAPMAN: Yeah, absolutely.

19 MEMBER BRADMAN: -- the details here,

20 but I'd be interested to hear your comments on

21 that. 

22 MR. CHAPMAN: I advocate following the
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1 standards of the Soil Association in England,

2 where they limit liquid feeding to 20 percent of

3 the nutrients that the crop requires regardless

4 of whether it's in the field or in a greenhouse,

5 and I think that's a good standard.

6 I hope that we're not permitting

7 straight fertigation in the field. It's not

8 according to the standards. We shouldn't be.

9 CHAIR CHAPMAN: Thank you. I have

10 Steve and then Dan. 

11 MEMBER ELA: That was my question. 

12 So, thank you.

13 CHAIR CHAPMAN: Thank you, Steve. 

14 Dan?

15 MEMBER SEITZ: My question has been

16 answered.

17 CHAIR CHAPMAN: Excellent. Is there

18 any other questions I missed?

19 Thank you, Dave, for --

20 MR. CHAPMAN: Thank you very much.

21 CHAIR CHAPMAN: -- taking all of our

22 questions. Very appreciated. 
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1 Up next I have Madison and following

2 Madison is Courtney Ellis, if you go to the on

3 deck spot. Madison, could you state your name

4 and affiliation for the record? 

5 MS. MONTY: Sure. My name is Madison

6 Monty and I'm Policy Advisor for the Northeast

7 Organic Farming Association of Vermont.

8 NOFA Vermont and Vermont organic

9 farmers represent over 1,200 member and close to

10 700 certified organic producers and handlers. 

11 I appreciate this opportunity to

12 address the Board, and I'll be commenting today

13 on two discussion documents including eliminating

14 the incentive to the organic ecosystems to

15 organic production and hydroponics, aquaponics,

16 aeroponics, as well as a proposal on

17 strengthening the organic seed guidance.

18 While we haven't found this to be a

19 significant issue in Vermont, we support the

20 NOSB's efforts to prevent the conversion of

21 native ecosystems and high value conservation

22 land to organic production, and we appreciate the
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1 discussion document on this topic.

2 In general, we believe a rule change,

3 rather than the issuance of guidance by NOP will

4 be the best approach to addressing this issue. 

5 We also generally support an extended five year

6 waiting period for land that has recently been

7 converted from a high value conservation land or

8 native or fragile ecosystem.

9 We also support the NOSB's

10 recommendation for a rule change to require

11 annual documented improvement for sourcing and

12 using organic seed and planting stock, as long as

13 it is understood that there may be circumstances

14 that would warrant an exception.

15 For example, a producer may increase

16 their production in a crop where organic seed is

17 difficult to obtain, and therefore, their annual

18 sourcing percentage would decrease in that

19 situation.

20 In addition, we don't support the

21 inclusion of language that would require full

22 compliance with 205.204(a) because we don't feel
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1 it would be fair to burden the farmer with

2 sourcing organic seed and planting stock that

3 might not yet exist.

4 Finally, as you all know, the NOSB's

5 deliberations around hydroponic, aquaponic and

6 agroponic systems have substantial ramifications

7 for the future of organic.

8 Although there is a continuum of

9 methods used in greenhouse and container

10 production, as has been discussed, we believe the

11 distinction between the two ends of this

12 continuum, one being in-ground farming and the

13 other being bioponic systems is clear enough for

14 the NOSB to move forward with a prohibition of

15 the latter in organic.

16 While some container production may be

17 -- may approach the in-soil end of the continuum,

18 we prefer a situation where only in-ground

19 production can be labeled organic, aside from

20 some exceptions for bedding plants and herbs as

21 in the EU standard.

22 With regard to fully mature crop
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1 production in containers, clear standards are

2 needed before this type of can be considered to

3 meet the basic principles of organic in the

4 letter and spirit of OFPA. 

5 These standards would need to specify

6 the percentage fertility provided by liquid

7 fertilizers and include clear requirements for

8 soil volume and compost.

9 To that end, we support the

10 recommendations of the 2010 NOSB recommendation

11 subcommittee of the hydroponics task force for

12 liquid fertilization, soil volume and compost,

13 which Dave just mentioned.

14 Lastly, I wanted to address two of the

15 subcommittee's specific questions. The first

16 regarding an alternative label under OFPA for

17 hydroponics.

18 We're not confident that this would be

19 a meaningful solution, as it may still be

20 challenging for consumers to distinguish between

21 soil grown and hydroponic and may add to

22 confusion in the marketplace. Okay. 
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1 CHAIR CHAPMAN: You want to finish

2 your last sentence? 

3 MS. MONTY: Yeah, sure. I was just

4 going to add that if a distinct hydroponic label

5 is going to be established, we would support an

6 alternative, you know, outside of the OFPA label

7 under a separate USDA program, as Dave just

8 discussed, as well.

9 CHAIR CHAPMAN: Any questions for

10 Madison? Harriet?

11 MEMBER OAKLEY: So, even in ground

12 production, say in a greenhouse, how do you, as a

13 certifier, deal with artificial light, as well as

14 continuous use of some -- like a plastic

15 landscape cloth? 

16 MS. MONTY: We generally support the

17 use of artificial light, consistent use of

18 artificial light, only for the production of

19 transplants and not for mature crop production,

20 and as far as plastic landscape cloth, that would

21 be a better question for Nicole Dehne, who is our

22 certification director, who will be commenting
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1 tomorrow. She could answer that more fully for

2 you. 

3 CHAIR CHAPMAN: And you, Steve. 

4 MEMBER ELA: Just to clarify what you

5 said. So, at this point, you would -- your group

6 would support just soil based systems and you

7 prefer to leave the container issue to be defined

8 later at this point, draw the line on soil or not

9 and then -- and then back up and allow containers

10 as we define a more clear standard, is that

11 correct? 

12 MS. MONTY: Yeah, basically, yeah. We

13 would like to see container standards develop

14 more clearly and we definitely support that work.

15 But at this point, since there aren't

16 clear standards for container production, we

17 think in ground is the best approach.

18 CHAIR CHAPMAN: Joelle? 

19 MEMBER MOSSO: I have a question

20 regarding in ground growing. 

21 If you were to use the substrates that

22 are normally used in container growing and
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1 recreated that in ground, how would you view

2 that? 

3 MS. MONTY: I don't know how that

4 would be done. I mean, I think it would still --

5 MEMBER ELA: You incorporated it into

6 the -- 

7 MS. MONTY: -- a question of the --

8 MEMBER ELA: -- majority of this top

9 soil --

10 MS. MONTY: Okay.

11 MEMBER ELA: -- so that it would be in

12 the root zone.

13 MS. MONTY: Uh-huh. I mean, I think

14 really the question at the end of the day is

15 where the plants are getting their nutrients

16 from, and I think if the plants are getting the

17 majority of their nutrients from the soil, rather

18 than the liquid feeding system, then that is

19 acceptable.

20 CHAIR CHAPMAN: Any additional

21 questions? Thank you very much. 

22 MS. MONTY: Thank you very much.
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1 CHAIR CHAPMAN: Up next is Courtney,

2 followed by Vanessa Campuzano. Courtney, if you

3 start with your name and relevant affiliations

4 for the record. 

5 MS. ELLIS: Yes. My name is Courtney

6 Ellis. I am a nutrition therapist here in

7 Denver, and just to let you guys know, some of

8 the clients that I see regularly have digestive

9 issues, dysbiosis, auto-immune disorders and so

10 forth.

11 So, basically I want to start out by

12 saying this consumer driven rise of organic whole

13 foods is not a trend. It's a matter of life or

14 death for some people. 

15 Organic food is vital to our health

16 and well-being and should be viewed as medicine

17 and every time we put something into our bodies,

18 we need to decide if this is going to hurt us or

19 help us.

20 The food we eat, the water we drink

21 and the air we breathe directly affect our health

22 and when we water down our standards or require
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1 exemptions to the rules set in place for safety

2 and quality, our farmers, our soil, our

3 environment and our health suffer.

4 Food is not just fuel. It's

5 information and it communicates with our cells,

6 and every time we eat our food sends messages to

7 release hormones into immune cells. It also

8 communicates with our genes, by telling which

9 ones to turn on and which ones to turn off.

10 Our soil needs several minerals to

11 grow food and we need those minerals to survive.

12 Phytonutrients are part of the plant's

13 immune system and organisms in the soil stimulate

14 the plant to make more phytonutrients. Just as

15 the plant needs those nutrients, so do we.

16 Soil based organisms support our gut

17 health and immune responses. They help plants

18 grow and without their protection, healthy plants

19 become malnourished and are susceptible to

20 disease or contamination.

21 To quote Dr. Josh Axe, "Just as plants

22 grow best in healthy soil, teaming with highly
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1 active micro-organisms, we too need these

2 organisms to live a long and healthy life."

3 We now know that soil based organisms

4 nourish cells in the colon and liver and create

5 new compounds as B vitamins, K2, antioxidants and

6 enzymes. Soil based organisms can destroy or

7 crowd out harmful pathogens and kill off bad

8 bacteria that combine to puncture the gut wall.

9 There is a place for hydroponic foods,

10 but in my opinion, it should not be included

11 under the organic standard, and when I worked

12 with clients on improving their health, I need to

13 know they are getting healthy soil with their

14 food or some of them are just not going to get

15 better.

16 On a quick other topic on oil

17 wastewater and organic foods. Cruciferous

18 vegetables such as broccoli, cabbage and

19 cauliflower all have the phytonutrient

20 isothiocyanate which neutralize free-radicals and

21 cause cell damage, as well as protect against

22 certain cancers.
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1 If a client is facing cancer and wants

2 to use these nutrient dense foods as part of

3 their treatment plan, how does allowing oil

4 wastewater irrigation factor into it? How is

5 allowing benzene along with other chemicals we

6 don't know about, considered organic?

7 There are over 100 different chemical

8 constituents that have been reported in this

9 wastewater. How many more have not been

10 reported?

11 Our water treatment plants are

12 antiquated and failing all across the U.S., and a

13 prime example of that is benzene showing up in

14 our water supply, even after that water has been

15 treated.

16 Consumer purchase of organic produce

17 and products are skyrocketing and by choosing

18 organics we are sending a message that we want

19 GMO-free foods, we want foods free of pesticides

20 and herbicides, and we certainly don't want food

21 that has been watered with the oil wastewater. 

22 Thank you so much for your time.
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1 CHAIR CHAPMAN: Thank you. Any

2 questions? Thank you. Thank you.

3 MS. ELLIS: Thank you so much.

4 CHAIR CHAPMAN: Up next is Vanessa. 

5 Is Vanessa here? Vanessa, going once. Vanessa,

6 going twice. No Vanessa.

7 Is Patty from Food and Water Watch

8 ready? Patty, you're up next and Abby is on

9 deck. Patty, if you could start, when you get up

10 there, I apologize, for just pulling you up, with

11 your name and affiliation for the record.

12 MS. LOVERA: Yeah, and I just heard

13 that Vanessa was dealing with a parking meter. 

14 So, maybe she can get back in the queue when

15 she's back in.

16 Hi. My name is Patty Lovera and I

17 work for Food and Water Watch in our Washington,

18 D.C. office, and you've heard from several other

19 folks from here in Colorado, that are either

20 staff or volunteers with us, and they're here

21 because they're your customers. They're organic

22 consumers. 
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1 We're -- Food and Water Watch is also

2 a member of the National Organic Coalition, and

3 so, you're going to hear comments from them on

4 other topics, which we support, but I wanted to

5 spend a couple minutes kind of talking about the

6 bigger picture of why we think it's important for

7 the organic community to start talking soon and

8 loudly about the impact of oil and gas drilling

9 is having, not only on the environment, but on

10 our food system.

11 So, people are becoming more aware of

12 the impacts on our environment, of our public

13 health of this industry, but it's becoming

14 increasingly clear to us that this is an industry

15 that is becoming into conflict with our food

16 system, whether it's the drilling sites

17 themselves, whether it's traditional drilling or

18 fracking, the pipelines and infrastructure that

19 it takes to move the oil or the gas, and even the

20 tentacles extend even further into communities

21 that don't have gas, but have something like

22 sand, that has to be used in fracking wells, that
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1 comes from specific parts of the country, like

2 Southeastern Minnesota and 

3 Southwestern Wisconsin.

4 So, the tentacles of this industry

5 spread very far and they spread in rural

6 communities where we raise our food.

7 So, water use is an issue. We're

8 going to see conflict between farmers who need

9 that water just to access it to grow, especially

10 in places like Colorado, the contamination of the

11 water that comes back out after it's used in the

12 drilling. You've already heard a little bit

13 about in some parts of the country where we have

14 disposal issues of how we dispose of that

15 contaminated water and if it ends up in a system

16 that's used to irrigate food, and organic isn't

17 exempt from this conflict.

18 It's not fair. But it's happening,

19 so, and consumers are starting to become aware of

20 it and they feel like it's one more thing that

21 they now have to ask, and organic is the place

22 they go to get more of those reassurances.
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1 So, we think it's time for organic to

2 really start talking about this. There's a

3 couple levels and ways that I think organic can

4 do that. 

5 One, on specifically on this

6 California produced water situation, organic

7 could be very clear and ask the Governor of

8 California to stop allowing this waste to be

9 disposed into systems that are used to irrigate

10 food crops. That practice could stop and then

11 you wouldn't have to have this conversation about

12 is it happening, is it not happening.

13 We support OFPA's mitigation plans to

14 help farmers protect themselves and we think that

15 as you talk about contaminated inputs, that water

16 should be a part of that conversation.

17 Bigger picture. We think that

18 organic, it's time for organic to really join a

19 really growing very loud, very you know, really

20 overdue movement to ban fracking, which can't be

21 done safely, and to really illustrate that our

22 food system is part of what's at stake.
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1 It's happening all over the country.

2 You won't have to do it by yourself. Three

3 states have banned fracking. Maryland just

4 signed a bill two weeks ago, three weeks ago, a

5 Republican Governor signed a bill in Maryland to

6 ban fracking because he said it couldn't be done

7 safely.

8 So, it's time for organic to join in

9 that conversation, to join in that fight and

10 really elevate what's at stake, which is the --

11 whether we have a healthy environment, where we

12 can grow the food people are looking for, so we

13 just urge you to join in that movement, because

14 there's lot of folks doing it. It's a good place

15 to be. 

16 CHAIR CHAPMAN: Thank you, Patty. Any

17 questions for Patty? All right. Emily, Harriet,

18 Scott and Dan and anyone on this side? No. Just

19 want to note, we're 30 minutes behind schedule. 

20 So, please try to keep it brief and the answers

21 relevant to the questions. Go, Emily.

22 MEMBER OAKLEY: Hi, Patty. Thank you,
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1 and I am from Oklahoma, which is a state that is

2 definitely experiencing these issues and know

3 farmers that have experienced these issues.

4 The CACS has been discussing this and

5 one thing that we're wanting help from

6 stakeholders with is identifying the link between

7 these issues with OFPA and the regulations, and

8 if you can help us identify how we can work

9 through the regulatory framework on this, that

10 would be very beneficial for us.

11 So, it's more of a comment or a

12 request, than a question at this point. 

13 MS. LOVERA: Sure. Happy to do that. 

14 Some of those were talking in the hall, already

15 this morning, about how do we start doing that,

16 and happy to come up with ideas to start that. 

17 CHAIR CHAPMAN: Thank you. Harriet? 

18 MEMBER OAKLEY: So, my understanding

19 is, and I know you're more of an expert in this

20 than I am, that fracking and the movement of gas

21 and oil is regulated state by state, and I know

22 that Minnesota, and every state had it
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1 differently.

2 So, I know Minnesota and Wisconsin,

3 and I know Minnesota has administrative law,

4 which has a mitigation plan that is law, that if

5 a pipeline is proposed, to even go through

6 organic land, they are requested or they're

7 supposed to look at an alternative to not even go

8 through the organic land, and I know that's a

9 part of -- OFPA has done that.

10 In Wisconsin, we don't have the same

11 type of system and it's -- but the gas and oil

12 companies have agreed voluntarily to do it.

13 So, I think the -- one of the issues

14 that I struggle with is, how can we, as a federal

15 advisory group make any influence on these state

16 by state regulations that really are the place?

17 I mean, what we want to do is have

18 them avoid the organic land to begin with, when

19 they're planning, but we can't -- you know, I

20 don't know how we can even make that

21 recommendation because it's a state by state

22 issue, my understanding. 
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1 MS. LOVERA: It's excessively

2 complicated, regulates pipelines, depends what's

3 going through the pipe. 

4 There is a federal rule. There's a lot

5 of state rule and it depends on the specifics of

6 the circumstances. But I think there is a

7 question too about whether the organic community

8 and that includes the NOP and the NOSB, can start

9 just putting this out there as part of the

10 conversation of what's at stake, and I think what

11 OFPA is doing to help land owners protect

12 themselves is important. 

13 If there's a way to get other

14 certifiers having that conversation, to share

15 that, so it's not state by state, people are

16 doing it in more of a unified way.

17 So, I'm happy to think through the

18 regulatory angles, but I think there's also a

19 communication bully pulpit angle that we're

20 asking for organic to step up to as well. 

21 CHAIR CHAPMAN: Scott and then Dan.

22 MEMBER RICE: Emily captured my
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1 points. We've just -- we've been addressing this

2 at the CACS level and would really love input on

3 how in our authority under the rule, that we

4 could best do that, and just you know, reiterate

5 to you and OFPA that this is -- we're hearing

6 this and we're hearing it loud and clear, and I

7 think I can speak for a number of us, we as

8 individuals care about this, but it's really just

9 struggling to, as a Board and how we can best

10 address in a way that is meaningful and have

11 impact. 

12 MS. LOVERA: Again, similar answer. 

13 I'm happy to stay in touch and think of ideas and

14 share them.

15 CHAIR CHAPMAN: Dan? 

16 MEMBER SEITZ: So, from what I've

17 read, there is no question that water that comes

18 out of a fracking operation is filled with all

19 sorts of noxious chemicals.

20 But we hear this distinction with

21 produced water and is that water also

22 contaminated? I'm just kind of curious about
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1 that. 

2 MS. LOVERA: Well, stunningly, there is

3 not a lot of people paid to look at that and

4 figure that out.

5 We have one study for one water

6 district in California that did testing one time,

7 and they found some chemical components higher

8 than drinking water levels.

9 A lot of these chemicals don't have

10 agricultural standards. They never got it dealt

11 with.

12 There is also a study, which can round

13 up and share with the Board, that came from UC

14 Berkeley that did find some chemical constituents

15 in the wastewater after it went through what the

16 water district said was sufficient treatment, and

17 that's about what we have. 

18 So, there is a lot of questions. This

19 is kind of a tailor made case for precaution. 

20 There is no need to dispose of this wastewater in

21 the system that's providing the water we grow our

22 food with, and the Governor of California could
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1 stop it. 

2 MEMBER SEITZ: And then just one other

3 question.

4 Just as we saw with the DARK Act that

5 when states starts doing progressive things

6 around regulation, there's sometimes an attempt

7 to preempt that on the federal level.

8 Is anything like that happening with

9 fracking on the federal level and do we need to

10 be just cognizant of that? 

11 MS. LOVERA: We always need to be

12 cognizant of that. Whenever people do something

13 progressive at the state level, we always need to

14 be aware. 

15 Lots of people are on patrol for that. 

16 There is a really active keep it in the ground

17 movement, talking about this, and so, they're

18 definitely on alert and I think we'll see other

19 states take this action and then we'll have to

20 stay alert to make sure that something -- there's

21 no shenanigans at the federal level.

22 That happens at the state level too,
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1 unfortunately. People in Colorado experienced

2 that. There are towns in Colorado that said you

3 can't do fracking in our city limits. The state

4 tried to preempt them and it's still ongoing as a

5 fight.

6 So, it happens at every level, which

7 is why we need the biggest movement we can, with

8 the most number of stakeholders to say this is an

9 unacceptable practice. 

10 CHAIR CHAPMAN: Thank you, Patty. Up

11 next, we have Abby Youngblood and on deck, we

12 have Charlotte from consumer reports.

13 Abby, for the record, can you state

14 your name and affiliation? 

15 MS. YOUNGBLOOD: Hi. I'm Abby

16 Youngblood with the National Organic Coalition.

17 Good afternoon. My name is Abby

18 Youngblood and I'm the executive director of the

19 National Organic Coalition, or NOC, and I want to

20 thank you NOSB members. Your work to create a

21 strong organic label continues to be essential,

22 especially as we head into a new administration.
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1 We believe that the success of the

2 organic label and organics role as an engine for

3 economic activity and job creation depends on

4 having clear and consistent standards, and we

5 look forward to partnering with you, to further

6 your efforts to maintain the integrity of the

7 organic label.

8 I want to start by drawing your

9 attention to the issue of peer review. This past

10 year, a panel was established to examine the

11 National Organic Program's accreditation

12 procedures.

13 This process known as peer review is

14 required by the organic law and regulations and

15 it's this independent evaluation of the NOP's

16 competence in carrying out its activities, as

17 part of what gives us the confidence in the

18 organic seal, and I want to urge the NOSB to

19 actively engage in this process, which is

20 foundational to organic integrity by taking a

21 close look at both the process that is being used

22 for peer review, as well as the results that came
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1 out of that 2016 report, and this is an area that

2 needs more work and the NOSB has a role to play

3 here. 

4 So, please see our more detailed

5 written comments on the subject of excluded

6 methods. 

7 A big thank you to the NOSB for the

8 excellent work done in Saint Louis by adopting

9 the proposal. You brought clarity to the organic

10 standards. There's still many to be determined

11 techniques. We support including four of these

12 in the list of excluded methods, this genesis,

13 intra-genesis, transposals and agro-infiltration.

14 We urge the NOSB to fully resolve the

15 other to be determined techniques after

16 additional vetting and debate. We urge the NOSB

17 to recommend a national pilot study to gather

18 data on the presence of GMO materials in seeds

19 and crops. Finding from this study could help

20 the NOSB and future discussions about the

21 presence of excluded methods and this discussion

22 on thresholds.
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1 On hydroponics, the National Organic

2 Coalition acknowledges that organic agriculture

3 is about more than just the inputs used. We

4 believe hydroponics advocates have muddied the

5 waters by claiming that soil ecology operates in

6 systems that use inert or recalcitrant materials

7 as a growing medium, and by describing these

8 systems as contain production rather than

9 hydroponics production.

10 These systems rely on outside liquid

11 fertility inputs for all or most of their

12 fertility needs and as such, these hydroponic

13 systems are inconsistent with organic principles.

14 Thank you, NOSB members for all that

15 you do. We greatly appreciate and value your

16 service to the organic community. 

17 CHAIR CHAPMAN: Thank you. Any

18 questions for Abby? 

19 All right, thank you, Abby. Charlotte

20 is up next. On deck is Rosemary Bilchak. Sorry

21 if I butchered that name. 

22 Just so you guys know, the agenda did
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1 have us breaking at 12:45. I'm going to run

2 until 1:00, as we're a half hour behind schedule. 

3 We'll break at 1:00 until 2:00 and start promptly

4 back at two.

5 Charlotte, can you start with your

6 name and affiliation for the record? 

7 MS. VALLAEYS: Sure. My name is

8 Charlotte Vallaeys and I'm a Senior Policy

9 Analyst with Consumer Reports.

10 First, I'd like to say welcome to the

11 new Board members, and thank all of you for your

12 time and commitment to this Board's important

13 work.

14 To start, I'd like to say a few words

15 about Consumer Reports.

16 We're an independent, non-profit

17 organization and we work side by side with

18 consumers to create a fair, safer and healthier

19 world.

20 For 80 years, Consumer Reports has

21 provided evidence-based product testing and

22 ratings, rigorous research, journalism, public
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1 education and policy action on behalf of

2 consumers.

3 We work in many areas, including

4 efforts to create a safe and sustainable food

5 system. In many ways, our vision for a safer and

6 more sustainable food system aligns with organic. 

7 We believe in the integrity of the label is worth

8 protecting and where warranted, its standards

9 should be improved.

10 Now, to the topics you are discussing

11 at this meeting.

12 Sodium phosphate should be removed

13 from the national list. A high intake of

14 phosphorus is associated with negative impacts on

15 bone, kidney and heart health. No single

16 phosphate food additive can be implicated as an

17 isolated risk factor. It is the widespread use

18 of phosphate food additives, like sodium

19 phosphate and their cumulative impact that raises

20 health concerns.

21 The prohibition on sodium phosphate

22 and other standards, including the EU and Japan,
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1 shows that it is not essential.

2 We urge you to reject the petition for

3 short DNA tracers, because they were created

4 using excluded methods and are not essential. We

5 are concerned with the process the Board uses to

6 review ancillary substances. We're especially

7 concerned with Kymene and vinyl chloride as

8 ancillary substances for cellulose. We ask that

9 you ensure that these materials do not end up in

10 organic foods.

11 Finally, I would like to share the

12 results of a consumer survey that we released

13 today.

14 When shopping for groceries, more than

15 a quarter of Americans say that they often or

16 always buy foods labeled organic. Among those

17 consumers, 86 percent say that it is very or

18 extremely important that the animals used to

19 produce organic foods are raised on farms with 

20 high standards for animal welfare.

21 We also asked specifically about

22 outdoor access for hens that lay eggs that are
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1 labeled organic, since so much of the controversy

2 around this new rule is around this issue.

3 Among organic consumers, 83 percent

4 say that it is highly important that eggs labeled

5 organic come from hens that were able to go

6 outside and move around freely. 

7 The USDA should make the organic

8 animal welfare rule effective right away. Please

9 do reach out to us if you have questions and

10 thank you for considering our comments, and

11 again, thank you for your work. 

12 CHAIR CHAPMAN: Thank you, Charlotte. 

13 Any questions for Charlotte? Harriet?

14 MEMBER OAKLEY: So, for sodium

15 phosphate, it is used many times in just

16 minuscule quantities, used in milk products, and

17 I'm just wondering if the dire health effects

18 are, you know, viewed in these minuscule

19 quantities that are used.

20 MS. VALLAEYS: Yes, so the studies

21 have shown that as food additives, that the

22 intake and the impact is different from
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1 phosphorus in whole foods and that the widespread

2 use at -- in the food supply, processed foods is

3 creating these health impacts for consumers.

4 So, if somebody is choosing only

5 organic thinking that that is a healthier safer

6 option, but it still has the sodium phosphate,

7 they could potentially if they only eat processed

8 foods, but it's organic, they could still have --

9 they could still reach those levels, where it

10 would have, according to the studies, negative

11 impacts.

12 Also, on sodium phosphate

13 specifically, mac and cheese for example, if you

14 go to the store, you can find two boxes of mac

15 and cheese both labeled organic, one has it, one

16 doesn't. 

17 So, I think when shoppers choose

18 organic, part of it is that they are avoiding

19 these kinds of additives, and it shows that it

20 can be done to make these products without them.

21 CHAIR CHAPMAN: Thank you. Any

22 additional questions?
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1 I also wanted to thank you for your

2 comments on L-methionine. I thought they were

3 well reasoned and well written and I know you're

4 no fan of synthetic vitamins and minerals. But I

5 hope the Boards reads those as well. Thank you

6 for that. 

7 MS. VALLAEYS: Yes, you're welcome.

8 CHAIR CHAPMAN: Seeing no other

9 questions, thank you Charlotte. 

10 Up next is Rosemary and following that

11 is Vanessa. Rosemary, if you could start with

12 your name and affiliation for the record. 

13 MS. BILCHAK: Rosemary Bilchak.

14 Hotchkiss, Colorado. We are -- we live five

15 hours west of Denver and we are OSGATA members.

16 My husband is registered pesticide

17 sensitive with the Colorado Department of

18 Agriculture on the advice of his oncologist for a

19 very rare form of Leukemia.

20 We are organic farmers, however, we

21 have been prevented from doing what we love

22 because of ongoing pesticide drift and a
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1 complicit Department of Agriculture.

2 USDA NOP accredits CDA, the Ag

3 Department to certify organic farmers in

4 Colorado. However, CDA has failed to protect our

5 right to farm organically.

6 Since 2010, our neighbor has been

7 contaminating our property with pesticides. He

8 uses a truck-mounted fogger, an industrial-sized

9 fogger that sends up ultra-low volume pesticides

10 that by design, travel hundreds or even thousands

11 of feet. This picture demonstrates what that

12 looks like.

13 Over the last six and a half years,

14 CDA has found toxic contamination of our property

15 multiple times, yet declares that such

16 contamination "does not constitute the use of

17 this pesticide in an unsafe manner".

18 Meanwhile, I have received notice from

19 the same CDA that we cannot be certified organic

20 because of this very same contamination. We find

21 ourselves in a double bind that denies us the

22 full use and development of our private property.
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1 CDA has not even responded to our

2 multiple requests to revoke the public health

3 applicators license from this individual. This

4 license that allows is travesty to continue.

5 This license is usually reserved for

6 trained public health officials, not for an

7 individual who has failed the test multiple

8 times, has violated the label multiple times, has

9 stated under oath that he would continue to

10 spray, even if the result of that spray was my

11 husband's death.

12 Has been found in contempt of court

13 for violating a permanent injunction order,

14 specifically crafted to limit his renegade

15 spraying and protect our farm, and has been sent

16 to jail and fined for this offense, yet this man

17 still has his license.

18 I am here today to tell you that we

19 are just one organic farm who has been impacted

20 by chemical trespass. Our region has the highest

21 concentration of small organic farms in the State

22 of Colorado, and that entire community, which is
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1 a significant economic driver in that rural area,

2 is at risk because CDA has failed to do its job.

3 Since CDA is accredited by USDA, we

4 want you to compel CDA to be responsible for the

5 protection of organic farmers. We plead with you

6 to help us find some justice, some way out of

7 this horrific catch-22, that allows continued

8 toxic pollution, yet denies us organic

9 certification as the result of that very same

10 contamination. 

11 CHAIR CHAPMAN: Thank you.

12 MS. BILCHAK: Thank you.

13 CHAIR CHAPMAN: Any questions for

14 Rosemary? Harriet and Emily. 

15 MEMBER OAKLEY: In the upper Midwest

16 where I live in Wisconsin, actually, the State of

17 Minnesota has a pretty big problem with pesticide

18 drift on the regulatory side, because the

19 Minnesota Supreme Court declared that even if

20 organic land was drifted upon, that crop could

21 still be sold as organic.

22 So, the farmer didn't lose
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1 certification, but the farmers actually don't

2 want to sell that crop as organic. They want the

3 NOP to have their backs.

4 So, I have been talking with the

5 program for a while to get some clarity there. 

6 The case did go to -- we tried to move it forward

7 and I was helping the farmer and the lawyer, to

8 try to move it forward to the Supreme Court of

9 the United States, and it went through two hoops,

10 but it didn't get through the third. So, it was

11 not reviewed.

12 So, right now, there's actually one

13 farmer who continually gets sprayed upon and then

14 continually -- the certifier does not de-certify

15 that land, and then he appeals to the NOP to have

16 his certification removed, which the NOP has

17 done. 

18 So, he is really in a catch-22, as

19 well. But this is a big issue. Many states does

20 have trespass laws that do cover pesticide drift. 

21 But since we are the great minority of

22 agricultural production, it seems like we don't
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1 get the protection that we deserve. So, I very

2 much sympathize with you. 

3 MS. BILCHAK: My understanding of that

4 case was that they did not -- they decided that

5 they needed to have damages, to be able to say

6 that is was trespass.

7 This case says and it's in the -- I

8 can give you the case number. It actually set

9 precedent nationwide that pesticide drift in and

10 of itself, without proof of damages is trespass,

11 and the court has stood behind that.

12 Now, it's only in one. It's in the 

13 Delta District Court in Colorado. But people

14 need to cite it and use that, but it has -- I

15 mean, the court has stood up and said you are in

16 contempt of court for his violation of that

17 order. 

18 CHAIR CHAPMAN: Thank you. I want to

19 remind members to keep the questions short, as we

20 are 30 minutes behind schedule. Emily? 

21 MEMBER OAKLEY: This was just a

22 question for Miles.
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1 Is there any avenue that she can

2 pursue with the NOP for this situation? 

3 MR. McEVOY: Yeah, I was going to make

4 a comment about pesticide drift. It is a very

5 complicated topic, and it's mostly -- it's kind

6 of like the -- the fracking and the oil and gas

7 thing. It's regulated more by the states than by

8 the Federal EPA.

9 EPA has some overarching regulations

10 about drift, but they're implemented by State

11 Departments of Agriculture, and there's different

12 legal precedence in different states.

13 I'm from Washington State and the

14 legal precedent we use there was strict

15 liability. So, if you can show damage, it was

16 relatively easy to receive compensation.

17 Oregon has in their Courts, determined

18 it was chemical trespass. So, again, it's

19 relatively easy there, whereas in my

20 understanding, California, you have to prove

21 negligence in order to recover damages.

22 So, it's a complicated multi --
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1 different state legal determinations about drift

2 and what's damage and how do you get compensated

3 for it.

4 In terms of the National Organic

5 Program, the regulations, if there's application

6 of a prohibited substance, even if it's coming

7 from drift, then the -- the crop cannot be

8 considered organic. It doesn't necessarily

9 affect certification, but that crop could not be

10 considered organic, and we're looking at this on

11 a case-by-case basis. We have looked at

12 potentially providing instruction or guidance,

13 but that's probably going to be very difficult,

14 and it's more likely that we'll just keep dealing

15 with it on a case-by-case basis. 

16 But if you could provide me with your

17 contact information, we can discuss more, whether

18 or not there's anything we can do. 

19 MS. BILCHAK: Okay, I have given the

20 two letters from the CDA for copies. Is that

21 sufficient or do you want more?

22 MR. McEVOY: Yeah, that will work. 
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1 Thank you.

2 MS. BILCHAK: Okay. 

3 CHAIR CHAPMAN: Thank you very much. 

4 Thank you for your testimony. 

5 Up next we have Vanessa, and then we

6 will be breaking for lunch. 

7 MS. CAMPUZANO: Hi. Thank you for

8 being compliant with my parking meter issues. 

9 Sure, all right. Hello. My name is 

10 Vanessa Campuzano and I'm an intern at Food and

11 Water Watch.

12 So, I am 19 years old, and I'm a

13 sophomore at the University of Colorado Denver.

14 There seems to be a stereotype

15 surrounding college students that they all eat

16 Ramen noodles or dining hall food and they're too

17 lazy or broke to eat healthy and cook for

18 themselves.

19 I however, put a lot of time and

20 conscious effort into cooking healthy meals and

21 using organic ingredients whenever I can.

22 It has come to my attention that these
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1 ingredients that I spent more money on may be

2 grown with oil and gas drilling water. 

3 While the wastewater is treated before

4 it is transported to water districts, testing has

5 shown the numerous chemicals can persist after

6 treatment.

7 An analysis conducted by UC Berkeley

8 researchers found that drillers who provide

9 wastewater for irrigation have reported using 173

10 different chemical constituents. Eight of these

11 chemicals are on California's Proposition 65

12 list, and 10 are known or suspected carcinogens.

13 This water then goes to agricultural

14 fields for conventional and organic farms.

15 The National Organic Standards Board

16 needs to address this issue. It won't go away on

17 its own and consumer confidence in organic food

18 is at risk. 

19 The Board should consider the impacts

20 of fracking and drilling wastewater as part of

21 the discussion on preventing contaminated inputs

22 in organic production.
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1 I urge you all to think about the

2 impacts fracking has, not only on our air, but

3 our water, food and health as well. Thank you.

4 CHAIR CHAPMAN: Thank you. Any

5 questions for Vanessa?

6 MS. CAMPUZANO: Have a good lunch.

7 CHAIR CHAPMAN: Thank you very much. 

8 So, we will be in recess for an hour and start

9 back promptly at 1:00 p.m.

10 First up when we start back is Lisa

11 Trope from Food and Water Watch. Thank you guys,

12 very much.

13 (Whereupon, the above-entitled matter

14 went off the record at 1:40 p.m. and resumed at

15 2:05 p.m.) 

16 CHAIR CHAPMAN: Okay, we're going to

17 get underway. It is 2:04, and we do have a

18 quorum of members back here.

19 Up first was Lisa Trope. Is Lisa

20 Trope here? And then after Lisa, we have Cheryl

21 Van Dyne on deck. Cheryl Van Dyne. 

22 Lisa, if you could start by stating
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1 your name and affiliations for the record. Thank

2 you. 

3 MS. TROPE: Sure. Lisa Trope with

4 Food and Water Watch.

5 Okay, so my name is Lisa. I am an

6 organizer here in Denver with Food and Water

7 Watch Colorado. We currently have over 55,000

8 supporters across the state, and Food and Water

9 Watch has been highly involved in communities to

10 fight the fracking industry, because of impacts

11 on health, homes and water.

12 Currently, unfortunately, here in

13 Colorado there are 52,000 active fracking wells

14 and counting, and we've worked with local

15 municipalities to pass bans and moratoriums on

16 fracking in five different communities around

17 Denver.

18 People are really fighting for their

19 livelihoods here, and they're not only worried

20 about health and their homes and water, but also

21 on impact that it's having on their food.

22 So, I know that Patty and a number of
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1 others spoke about wastewater. But I'm actually

2 going to speak a little bit about the impact that

3 the oil and gas industry is having here on

4 Colorado, and how we have to be keeping them in

5 mind when it comes to organic labeling.

6 To date, water usage, spills and air

7 pollution all are having an impact on our food

8 here in Colorado. It takes between one and eight

9 million gallons of water to frack one well, and

10 we have 52,000 wells here in Colorado. So that's

11 a huge amount of fresh water that's being used.

12 We're finding that farmers are having

13 to compete with frackers for that fresh water.

14 Secondly, in 2015 the oil and gas

15 industry reported that there was 615 spills in

16 Colorado. That's on average of two -- a little

17 less than two spills a day. Ninety of those

18 spills contaminated ground water.

19 I have worked with the Valley Organic

20 Growers Association in -- or near Paonia, a few

21 hours from here, and currently Paonia and that

22 valley is taking on a huge fracking site fight. 
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1 If we see the same kind of water usage

2 and possible spills in that area, it could be

3 completely catastrophic for those farms.

4 Finally, air pollution is a really big

5 issue. Fracking creates ozone level smog, and

6 that doesn't only cause health issues, but also

7 decrease in crop yields.

8 Denver was last year, ranked eighth

9 most polluted city in the country, and that was

10 because of increased population growth and oil

11 and gas development. Fort Collins, which is also

12 a hub for farms, is in the top 10 most polluted

13 cities in the country, and unfortunately, that

14 polluted air doesn't just stay in those areas.

15 So today I'm asking the National

16 Organic Standards Board to address the issue

17 because failing to talk about continues to put

18 consumers' confidence in your product at risk and

19 also the quality of the product itself.

20 The National Organic Standards Board

21 has spoken about publicly about the impacts of

22 GMO crops on their organic community, and we
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1 really are urging the Board to talk about the

2 impacts that organics -- or that fracking and oil

3 and gas development is having on organic farms. 

4 We need to take a stance away from the

5 oil and gas development towards clean energy that

6 is going to have the kind of harm that it's

7 currently having here in Colorado and across the

8 country on things such as organic food. 

9 CHAIR CHAPMAN: Thank you. 

10 MS. TROPE: Thanks for your time.

11 CHAIR CHAPMAN: Any questions? Thank

12 you for your comments.

13 MS. TROPE: Thank you.

14 CHAIR CHAPMAN: Up next, we have

15 Cheryl Van Dyne. Is Cheryl here? Is Jessica

16 Knutzon here or Wanda Jurlina?

17 All right, how about Wayde Jester? Is

18 Wayde Jester here? All right, we'll just keep

19 going down the list. Alan Lewis? Is Alan Lewis

20 here? 

21 All right, Alan, come on up, and after

22 Alan we have Martin Eddy from OFARM on deck. 
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1 Martin, if you could go to the on deck chair,

2 that's appreciated. 

3 Alan, when you get up here if you

4 could state your name and affiliation for the

5 record. 

6 MR. LEWIS: Thank you, Mr. Chair. 

7 Alan Lewis. I work with Natural Grocers.

8 As a reminder, Natural Grocers is a

9 62-year-old company, still family run, and we've

10 been certifying our producers for many decades,

11 and we very much welcome the Organic Foods

12 Production Act, I think when we were 35 or 40

13 years old.

14 At the moment, we have 140 stores in

15 20 states. All of our stores are certified

16 organic processors or handlers within a year of

17 opening. We also have a certificate for our food

18 processing in Golden, which is 110,000 square

19 feet.

20 My comments today to the Board have to

21 do with organic plus, and just a reminder that

22 grass-fed milk is now by consensus among the
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1 industry, 100 grass-fed. Grass-fed meat, based

2 on the American grass-fed standard is 100 percent

3 grass-fed, and we're putting pressure on the

4 organic standard where it hurts the most. It's

5 hard catch up, and so we're seeing these

6 additional certifications and seals accompanying

7 organic.

8 As was discussed quite a bit in the

9 last few days, the problem with contaminated

10 organic seed, organic plus seed would be seed

11 that isn't organic -- isn't contaminated with

12 genetically engineered organisms, and let's not

13 get started on the non-GMO project.

14 So more and more, we seem to be

15 mounting a defense of sub-standard standards,

16 even if the animal welfare rule actually gets put

17 into place, and we certainly understand the

18 technically difficulties and the attractions of

19 economies of scale.

20 But if the organic seal raises

21 skeptical and pointed questions instead of strong

22 consumer confidence, as other people have said,
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1 farmers will flee it. 

2 So let's be honest, we're not the only

3 game in town anymore. So we need to watch out

4 when we find ourselves explaining the need for

5 organic plus.

6 So, hydroponics is one of these sub7 standard standards. Consumer trust drives our

8 grocery business. We remain staunch for

9 supporters and defenders of the National Organic

10 Program, but on behalf of our customers who can't

11 participate in or endorse the torturous

12 justifications being used to make the claim that

13 soil-free and sunlight-free growing is really,

14 you know, organic. Look ma, no pesticides.

15 Hydroponics can be a very fine, safe,

16 nutritious system with which to grow food, but it

17 has a bright future. We're told earlier, it will

18 grow 40 percent quickly. Great. But it's not

19 organic to the consumer.

20 I'd like everyone here to visit the

21 Colfax Store, just a 15 minute walk. Some of

22 there you were there yesterday for the NOC lunch. 
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1 Check out our 100 percent organic produce

2 section, and take special note of how few

3 remaining hydroponic items there are that we are

4 allowing to sell for now and how they're being

5 properly called out for our consumers as

6 hydroponic organic. 

7 CHAIR CHAPMAN: Thank you. 

8 MR. LEWIS: Welcome to the era of --

9 CHAIR CHAPMAN: Thank you, Alan.

10 MR. LEWIS: -- organic minus, and if

11 that doesn't break your heart, nothing will. 

12 Thank you.

13 CHAIR CHAPMAN: Thank you, Alan. Any

14 questions for Alan?

15 Seeing none, thank you very much for

16 your testimony.

17 Up next is Martin Eddy followed by

18 Cheryl Van Dyne. Cheryl can go to the on deck

19 chair, and Martin, if you can start with your

20 name and affiliation for the record. 

21 MR. EDDY: Howdy. I'm Martin Eddy. 

22 I work for Kansas Organic Producers. We're
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1 affiliated with OFARM, which is seven organic

2 farming marketing co-ops, and so that's what

3 we're working with.

4 I was really heartened by the listing

5 of the fraudulent certifications. Those came out

6 in the last couple days. Part of the issue it

7 got with the organic certification, of course,

8 it's a blended standard of marketing and

9 production standards, which leads to dissonance

10 sometimes. 

11 Going back on that, I'd like to know

12 the -- so, what happened with us is that prices

13 were going down. Farmers kept asking us, why is

14 that? Why is that? I thought, well, let's find

15 out. Let's educate ourselves instead of just

16 being pissed off.

17 So basically, where a lot of the roads

18 led us to was the ECHO, as you know, importing --

19 being a certifier from Turkey and exporting of

20 grain from Turkey and the Ukraine. It's been de21 certified by Europe, as you know, and Canada.

22 So was a year ago, April 6th, entered
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1 into an agreement. NOP tried to de-cert them,

2 and that didn't work too well. So, we had an

3 agreement.

4 Twelve months after April 6th, we're

5 supposed to have an onsite inspection. I wanted

6 to know what the status of that is, if it

7 actually happened.

8 There is no provision in the agreement

9 that if that inspection doesn't happen, for them

10 to continue to be certified in the United States.

11 So it seems like the crux of the

12 matter seems to be CFR 205.101 and then the sub13 section that takes us to .272. The co-mingling

14 must implement measures to prevent co-mingling. 

15 I'd like to know more about that.

16 The big thing that we really noticed

17 is when the bulk ships have been coming in now,

18 that's a 450,000 bushel of grain. That's what my

19 co-op produces in a good year, one ship. That's

20 like, do the math, that's about 3,000 acres of

21 organic production that was just kind of thrown

22 under the bus right there.
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1 So I'm wanting to know, I'd like to

2 see a clean-down log for something of that size. 

3 It's like a small factory, and the thing that

4 we've been noticing is that you can trace these

5 ships quite easily on the net. They come in,

6 it's organic certified, then they load with

7 conventional grain and go right out.

8 That makes me wonder, how much does it

9 cost to clean those down, and how complete are

10 they doing, you know? When we work with truck

11 loads and that sort of thing, we're very careful

12 about that, and it's an expense.

13 Okay, well, we can just move passed

14 that little piece. 

15 Then on the last page, I was wondering

16 if the NOP is going to harmonize with the EU on

17 the residue testing machine, how -- what the

18 status of that is. Got 23 seconds here.

19 Then I'm also -- started going through

20 the tracing system that the EU is implementing,

21 going digital. I was wondering if NOP is

22 considering, or USDA is considering any kind of
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1 similar thing, and that's implement that myself

2 in that right now. 

3 So that's it. Golly. I got it with

4 four seconds to go. All right. 

5 CHAIR CHAPMAN: Thank you very much,

6 Martin. 

7 MR. EDDY: Oh, we got more than that. 

8 I could -- but -- any questions? 

9 CHAIR CHAPMAN: Harriet?

10 MEMBER OAKLEY: So one thing that's

11 been nagging my mind here is with the imports,

12 the issue with the imports --

13 MR. EDDY: Right.

14 MEMBER OAKLEY: -- if the imports all

15 went away, could we feed all the organic

16 livestock in the United States from North

17 American sources, Canadian and the U.S.?

18 MR. EDDY: And of course, the answer

19 to that is no, and so, that's why this is so

20 tricky, and part that comes with that question

21 is, we fully -- that's why the co-mingling thing

22 is so important.
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1 We have satisfied ourselves, just from

2 the research and people we've talked to, there

3 are really good organic, certified organic

4 farmers worldwide. We have no quarrel with that.

5 But it seems to be the chain of

6 custody, I think that's been mentioned, from the

7 farm to the bulk ship, somewhere in there, or

8 from the farm to the -- when it ends at the Port

9 of Indiana and Michigan or whatever, there is a -

10 - that's a really problematic area, and we

11 suspect -- I mean, I'm not -- there's been co12 mingling with the gray grain or whatever.

13 That's why residue testing might be

14 useful. But just -- and also the certification

15 of importers and handlers. That whole little

16 2.272 thing, to me, seems to be the crux of the

17 whole deal, and I think there's been talk about

18 modifying that.

19 That's real tricky. I'm not saying you

20 have an easy job here. 

21 MEMBER OAKLEY: So, you're not saying

22 to get rid of imports --
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1 MR. EDDY: Oh, absolutely --

2 MEMBER OAKLEY: But you just -- 

3 MR. EDDY: To answer your question --

4 MEMBER OAKLEY: But --

5 MR. EDDY: -- no but --

6 MEMBER OAKLEY: But the imports should

7 have the integrity --

8 MR. EDDY: Yes.

9 MEMBER OAKLEY: -- that the domestic

10 has.

11 MR. EDDY: Yes.

12 MEMBER OAKLEY: Okay. 

13 MR. EDDY: And then we're also taking

14 steps to -- we have -- we're holding a series of

15 beginning organic farmer meetings and so forth. 

16 We had one in Western Kansas. We'll have one in

17 Eastern Kansas. 

18 But we're really working towards

19 growing more -- because the thing is, the plants

20 I feel -- maybe I'm being a little odd here, but

21 once something called organic agriculture or that

22 looks like more biological agriculture, that's
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1 the direction we need to go, because conventional

2 farming -- I talked to conventional farmers, and

3 they're quite clear. They're in a little box and

4 it's dying. You know, and so we need to help them

5 get out of that.

6 CHAIR CHAPMAN: Thank you. 

7 MR. EDDY: Any other questions?

8 CHAIR CHAPMAN: Thank you. Any other

9 questions? Thank you, Martin. 

10 MR. EDDY: Great. Thank you.

11 CHAIR CHAPMAN: Up next is Cheryl and

12 after Cheryl is Jessica Knutzon. If you can go

13 to the on deck seat. Cheryl, if you could start

14 with your name and affiliation for the record. 

15 MS. VAN DYNE: Hello. My name is 

16 Cheryl Van Dyne. I am speaking on behalf of the 

17 International Pectin Producer's Association. I

18 am the Global Director of Regulatory Affairs for

19 CP Kelco. Did I turn it off? I did this last

20 time.

21 IPPA, which is the International

22 Pectin Producer's Association, supports re-
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1 listing of pectin non-amidated forms only to 7

2 CFR 205.606.

3 The International Pectin Producer's

4 Association is a global association of companies

5 that manufacture pectin, and together IPPA

6 produces over 95 percent of all pectins worldwide

7 in commercial volume.

8 So commercial pectins are obtained by

9 extraction of selected, suitable, edible

10 vegetable raw material, and pectin is naturally

11 present in all land plants, but especially

12 abundant in fruits.

13 The principle raw material containing

14 pectin is in a form that's suitable for

15 commercial production of products with useful

16 gelling and stabilizing properties are pectin --

17 I'm sorry, are citrus fruit peel, lemon, lime and

18 orange or apple pomace.

19 The raw materials used in pectin

20 production are all byproducts of industrial juice

21 production or citrus oil production. Thus,

22 pectin products are converted from byproducts
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1 into high-quality specialty ingredients.

2 Specific, desirable, function

3 properties of the pectin produced, especially the

4 gel formation and the stabilizing features are

5 controlled through selection of proper raw

6 materials and by observing specific suitable

7 extraction and processing conditions.

8 So at this time, no member of IPPA

9 produces an organic certified pectin, and it is

10 to the best of IPPA's knowledge that there --

11 organic is not available globally in today's

12 market.

13 Members of IPPA concurrently still

14 support the fact that all -- that at present,

15 organically produced raw materials are neither

16 available in a quantity nor in a quality that

17 could be the basis for substantial industrial

18 production of commercial organic pectin products.

19 To the best of IPPA's knowledge, this

20 situation is not likely to change for several

21 years, and as such, organic pectin will not be

22 commercially available in the near future.
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1 I'm willing to take questions and my

2 team, as well, if you have questions about

3 pectin.

4 CHAIR CHAPMAN: Harriet?

5 MEMBER OAKLEY: What is the barrier to

6 producing pectin organically? 

7 MS. VAN DYNE: I'm sorry?

8 MEMBER OAKLEY: What is the barrier to

9 producing pectin organically? 

10 MS. VAN DYNE: There are no suitable

11 raw materials available at this time.

12 What happens is the juice or oil

13 production, where the juices and oils are

14 extracted, the waste peel goes into co-mingled.

15 So, they're just not segregated as

16 organic, and there is just not enough of it to

17 make organic pectin available.

18 CHAIR CHAPMAN: Any additional

19 questions? Thank you very much.

20 Up next is Jessica, and following

21 Jessica is Wanda Jurlina. Jessica, if you could

22 start with your name and affiliation for the
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1 record. 

2 MS. KNUTZON: Sure. I'm Jessica

3 Knutzon. I'm a Marketing Specialist at CP Kelco,

4 and before I start, I recommend that you not ask

5 me questions because Wanda is coming up next and

6 she's our pectin expert. So. 

7 CHAIR CHAPMAN: Please speak into the

8 mic.

9 MS. KNUTZON: Okay, is that better? 

10 Okay, so, why pectin? Let me see here.

11 Pectin provides a unique texture and

12 viscosity. The gel textures themselves are also

13 unique, vary from soft and spreadable and to firm

14 and cuttable.

15 It is a hydrocolloid that protects

16 proteins, ensuring that proteins remain intact

17 with a smooth mouth feel. It is the only

18 ingredient on the NOSB list that provides this

19 property.

20 It is a clean label, allergen-free

21 option that emulsifies and aerates, while

22 enhancing stability and shelf life.
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1 Many ingredients are not able to

2 perform in an acid environment, making pectin a

3 unique solution for products that fall within an

4 acidic PH range.

5 Typical products that contain pectin

6 are jams, jellies and spreads; bakery fillings

7 and glazes; yogurt, white mass and fruit;

8 beverages; flavor emulsions and dressings; and

9 gelatin-free confectionary products and fruit

10 snacks.

11 My colleague Shannon will go over this

12 later today as well, but there are plenty of

13 products, including jams, jellies, and preserves

14 that require pectin under the standard of

15 identity. Other products that use it as well

16 within this category are spreads.

17 So squeezable all-fruit products,

18 reduced sugar products and no sugar added

19 products that typically require pectin in order

20 to work correctly.

21 Pectin provides a gel-like structure

22 in these products. It also controls water, so
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1 the structure of these products stay intact. 

2 Pectin also suspends fruit and marmalade

3 products, which you may be able to see in this

4 photo here of yellow marmalade.

5 Within beverages, typical products

6 include the reduced sugar fruit products that we

7 now see as a trend. Consumers want the full

8 sugar texture and flavor but with the low sugar

9 actually in the product, and pectin helps deliver

10 that with smooth mouth feel stability and

11 maintaining within the acidic systems.

12 Here you can see an -- it's an 

13 orange smoothie beverage, and on the right side

14 is the control. So, there isn't a pectin in

15 this, and all the protein settles at the bottom. 

16 It becomes sandy and gritty, and it's not

17 pleasurable to be drinking this.

18 So if you put in pectin on the left,

19 you see everything stays suspended within the

20 beverage.

21 With yogurt mass, it provides

22 viscosity and texture. It controls water and whey
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1 off. The fruit, same with the yogurt fruit prep

2 as well and for -- it helps you keep everything

3 separated within the container, both for the

4 consumer and the manufacturer. This is a

5 benefit.

6 Typical products within this category

7 within confectionary products are fruit leathers,

8 gummies and gummy vitamins. It is one of the

9 only products that provides a vegan solution for

10 those who do not want to use gelatin in their

11 gummies, and the texture of these products go

12 from easy-to-chew to texture -- easy-to-chew

13 texture that goes from soft to firm. So you get

14 everything in between that you need, and that's

15 it. 

16 CHAIR CHAPMAN: Thank you. Any

17 questions? Thank you very much.

18 Up next is Wanda, and on deck is Wayde

19 Jester, if Wayde is here. If Wayde Jester is not

20 here, we'll be going to Max Goldberg.

21 Jessica, if you could start with your

22 name and affiliation for the record.
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1 MS. JURLINA: Yes. My name is Wanda

2 Jurlina. I'm the technical service manager for

3 CP Kelco. 

4 I spent my entire career working with

5 ingredients that thicken in gel water, and mostly

6 in food applications, but also in some non-food

7 applications, as well.

8 So what I've got for you today is to

9 address the essentiality of pectin for people who

10 are making products in the organic category.

11 So I've gone through, and I've pulled

12 out some information to start with on some of the

13 other ingredients that are approved for use in

14 organic applications, on either List 605 or 606,

15 so that you have a comparison of some of the

16 properties of these ingredients.

17 Jessica has introduced you to some of

18 the functionalities of pectin itself, but there

19 are many reasons that folks use these ingredients

20 in different products, and these are just a

21 couple that I'd like to touch on.

22 So we're talking about a category of
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1 ingredients where some of them actually provide

2 gel structure. Others actually just provide

3 thickening or viscosity. 

4 We've got some ingredients in this

5 category that can actually stabilize proteins at

6 low PH, when they go through heat treatment, so

7 that you have a stable, safe to consume beverage. 

8 We have other products that are used just to

9 enhance the mouth feel in beverage applications,

10 and we've got ingredients that are both acid

11 stable and not acid stable.

12 So, I put a comparison here together

13 for you comparing pectin to carrageenan, which

14 the Board voted at the last meeting to remove

15 from the list, as well as locust bean gum and

16 guar.

17 You'll see when we're looking at the

18 products or the properties of pectin compared to

19 the competition, it has a very unique set of

20 properties that allow for its use in systems

21 where we can't use these other ingredients that

22 are listed as suitable for use in organic
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1 products.

2 The second list I've put together for

3 you will be better in the public record than it

4 is here on the screen, because it is tiny, but we

5 tried to address all of the different

6 hydrocolloids or gums that are on the list and

7 how they compare in different applications.

8 When I've spoken to the Board in the

9 past before, I've shared with you that each one

10 of these ingredients have an incredibly unique

11 set of properties that dictates their use in

12 particular systems.

13 With pectin, it is unmatched in low PH

14 systems where it's providing either a gel

15 structure or just controlling the texture and the

16 product. 

17 So things like jams, jellies and

18 spreads which there are regulations mandating its

19 use, the things like yogurt fruit preps for

20 organic yogurt products, where there is really

21 nothing that matches the flavor release and the

22 texture that it brings to those products.
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1 As Jessica mentioned, I'd be happy to

2 answer any questions you have. 

3 CHAIR CHAPMAN: Thank you. Dan?

4 MS. JURLINA: Yes?

5 MEMBER SEITZ: So on your website, you

6 list sugar beet pulp as a major source for your

7 pectin, and do you source that free of GMO sugar

8 beets, because that's -- 

9 MS. JURLINA: That's a great question,

10 yes.

11 So, the sugar beet pulp that we source

12 for one specific type of pectin, and that is a

13 non-gelling grade of pectin, that is grown in

14 Europe. It is a non-GM sugar beet that is used. 

15 We don't actually process any pectins in the U.S.

16 where the GM sugar beets are grown. So that is

17 all coming out of Europe. So it is non-GM. 

18 CHAIR CHAPMAN: Steve?

19 MEMBER ELA: I'm curious, you -- over

20 here. Your colleague listed the low sugar, you

21 know, consumers wanting low sugar products and my

22 understanding that at least on the national list
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1 right now, it's the non-amidated pectins that

2 we're allowing.

3 MS. JURLINA: Right.

4 MEMBER ELA: But my understanding is

5 the low sugar products actually have to use the

6 amidated forms. Are there any alternatives for

7 those low sugar products? 

8 MS. JURLINA: There's basically two

9 categories of low-methoxyl pectins. There are

10 the amidated pectins, and there are my low11 methoxyl conventional pectins. 

12 Historically, folks liked working with

13 the amidated pectins because they're a little bit

14 easier to work with, but there are families of

15 low-methoxyl conventional pectins that are not

16 admidated and are suitable for use in low solid

17 systems. So, there is products out there?

18 MEMBER ELA: Okay, and so would those

19 fall under the current listing for pectin? 

20 MS. JURLINA: Yes. They would be

21 suitable for use in organic products. 

22 CHAIR CHAPMAN: Any additional
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1 questions? Thank you very much. 

2 MS. JURLINA: Thank you. 

3 CHAIR CHAPMAN: Is Wayde Jester here? 

4 Going once. Going twice. Max, you are up, and

5 on deck is Jim Gerritsen. 

6 Max, if you could start with your name

7 and affiliation for the record. 

8 MR. GOLDBERG: Sure. My name is Max

9 Goldberg. I am the founder of Organic Insider

10 and a founder of Living Maxwell, an organic food

11 blog.

12 Thank you to the NOSB. Being on the

13 NOSB is a tremendous amount of work, and I

14 greatly appreciate your efforts.

15 There is two things I wanted to

16 discuss today. One is hydroponics.

17 While there is tremendous merit in

18 hydroponics, it is absolutely not organic. The

19 organic food production act of 1990 requires

20 maintaining and improving soil fertility as the

21 foundation of organic agriculture. If that is

22 the case, I don't know why there is any
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1 discussion about hydroponics or any container

2 growing system being organic, and those

3 hydroponics or container growing systems adding

4 to soil fertility is a major, major stretch.

5 As being on the NOSB, it's a

6 tremendous responsibility, and you have the

7 future of organic in your hands. With

8 hydroponics, with soil, we are talking about the

9 absolute basis of organic, and the fact that it

10 is being deliberated is putting the future of

11 organic in jeopardy. So that's number one.

12 The second point I wanted to bring up

13 was glyphosate. In the NOP Handbook Section

14 2611-1, dated July 22nd, 2011, the prohibited

15 pesticides for NOP residue testing, which organic

16 certifiers are supposed to test a minimum of five

17 percent of their certified operations on an

18 annual basis, it lists all of the prohibited

19 chemicals such as DDT, chlorpyrifos, atrazine,

20 naled and many, many other chemicals. Glyphosate

21 is not on that list, and as you know, California

22 just listed glyphosate as a cause of cancer. 
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1 It's the world's must ubiquitous chemical. The

2 World Health Organization said it is a probable

3 human carcinogen, and I urge the NOSB -- I'd like

4 to know why it's not on that list, and I'd like

5 to urge the NOSB to try to get it on that list.

6 CHAIR CHAPMAN: Thank you very much. 

7 Any questions for Max?

8 MR. GOLDBERG: Does the NOSB have no

9 comment about why it's not on the list?

10 CHAIR CHAPMAN: Asa, do you have a

11 question? 

12 MEMBER BRADMAN: Well, it's a question

13 -- a comment.

14 I do know one thing that glyphosate is

15 very difficult to measure in environmental

16 samples at low levels, and there are a number of

17 laboratories that are currently developing

18 methods, some of which are reliable and some not,

19 and one thing is that I think the technology,

20 even in the next few years, is going to change.

21 I don't know if historically that's an

22 issue, but it could be part of it. 
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1 MR. GOLDBERG: Well, I know right now

2 there's a glyphosate residue certification

3 program in effect right now.

4 So this is something that I urge the

5 NOSB to really push, because we've already --

6 it's what's been tested. Reports that have come

7 put done by the Detox Project and Food 

8 Democracy Now is showing that there are organic

9 products contaminated with glyphosate, and I

10 would urge the NOSB to really push on this. 

11 CHAIR CHAPMAN: Thank you, Max. Any

12 other questions? Yes, Miles has a comment.

13 MR. McEVOY: Yes, we put together that

14 list of substances that can be tested under the

15 residue testing rule that went into effect in

16 2012, 2013.

17 So prior to that time, residue testing

18 was done by certifiers when they suspected that

19 there was a problem, and after 2012, it was

20 required that certifiers do -- at least five

21 percent of the operations that they certify, that

22 they test them for residues.
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1 We didn't specify what they would test

2 for, and they can, and we do tell them, that they

3 can test for whatever they think is the most

4 likely thing that they may be able to find.

5 So they can test for GMOs. They can

6 test for antibiotics in dairy production. They

7 can test for glyphosate. 

8 The list of those -- those listed of

9 chemicals is a fairly standard process to do a

10 multi-residue test where you can check a lot of

11 different chemicals at the same time in the -- in

12 various classes of pesticides, and it does not

13 include glyphosate. But there's nothing that

14 prevents a certifier for testing for glyphosate

15 if they choose to do that with the resources that

16 they have.

17 MR. GOLDBERG: Okay, all right. Thank

18 you.

19 CHAIR CHAPMAN: Thank you very much. 

20 Scott has one more. Max, we have one more

21 question. 

22 MEMBER RICE: I would just add one
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1 more comment from a certifier working with a lab.

2 Our lab has come to us proactively and

3 said, hey, you know, we're interested in or have

4 some ideas about expanding or fine-tuning this

5 list, whether it's not seeing a particular

6 chemical that is very present or relevant in the

7 crops that we see, or expanding it to things that

8 they think would be more likely to come up.

9 But again, the glyphosate in our

10 experience and from what we understand from the

11 lab is very difficult to test for.

12 MR. GOLDBERG: Thank you.

13 CHAIR CHAPMAN: Thank you. Up next is

14 Jim Gerritsen followed by Janel Ralph on deck.

15 Jim, if you could start with your name

16 and affiliation. 

17 MR. GERRITSEN: I'm Jim Gerritsen. I'm

18 a farmer. Our family has a 60-acre seed farm in

19 northern Maine. We've been certified organic by

20 MOFGA for 35 years.

21 During that time, I served for 25

22 years as a volunteer on the MOFGA certification
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1 committee. So I'd like to stress my gratitude

2 for all the work that the members of the Board

3 put in. I'm one of those that understands what

4 kind of sacrifice that you're making for the good

5 of the organic community, and it's appreciated.

6 So in addition to farming, I'm also

7 president of the national membership trade

8 association called OSGATA, and that stands for 

9 Organic Seed Growers and Trade Association.

10 So I've got -- can you circulate that

11 around? I gave you a stack of papers. Can you

12 circulate them?

13 So I've got two pieces of paper here

14 that I want to refer to. One talks about the

15 issue of seed purity, and I want to make two

16 points.

17 One, we've come up with a definition

18 of organic plant breeding, which is by design,

19 lay language for farmers and consumers, and the

20 most important phase within that, if there is

21 ever any confusion as to whether a material is

22 genetically engineered or not, we feel that the
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1 basic concept is if there is manipulation at a

2 sub-cellular level, that's genetic engineering. 

3 Monsanto and their allies can come up with

4 interesting descriptions, but the bottom line is,

5 if there is sub-cellular manipulation, that does

6 not fit organic.

7 The other thing which I want to point

8 out, which we have pointed out to previous NOSB

9 meetings in the past, is that our organization,

10 comprised of certified organic farmers, certified

11 organic seed companies, accredited certifying

12 agencies, and organizations and individuals that

13 support the growth of organic seed, we have put

14 this issue out to our membership, and we with

15 consensus, came up with a standard that as far as

16 we're concerned, organic seed should be only

17 viewed as organic if it is free of genetic

18 content.

19 The second page I want to make

20 reference to, and that's that the idea of soil as

21 being the foundation of organic farming. If you

22 don't have soil, you're not organic. So
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1 hydroponic needs to come up with their own

2 program, and it should not be part of the organic

3 system. It doesn't meet the requirements in the

4 Organic Foods Production Act, nor in the federal

5 rule. Happy to take any questions. 

6 CHAIR CHAPMAN: Thank you, Jim. Do we

7 have any questions? Thank you, Jim. 

8 Up next I have Janel, and on deck is

9 Demetria Stephens. 

10 Janel, if you could start with your

11 name and affiliation for the record. 

12 MS. RALPH: My name is Janel Ralph,

13 and I am the president and CEO of Palmetto

14 Synergistic Research. We produce a line of hemp

15 products, therapeutic hemp products. 

16 First, I would like to thank everyone

17 at the USDA who has taken the time to commit to

18 exploring the opportunities that industrial hemp

19 has to offer.

20 I would like to start by telling you

21 a little about myself and how I got into the hemp

22 industry.
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1 I produce a line of products made from

2 the hemp plant known as Palmetto Harmony. These

3 products are high in cannabidiol and are used by

4 medically complicated individuals, including my

5 youngest daughter, Harmony. 

6 This is why I feel that properly

7 certified organic hemp is not only a necessity,

8 but in my business, should be a requirement.

9 My youngest daughter Harmony was born

10 with a rare genetic condition called

11 lissencephaly, otherwise known as smooth brain. 

12 She began having seizures at six months old, and

13 within a few years, was having hundreds of

14 seizures a day. Her medical team had all but

15 given up on her. After six failed anti-epileptic

16 drugs including three 30-day courses of twice a

17 day steroid injections, we were sent home on

18 hospice and told she was out of options.

19 That's when we exploring cannabidiol

20 produced from the hemp plant.

21 For those that don't know, cannabidiol

22 is the predominant compound in the hemp plant. 
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1 It is non-psychoactive, and has been proven to

2 have zero health risks. It works as a powerful

3 anti-inflammatory and neuro-protectant, and in my

4 child's case, was what she needed to help curb

5 her seizures to the point that she is now living

6 a manageable life.

7 The problem I ran into and why I

8 ultimately decided to start producing Palmetto

9 Harmony was because I was not able to find truly

10 organic products. 

11 Most of the cannabidiol products on

12 the market are riddled with pesticides,

13 chemicals, even mold, and parents like myself and

14 sick people deserve to choose a better product

15 that has the USDA organic stamp of approval. 

16 This way we know what we are getting and

17 consuming. 

18 The problem is that while Palmetto

19 Harmony products are grown under the definition

20 of hemp in the Federal Farm Bill, the USDA signed

21 onto the statement of principles on industrial

22 hemp, which provided a contrary definition of the
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1 plant, and the NOP is basing its instruction on

2 certifying hemp organic as articulated in the

3 statement of principles on industrial hemp. 

4 Which is disturbing to think that my company,

5 even though we grow and process under stricter

6 guidelines than required by the USDA for organic,

7 even though we send every batch off to be ISO

8 certified and lab tested for heavy metals,

9 pesticides, herbicides, microbials, molds, and

10 residual solvents, we still would not qualify

11 under the outdated definition of hemp that the

12 USDA interpreted in the statement of principles.

13 What would hemp processors have

14 difficulty -- would hemp processors have

15 difficulty becoming USDA organic certified based

16 on this interpretation? 

17 I feel that these important issues

18 need to be brought to your attention today. Some

19 of the most important hemp products that truly

20 need to be stamped organic certified will not be

21 able to attain this sought after certification,

22 and why I am speaking to you today, I feel that
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1 properly certified organic hemp in my industry is

2 not a necessity, but in my business, should be

3 mandatory.

4 In my assessment, the only people that

5 this will damage are the medically fragile who

6 are just wanting to have a naturally organic

7 substance they can trust to consume.

8 I beg you to please look at these

9 issues and adjust them accordingly. The ability

10 to purchase a USDA organic certified cannabidiol

11 hemp oil as a health and wellness supplement was

12 not available to me, but I'd like to make it

13 available to others. I thank you for your time,

14 and I hope one day that Palmetto Harmony line of

15 products will proudly be stamped USDA organic

16 certified. 

17 CHAIR CHAPMAN: Thank you. Questions?

18 I have Dan. 

19 MEMBER SEITZ: This is a question for

20 Miles, just as -- for my understanding.

21 Where does USDA certification come

22 into play with health and wellness products as
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1 opposed to food products?

2 MR. McEVOY: Well, under the USDA

3 organic regulations, it refers to agricultural

4 products. So anything that could be considered

5 an agricultural product could be certified

6 organic.

7 So that would include some health and

8 wellness products. So for instance, a massage

9 oil made out of natural oils from almonds or

10 olives could be certified organic, because it's

11 agricultural ingredients.

12 So does that answer your question?

13 MEMBER SEITZ: Yes, and then just one

14 other question for clarification, and I think

15 it's apropos on the eve of the 4/20 celebration.

16 Where do federal regulations around

17 hemp come in to play with say a product like this

18 being considered by the NOSB? 

19 MS. RALPH: Well, my product is grown

20 compliant under the Federal Farm Bill of 2014. 

21 We grow in Kentucky under the KDA's federally

22 sanctioned program. So it is a legal hemp
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1 product, just like any hemp product that you

2 import from out of states -- overseas, but we

3 only grow in the United States. We don't import

4 anything.

5 Also, to answer your question, it's

6 very much an essential oil. It's just an

7 essential oil that stems from the hemp plant.

8 CHAIR CHAPMAN: So, we have Harriet

9 next and then Miles.

10 MEMBER OAKLEY: I know they do

11 industrial hemp in Canada. Do you know if they

12 have any organic industrial hemp up there that

13 you can use as the base for your products? 

14 MS. RALPH: Okay, so, Canada does

15 import a lot of hemp. But I'm more of the mind

16 set to support hemp industry in the United

17 States. That's why I choose to purchase all my

18 products, and we do grow with very high

19 standards, probably higher than the USDA requires

20 for organic production.

21 I do believe that Canada does have a

22 division of organically certifying hemp. 
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1 CHAIR CHAPMAN: Miles.

2 MR. McEVOY: Yeah, the hemp topic is

3 complicated and has a lot of different agencies

4 that are involved in that.

5 So I would encourage you to write to

6 the new administration with your request, because

7 I think it's really important that they

8 understand what it is that you are trying to do. 

9 I think there is a lot of merit, in

10 terms of what you're trying to get into certified

11 organic and that you have to bring it them and

12 explain it to them. I would write to like the new

13 administrator at AMS, in terms of a contact

14 person, and then we can try to work it through

15 the system, the clearance process, work with the

16 Department of Justice, because they have a lot to

17 say about hemp products. 

18 MS. RALPH: Well, I know currently, I

19 think the definition that you guys have for hemp

20 is anything that's used for industrial purposes. 

21 You will certify organic. We're just asking you

22 to certify the whole plant organic, all parts of
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1 it. 

2 MR. McEVOY: Great. Yes, write to us,

3 and we'll see what we can do. 

4 MS. RALPH: Okay, great. Thank you. 

5 CHAIR CHAPMAN: Thank you very much. 

6 Up next we have Demetria Stephens, followed by

7 Jenny Cruse. Jenny, if you could go to the on

8 deck. Demetria, if you can start by stating your

9 name and affiliation for the record. 

10 MS. STEPHENS: So, I am Demetria

11 Stephens. I am from near Jennings on a farm

12 called Stephens Land & Cattle. I'm also

13 affiliated with Organic Seed Growers and Trade

14 Association, and I guess various other

15 organizations, but I'm speaking on behalf of

16 myself, as a fifth generation farmer today.

17 My family has been farming in 

18 Northwest Kansas, north of I-70 since the 1800s. 

19 It's about a five hour drive, and if you drive

20 along I-70 east of Denver here, you'll see a lot

21 of wheat and corn and beans, soy beans.

22 A lot of that crop is genetically
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1 engineered, and here and there, you'll see

2 organic farms isolated. I think there is about

3 150 or maybe 200 organic farms in Kansas and

4 genetically engineered contamination is a big

5 concern for farmers in my area.

6 Of course, corn and soy beans, they're

7 two of the biggest GMO crops in the world

8 probably, but also wheat has been found to --

9 there's been genetically engineered wheat found

10 where it's not supposed to. It's not

11 commercially available, but it was found in

12 Oregon and Montana, outside of trials, it was

13 supposedly destroyed, but they found some

14 contamination in affected markets in Asia.

15 This was not even organic markets. 

16 But it's a concern that I face as an organic

17 producer because I have customers thinking that

18 there is genetically engineered wheat out there. 

19 And that if my wheat was contaminated, it would

20 be devastating because we grow an old variety

21 called Turkey Red.

22 It's a land race and I am my own seed
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1 dealer. I can't go buy someone -- like, I can't

2 go to like a university or a non-organic seed

3 market and find this wheat. It's something that

4 people have saved for generations. 

5 So that is a big concern that other

6 farmers that I talk with face also, beyond wheat,

7 and especially when they're trying to market

8 their products, corn is especially promiscuous. 

9 So I've heard that part of the problem

10 with imports, an increase in imports, one of the

11 justifications that the buyers are giving for not

12 buying so many organic crops is GMO

13 contamination.

14 So it's something that we would need

15 to address as an organic community, and the seed

16 purity rules that the NOSB will be discussing are

17 very important. So thank you.

18 CHAIR CHAPMAN: Thank you very much. 

19 Any questions?

20 (No audible response.)

21 Thank you. Up next is Jenny Cruse

22 followed by Kiki Hubbard. Kiki, if you could go
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1 to the on-deck chair. Jenny, you can start with 

2 your name and affiliation for the record.

3 MS. CRUSE: Jenny Cruse, Accredited

4 Certifiers Association. The ACA would like to

5 thank the Board and the CACS for its work on the

6 proposal on personnel performance evaluations. 

7 The National Organic Program revision of NOP-2027

8 posted in March of this year presents an

9 allowance for certifiers to take a more flexible

10 and risk-based approach to inspector field

11 evaluations. We thank you for your advocacy for

12 that.

13 We acknowledge that the revised

14 version of NOP-2027 resolved the main concern our

15 members had related to the field evaluation

16 process. That is the requirement for annual in17 field evaluations.

18 However the CACS discussion and

19 proposal are still worth talking about. I'd like

20 to highlight a couple of topics.

21 The first is related to consistency in

22 inspector training. The CACS proposal stated
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1 that NOP trainings must include clear direction

2 as to inspector qualifications, continuing

3 education, annual evaluations and periodic in4 field witness audits.

5 We submit that a task force made up of

6 representatives from the ACA and IOIA would be

7 well suited to establish these expectations. Our

8 members have expressed a great deal of interest

9 in collaborating on this in the near future.

10 Our recent survey of our certified

11 members with 22 agencies represented found that

12 this was the second highest ranking ACA working

13 group priority for 2017. The ACA's broad

14 representation in conjunction with IOIA's

15 historical perspective on inspector training

16 would provide a strong foundation for

17 establishment of standardized training

18 expectations.

19 The second topic related to NOP-2027

20 is the use of clear language. Some of the

21 concerns certifiers had with the earlier drafts

22 of NOP-2027 had to do with the statement that
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1 certifiers should perform annual field

2 evaluations for inspectors and the fact that the

3 word should was enforced as a must in some cases.

4 While the question of annual in-field

5 evaluations seems to be largely resolved,

6 challenges with the implementation of NOP

7 guidance will persist if the distinction between

8 the words should and must is not recognized. We

9 thank the CACS for bringing this up in the

10 discussion of NOP-2027 and urge use of the

11 Federal Plain Language Guidelines to reduce

12 future confusion.

13 Again, we thank you for your time and

14 work.

15 CHAIR CHAPMAN: Thank you. Any

16 questions?

17 (No audible response.)

18 Thank you, Jenny.

19 Up next is Kiki followed by Terry

20 Shistar. Kiki, if you'd start with your name and

21 affiliation for the record.

22 MS. HUBBARD: Good afternoon. My name
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1 is Kiki Hubbard. And I'm the Director of

2 Advocacy for Organic Seed Alliance. We're a

3 nonprofit that works nationally to ensure organic

4 farmers have the seed they need through research,

5 education and advocacy. I'm going to touch on

6 two topics.

7 First, we encourage continued work on

8 the issue of excluded methods, including

9 initiating discussion and decisions regarding

10 methods listed as to be determined in the

11 November 2016 Discussion Document. This work is

12 especially timely given that some of the methods

13 in question are evolving rapidly and have

14 outpaced current regulations, oversee and

15 biotechnology. Organic Seed Alliance is ready

16 and willing to support the NOSB in these

17 conversations in the months ahead.

18 Second, we're very pleased to see the

19 Crops of the Committee Proposal to strength the

20 NOP's 2013 Guidance Document for Organic Seeds. 

21 The subcommittee's proposal demonstrates a

22 careful review of public comments and thoughtful
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1 consideration of various avenues for which to

2 clarify and strengthen the organic seed

3 requirement.

4 NOSB's ongoing attention toward

5 organic seed underscores the important role that

6 you as a board as well as the NOP and

7 certification community play in fostering organic

8 seed systems. Developing these systems is

9 important not only to help certified growers help

10 meet our regulatory requirements but to ensure

11 that we are advancing seed that helps organic

12 farmers stay competitive through access to

13 genetics that are adapted to organic farming

14 practices, changing climates and that meet

15 diverse and ever-changing market needs.

16 We believe the Crops of the Committee

17 Proposal is generally very strong. We support

18 the proposed regulatory change coupled with

19 stronger guidance for certifiers.

20 There are, however, a few components

21 of the proposal that we would like to see changed

22 before the NOSB votes on this proposal. These
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1 changes are essentially language that is set in

2 to provide more clarity for the organic

3 community. They are described in much more

4 detail in our written comments.

5 We therefore request that the NOSB not

6 pass this proposal as written and that the

7 subcommittee continue their work on the proposal

8 based on our comments and those of others in this

9 room with the hope that it will be back on the

10 agenda for a vote this fall.

11 Beyond regulatory change and

12 improvements to the NOP's guidance, we're happy

13 to see organic seed tools, resources and

14 certifier training emphasized as critical to more

15 consistency in enforcing the seed requirement and

16 in advancing organic seed generally.

17 It's understandably difficult for

18 certifiers and inspectors to keep up on organic

19 seed availability by crop and region. More than

20 half the certifiers who responded to a recent

21 survey of ours say that more training and

22 resources are needed to better understand organic
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1 seed availability and how to verify compliance.

2 We encourage the NOP to regularly

3 include organic seed topics in certifier's

4 training. And in addition in national training,

5 we encourage training at a regional level which

6 would also be very helpful.

7 And as an organization that leads

8 regular training for farmers on how to conduct on

9 farm variety trials, we believe there's an

10 opportunity for more collaboration and education

11 on how to conduct these trials in the context of

12 organic seed requirement and how to use this

13 information to verify compliance.

14 We are in the preliminary stages of

15 developing a manual on organic seed for

16 certifiers and organic operations with the goal

17 of creating a resource that explains the organic

18 seed requirement and guidance, why organic seed

19 is important beyond a regulatory requirement and

20 ways to measure continuous improvement. Thank

21 you.

22 CHAIR CHAPMAN: Thank you, Kiki. Any
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1 questions? Dan.

2 MEMBER SEITZ: If I understood the

3 testimony of someone who testified earlier, there

4 is perhaps a concern if you move too quickly to

5 require organic seeds that might adversely impact

6 diversity of crops. I was just wondering if I

7 understood that correctly what the worry about

8 unintended consequence would be there.

9 MS. HUBBARD: That's a great question. 

10 Our intention is never to propose policy changes

11 or actions that force farmers to use seed that

12 isn't appropriate for their farms. At the same

13 time we feel like stronger guidance and

14 consistency in enforcement is important to

15 supporting growth in the organic seed trade.

16 But we have a ways to go to create a

17 robust organic seed supply that fully meets the

18 diverse and regional needs of all organic

19 operations. That diversity piece is critical to

20 that because we don't, of course, want to pass

21 policies that have the unintended consequence of

22 reducing important diversity in the way of our
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1 plant genetic resource space.

2 And we support most of the current

3 proposal because the regulatory change and

4 improvements to the guidance we believe are a

5 reasonable next step to measure progress on an

6 annual basis without forcing full compliance in

7 the short term given that the supply isn't there

8 to meet the demand.

9 CHAIR CHAPMAN: Harriet.

10 MEMBER BEHAR: Since Europe has had a

11 longer requirement for the use of organic seed

12 than we have had, how is the maturity of their

13 organic seed availability there in Europe? Or

14 are they struggling as well?

15 MS. HUBBARD: Harriet, I feel like I

16 can't fully answer that question based on my own

17 knowledge base. So forgive me. I do think that

18 their model is worth considering. I don't think

19 we should adopt it fully such as they have a

20 catalog system of sorts -- probably using the

21 wrong word -- where you have to use organic seed

22 listed in their list or supply. I do not think
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1 we should move in that direction.

2 At the same time, I think in terms of

3 meeting the full organic seed requirement we will

4 need to take a regional approach and perhaps by

5 crop type so that it is done in a way that is

6 reasonable and is not leaving farmers in a lurch.

7 CHAIR CHAPMAN: Thank you. Up next is

8 Terry followed by Cameron Harsh. Terry, if you

9 can start with your name and affiliation for the

10 record.

11 MS. SHISTAR: Hi. My name is Terry

12 Shistar. I'm on the Board of Directors at Beyond

13 Pesticides. We have a long history of

14 involvement with organic production. We

15 submitted comments on all of the issues before

16 the Board at this meeting, but I'm going to

17 address a few today.

18 There continues to be an

19 unconscionable delay in implementing existing

20 NOSB recommendations for replacing the obsolete

21 references to EPA List 3 and List 4 inert

22 ingredients on the National List with listings of
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1 actual approved, nonactive ingredients in

2 pesticide products.

3 We submitted a Beyond Pesticides

4 report that places the issue of inert ingredients

5 into its historical and policy context ending

6 with a proposal from Moving Forward with the

7 consideration of the use of inerts in organic

8 production that is consistent with NOSB

9 recommendations.

10 Inert ingredients make up the largest

11 part of pesticide products are not chemically or

12 biologically inert, are not disclosed on the

13 label and have not been reviewed according to

14 off-book criteria.

15 We looked at active and inert

16 ingredients in pesticides known to be used in

17 organic crop and livestock production and checked

18 them against some toxicity screens. We concluded

19 that there are many more synthetic substances

20 used as inert ingredients in pesticides in

21 organic production. It's 127 and then there are

22 inactive ingredients of 39.
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1 Inerts do not differ very much from

2 active ingredients in the range of effects that

3 are seen. There are more inert chemicals used in

4 organic production known to have almost every

5 kind of toxic effect. Of the inerts about which

6 information is available, some present serious

7 problems and some appear to be fairly harmless.

8 Our report lays out a plan for

9 implementing NOSB recommendations on inerts as

10 recommended by the NOSB and incorporates a Safer

11 Chemical Ingredients List and evaluations by

12 EPA's Safer Choice Program. We suggest next

13 steps and an outline for a memorandum of

14 agreement with EPA.

15 We urge the NOSB to recommend

16 prohibition of converting high value conservation

17 land or fragile ecosystems to organic crop

18 production. It should recommend regulations that

19 define high value conservation land

20 scientifically based on ecological value. NOP

21 guidance can clarify by reference to existing

22 databases. The NOSB should perform a
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1 comprehensive review of cleaner sanitizers,

2 disinfectants and sterilants that examines the

3 need for new materials in light of alternatives

4 and hazards as required by OFPA.

5 Finally we oppose the proposal of

6 ancillary substances allowed in cellulose. Two

7 genotoxic carcinogens and one poorly defined

8 substance were not reviewed. Thank you.

9 CHAIR CHAPMAN: Thank you, Terry. Any

10 questions for Terry?

11 (No audible response.)

12 Thank you.

13 MS. SHISTAR: We had a lot more

14 questions this morning.

15 CHAIR CHAPMAN: Next up is Cameron and

16 on deck is Jay Feldman. Jay, you can go to the

17 on-deck seat. Cameron, if you could start with

18 your name and affiliation for the record.

19 MR. HARSH: Hi. I'm Cameron Harsh. 

20 I'm the Senior Manager for Organic and Animal

21 Policy at Center for Food Safety, an

22 environmental and consumer advocacy organization.
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1 CFS supports the definitions of aeroponics and

2 hydroponics in the discussion document and agrees

3 with listing them at 205.105. OFPA provides the

4 practices not expressly prohibited in the statute

5 that are considered allowed, but states that such

6 practices must not be inconsistent with the

7 Organic Certification Program.

8 Suspending plant roots in air,

9 submerging them in liquid solutions or inert

10 media and relying solely on liquid inputs is

11 inconsistent with the organic program.

12 NOSB should continue gathering

13 information on aquaponics to ensure that a final

14 definition captures all systems considered

15 aquaponic which may use solid rooting media and

16 get some nutrients from fish waste in combination

17 from solid nutrient sources. NOSB should

18 continue posing questions to container producers

19 particularly on the types of solid matter

20 including what portion, if any, is soil. They

21 should also continue on the types of sizes of

22 containers used and the details of their plant
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1 nutrition strategy.

2 Micronutrients for sulfates,

3 carbonates, oxides or silicates of various

4 nutrients is a categorical listing and is

5 therefore inappropriate as it does not identify

6 specific allowed substances. This reduces

7 transparency and may result in use of substances

8 that have not undergone full review. 

9 Micronutrients are an important tool for farmers,

10 but should be individually petitioned and listed.

11 NOSB should also ensure that nanoscale

12 products for listed nutrients are excluded. 

13 NOP's 2015 guidance leaves the door open to

14 petitions for individual nano materials. This

15 undermines the organic label. And NOSB must

16 recommend that nano materials be added to 205.105

17 as excluded.

18 CSF appreciates the effort to

19 determine whether marine plants used in organic

20 are compatible based on harvesting impacts to

21 ensure that all materials meet the high bar of

22 organic. The subcommittee must explain its
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1 reasoning for the species proposed need

2 recommended listing.

3 It was unclear whether they were

4 proposed because they can be sustainably sourced

5 or if they are simply those that are commonly

6 used. The purpose of this process is to

7 accomplish the former.

8 CFS supports creating disincentives

9 for converting uncultivated land that should

10 remain uncultivated to organic. A framework

11 should be developed to guide determination of

12 when such land may be appropriate for conversion

13 and identify strategies that protect or enhance

14 ecosystems. Forest Stewardship Council is one

15 resource that can be looked to for insight and

16 possible tools related to high conservation value

17 lands including for delineating areas that

18 require total conservation.

19 NOSB should consider recommending

20 language similar to IFOAM as to 205.202(d)

21 establishing that any field which crops are to be

22 sold as organic must not have undertaken any
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1 actions that negatively impact high conservation

2 value areas. NOSB should recommend improving

3 requirements for organic poultry related to

4 selecting suitable breeds.

5 CFS urged NOP to do so in the Final

6 Organic Livestock and Poultry Practices Rule by

7 stipulating appropriate growth rates and a

8 minimum age of slaughter. This would prohibit

9 industrial breeds that do not thrive in outdoor

10 systems on 100 percent organic diets, free of

11 synthetic amino acids.

12 AMS agreed that this topic deserves

13 further attention and ask NOSB to explore it. 

14 NOSB should follow this instruction and develop a

15 recommendation on poultry breed requirements.

16 CHAIR CHAPMAN: Thank you, Cameron. 

17 Any questions? Dan.

18 MEMBER SEITZ: Can you state just the

19 very quick definition of what an nano -- what is

20 it? A nanoparticle?

21 MR. HARSH: A nanomaterial.

22 MEMBER SEITZ: Yes, a nanomaterial. 
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1 And how does that work its way potentially into

2 food that we're considering organic?

3 MR. HARSH: There's a number of

4 different ways that nanomaterials could be used

5 in organic. One instance is as additives and

6 packaging and plastics. So we also commented

7 that when you look to alternatives for BPA

8 nanomaterials such as nano titanium dioxide

9 should not be used in organic because they can

10 migrate into the food products.

11 In terms of micronutrients, there is

12 nano molybdenum and nano cobalt on the market

13 right now which are nanoscale which I do not know

14 off the top of my head. But our science policy

15 analyst, Jaydee Hanson, is an expert in this

16 field of what is the threshold for scale and size

17 of nanomaterials in particular. But there are

18 nanonutrients on the market used in agriculture

19 today for crops. 

20 CHAIR CHAPMAN: Thank you. Any other

21 questions?

22 (No audible response.)
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1 MR. HARSH: Thank you.

2 CHAIR CHAPMAN: Thank you, Cameron. 

3 I'm just getting some folks from the Board asking

4 public commenters to speak up a little bit. We

5 don't actually have a public comment mic speaker

6 pointing our way. We're going to fix that the

7 next break. But if you guys could just try to

8 speak up a little bit so we can hear you a little

9 bit better.

10 MR. FELDMAN: So you want me to yell

11 at you.

12 CHAIR CHAPMAN: Yell at us, Jay.

13 MR. FELDMAN: I thought so.

14 CHAIR CHAPMAN: And before you start,

15 Jay -- Jay is up and David Moore is on deck -- if

16 you could start with your name and affiliation

17 for the record.

18 MR. FELDMAN: Thank you. Thank you,

19 Tom. I'm Jay Feldman, Executive Director of

20 Beyond Pesticides. I served in the National

21 Organic Standards Board for five years like you

22 all are doing. Thank you for your service.
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1 You do great work. But I'm not here

2 to praise you today. I'm here to talk about

3 other issues as you could have guessed.

4 In acting as stewards for organic, you

5 face two critical tasks. One is the deal with

6 what's on your work plan, the National List and

7 the process of reviewing materials and issuing

8 discussion documents. And then you face the

9 other issue of larger issues that are not on your

10 work plan but issues that need to be addressed in

11 a timely way.

12 I'm going to focus on the latter, the

13 second approach, because the integrity of the

14 organic seal is undermined every day when we

15 don't look at these broader issues. I'm going to

16 bring up four issues today.

17 The first is the biodegradable, bio18 based mulch film. Obviously, this material was

19 not ready for prime time when it was adopted by

20 and put on the list by the NOSB in the fall of

21 2012. The memo that was put out by NOP that's

22 cited in your documents 55.15.1 talks about 100
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1 percent bio-based material.

2 That does not exist in the market. 

3 New information has indicated and confirmed the

4 concerns that were raised by many at the NOSB

5 meeting in 2012. Unless you can attach an

6 annotation to that material, it needs to be

7 removed from the list.

8 Contaminated inputs, the Board had a

9 plan for contaminated inputs. And some of these

10 issues have come up previous to my testimony in

11 terms of drift, in terms of compost that's

12 contaminated.

13 We need an action plan on compost. 

14 You've got a discussion document that the

15 previous Board has adopted. Go with that and

16 move on that.

17 With inerts, there continues to be the

18 unconscionable delay. This is an issue that the

19 Board addressed in 2010 and then again in 2012

20 and unanimously adopted a plan. We need to carry

21 out that plan and immediately get TRs. You can

22 TRs and move through that process.
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1 Hydroponics. Again, a previous Board

2 decision in 2010 clearly stated that organic is

3 soil-based. Unanimously found that. And I don't

4 think that position of the Board has been changed

5 in any way or there is any new information.

6 Finally, the open docket is critical

7 to the work of this Board. You really need to

8 start using the open docket process. Again, put

9 pressure on the NOP to get that docket going. It

10 will enrich the community involvement in the

11 discussion around organic standards. Thank you

12 very much.

13 CHAIR CHAPMAN: Thank you, Jay. Any

14 questions for Jay? Dan.

15 MEMBER SEITZ: I'm told that from a

16 very young age I like to ask lots of questions. 

17 I'm still trying to get my mind around inerts in

18 pesticides. Inert sounds like something pretty

19 innocuous. It's inert.

20 MR. FELDMAN: Right.

21 MEMBER SEITZ: And if I understand

22 correctly, they're not always identified if you
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1 can just put it in a nutshell for we who are not

2 engaged in pesticide side issues daily. What's

3 the deal? 

4 MR. FELDMAN: Yes. As you know, the

5 Organic Foods Production Act intersects with

6 other statutes. And in this case, it's

7 intersecting with the Federal Insecticide

8 Fungicide and Rodenticide Act which defines

9 pesticide as both having an active ingredient and

10 an inert ingredient. It's a term of art.

11 The active ingredient is in the

12 product to attack the target pest. The inerts

13 are in there are as carriers, sticking agents,

14 materials that help deliver the product either as

15 a dust, a granule or a liquid.

16 So the question as Terry mentioned,

17 the issue is that when you look at an actual

18 formulation which includes both the active and

19 inert you actually have a combination of

20 materials of a lot of different chemicals, the

21 majority of which are not the active ingredient.

22 When somebody says glyphosate or
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1 chlorpyrifos those are the active ingredients,

2 but they really make up a fraction of the total

3 formulation. So years ago when we wrote the

4 statute, OFPA we said there are inerts out there

5 that are not of toxilogical concern and we relied

6 on an EPA list, List 4.

7 It turns out EPA did away List 4

8 because they decided to go to a more streamline

9 process. And in the process of doing that, they

10 notified the NOP and the NOSB that we all would

11 have to come up with our process of reviewing

12 inert ingredients.

13 The Board did that in 2010. Great

14 meeting. Lot of work. Community involvement. 

15 2012 tweaked it a little bit. Unanimously said

16 we can do this. Worked with the State of

17 Washington to come up with a list, an armory of

18 what all the inerts were in organic products. 

19 And we determined there were about 126 or 123

20 materials that could be divided up over five

21 years and we could review these things. We could

22 get TRs. We would work with EPA's Office of
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1 Pesticide Programs and review these things.

2 You know what. Stay ahead of the

3 curve because this is a ticking time bomb. It

4 really is and it's something that we have enough

5 resources in this room and in our community. I

6 even think people out there would volunteer to

7 help with the review of these materials so that

8 we as a community could say we are looking at the

9 total product that we're using as an input into

10 organic production.

11 And we feel good about it. We feel it

12 meets the office standards.

13 CHAIR CHAPMAN: Thank you, Jay. Emily

14 and then Francis.

15 MEMBER OAKLEY: I have to admit that

16 this is a subject that I haven't fully wrapped my

17 head around because I came on and it was sort of

18 on the back burner. Then other issues came

19 aboard.

20 And I guess my question is what

21 happened after 2012 and why didn't that process

22 begin? Is it feasible to reignite that process. 
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1 I know that Zea was the lead on that and is

2 obviously not on the Board now. Those of us who

3 are on I think are mostly not fully aware as you

4 know which is probably frustrating.

5 MR. FELDMAN: There have been a lot of

6 leaders on this topic. Jeff Moyer with Rodale

7 Institute in 2010 when I came on the board. And

8 then I became the lead and Zea came on the next

9 year and became the lead. Zea is a leader by

10 nature of course.

11 There was a task force with EPA, NOP

12 and two NOSB Board members. For a while we had

13 previous Board members on a task force. And you

14 know things happen. Things get bogged down and

15 things don't move. From our perspective, things

16 could have moved and they should move. This is

17 one of the issues among a handful of others that

18 have been put on the back burner that you can

19 elevate, get back on the agenda, on the work

20 plan, demand to be put on the work plan.

21 I think you can resolve it. I mean it

22 can be done. Why did it get put off? Many
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1 different perspective on that I'm sure.

2 CHAIR CHAPMAN: Thank you. Francis,

3 briefly. We're 45 minutes behind schedule. So

4 we're going to have to keep moving along. 

5 Francis.

6 MEMBER OAKLEY: I think it is on our

7 work plan still. I just wanted to clarify. It's

8 not that it's off the work plan. I just don't

9 think we've acted on it yet.

10 MR. FELDMAN: The committee should get

11 a report at every meeting as to how it's

12 progressing.

13 MEMBER THICKE: Bio-based mulch, are

14 you suggesting we should sunset it and then if it

15 clears up eventually we can bring it back?

16 MR. FELDMAN: Unless you're able to

17 adopt a very clear annotation that indicates and

18 gives very explicit instructions. I'm very

19 worried, Francis, that what's going to happen

20 with this is that we're going to set an allowable

21 level of non-composted material, non-natural

22 material. 
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1 So we'll get to the point where

2 there's so much. It's on the list, right. It's

3 allowed. And we're going to start tinkering with

4 the allowable levels of non-natural or non-bio5 based material. 

6 When you leave, others that have

7 concern about this will see the degradation of

8 that standard. So we need a very clear

9 annotation which we don't have right now that

10 really indicates that it has to be fully

11 degraded. It's got to effectively be removed

12 from the field. And it's going to be 100 percent

13 bio-based. We don't have that right now.

14 CHAIR CHAPMAN: Thank you, Jay.

15 MR. FELDMAN: Thank you.

16 CHAIR CHAPMAN: Up next is David

17 Moore. On deck is Diane Wilson. David, if you

18 could start with your name and affiliation for

19 the record.

20 MR. MOORE: Good afternoon. I'm David

21 Moore. I'm a California licensed agricultural

22 pest control advisor and qualified applicator. I
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1 work for Neudorff.

2 I'm here today to urge each of you to

3 vote to retain coppers, fixed coppers, copper

4 sulfate and all soaps on the national list. 

5 Fixed coppers and soaps are not

6 harmful to human health or the environment. 

7 These materials have no systematic human toxicity

8 and no acute toxicity hazard germane to

9 agricultural use. Existing laws and regulations

10 adequately and appropriately regulate pesticidal

11 use of these materials and safeguard humans and

12 the environment from unlawful exposures and

13 residue.

14 US EPA explicitly states that it has

15 no concerns about human risk from exposure to

16 copper pesticides. The risks of the soap salts

17 to applicators and consumers are negligible.

18 Copper's a necessary nutrient required 

19 by all living organisms. It is readily regulated

20 by and metabolized within the human body and

21 deficiency is a far greater health hazard than

22 excess. Copper is widely present in our food and
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1 drinking water. This is not considered a risk or

2 a hazard.

3 I also point out that enforcement of

4 the existing copper annotation at 205.601(i)(2)is

5 a separate issue for your vote to retain as is

6 the annotation on herbicidal soaps at

7 205.601(b)(1). Fixed coppers and soaps are

8 necessary for organic production and thus they

9 are widely used. These materials effectively

10 address many common agronomic pests including

11 many challenging key pests of organic crops. The

12 best example of this is fire blight of organic

13 palm fruits which is a significant threat to the

14 orchards and to the livelihoods of these farmers

15 since the Board delisted antibiotics for control

16 of this pest following the events of 2013.

17 Fixed coppers and soaps are completely

18 consistent with both the letter and the spirit of

19 organic agriculture. Both are historic pillars

20 of organic agriculture and predate the NOP and

21 the National List by hundreds of years.

22 Both coppers and soaps are explicitly
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1 endorsed by OFPA as allowed synthetics. Indeed

2 copper is the first synthetic material allowed in

3 OFPA at 21.18(c). No new information has been

4 presented to the contrary. So again I encourage

5 each of you to vote to retain coppers and soaps

6 on the National List and to remove the annotation

7 restricting herbicidal uses of soaps at

8 205.601(b)(1). Thank you.

9 CHAIR CHAPMAN: Thank you. Any

10 questions?

11 (No audible response.)

12 Thank you very much. Up next we have

13 Diane Wilson and on deck is Beth Unger. Diane,

14 if you could start with your name and affiliation

15 for the record.

16 MS. WILSON: Can you see me? I'm so

17 short.

18 I'm Diane Wilson. I'm Director of

19 Nutrition Services for Nature's One. Nature's

20 One is the manufacturer of pediatric organic

21 nutrition formulas. And we've been manufacturing

22 these and selling them since 1999.
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1 The Board has been dealing with L2 methionine for many years. And when it was

3 mentioned by Dr. Brines that we would be

4 discussing the L-methionine petition again today

5 at the last meeting in St. Louis there was a huge

6 groan in the audience. And I can fully

7 understand why because I've been dealing with it

8 since 2012 also.

9 In 2012, the Board met and addressed

10 the petition by the International Formula Company 

11 regarding L-methionine and infant formula. At

12 the meeting, I requested that that annotation be

13 expanded to include organic soy, pediatric/infant

14 formulas. The reason being that not just infant

15 formula but formulas for young children,

16 especially young children who require total

17 nutrition from these formulas need L-methionine

18 in their soy formulas as well.

19 Many of you may remember that soy is

20 deficient in methionine which is why it's now

21 allowed in poultry feedings and infant formula

22 and it's needed in pediatric nutrition formulas
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1 especially again for children who require these

2 as their sole source of nutrition.

3 Sole source of nutrition can be

4 orally. It can be by tube, either through the

5 nose, through the stomach or through the

6 intestinal tract. That's called enteral

7 nutrition through the GI tract.

8 The specific indications for use of

9 the soy-based formula would be for children

10 galactosemia, a generic disorder where they

11 cannot digest the carbohydrates in dairy

12 products, lactose and galactose. It also is for

13 children who have an intolerance to cow's milk

14 protein. And it's also an indication for use for

15 those families who have tube fed children that

16 need soy-based formulas for vegetarian purposes. 

17 They don't want animal products.

18 Now the question becomes are there

19 that many tube fed children in the United States. 

20 And the answer is yes. I contacted the Tube

21 Feeding Awareness Group and they estimate that

22 over 100,000 children in the U.S. today are fed
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1 by tube, either totally or partially.

2 Now there are no data specifying how

3 many of these are fed on organic formula which

4 are fed soy formula. But if you look at the

5 incidents of cow milk protein allergy today in

6 the United States which is about 2.1 percent of

7 all children, then you can understand that there

8 is a reason for having a soy-based formula.

9 And we've been providing one since

10 1999. And I can tell you we do have children

11 using our formulas as total source of nutrition.

12 The biological value of soy protein is inadequate

13 unless it is supplemented with L-methionine. And

14 I thank you for considering our proposal.

15 CHAIR CHAPMAN: Thank you. Any

16 questions? Asa.

17 MEMBER BRADMAN: I wanted to clarify

18 that statement you said. There's 100,000

19 children in the U.S. being fed by tube.

20 MS. WILSON: By tube, yes.

21 MEMBER BRADMAN: So these are -- I

22 mean I presume these are mostly NICU, prenatal.
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1 MS. WILSON: I'm sorry. What was the

2 question?

3 MEMBER BRADMAN: Are they kids in

4 NICUs?

5 MS. WILSON: Not necessarily, no. 

6 These are children between the ages of one and

7 usually 13 years of age.

8 CHAIR CHAPMAN: I had some follow-up

9 questions which I think build on yours. Could

10 you speak a little bit to the underlying medical

11 conditions that would perhaps require a gastric

12 tube just so people have a sense of the children

13 that would require this type of formula?

14 MS. WILSON: Any child that's having

15 any kind of dysfunction with swallowing, eating,

16 any kind of cancer of the throat, neck,

17 esophagus, anything like that would require a

18 gastrostomy tube.

19 CHAIR CHAPMAN: Thank you. And then

20 are you aware of any other organic, non-dairy

21 products on the market that are marketed for or

22 that are enteral formula other than yours?
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1 MS. WILSON: Yes.

2 CHAIR CHAPMAN: Yes, there are. Thank

3 you.

4 Any other questions? Joelle.

5 MEMBER MOSSO: Of those alternatives,

6 are they all soy-based or are there other

7 alternative plant protein-based?

8 MS. WILSON: There are some

9 alternatives that are made out of whole foods,

10 but they are non-organic. And often times they

11 contain milk protein in the form of whey protein. 

12 So for children that have a milk protein

13 intolerance, they would not be appropriate.

14 In terms of organic, there have been

15 rice formulas that have been looked at. But

16 there are a lot of issues with rice-based

17 formulas as a source of protein because one,

18 people are concerned about the arsenic content of

19 rice and secondly they are more deficient in

20 various amino acids, more so than soy protein

21 such as L-lysine and so forth and so on.

22 MEMBER MOSSO: Thank you.
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1 CHAIR CHAPMAN: Any other questions?

2 (No audible response.)

3 Thank you very much.

4 MS. WILSON: Thank you.

5 CHAIR CHAPMAN: Up next is Beth. On

6 deck is Chris Ciolino. Sorry if I butchered

7 that. Beth, if you could start with your name

8 and affiliation.

9 MS. UNGER: Thank you, Tom. I'm Beth

10 Unger. I am employed by CROPP Cooperative. This

11 is the nation's largest organic, farmer-owned

12 cooperative in the nation. And we are marketing

13 products under the Organic Valley and the Organic

14 Prairie brands. Today I am coming to you with a

15 request to keep casings on 606 on behalf of our

16 Organic Prairie products.

17 Casings I think if you read my written 

18 comments it was mostly about the casings. It's a

19 lot of information because I want to make sure

20 that you'll very well educated about casings. 

21 And the comment focused primarily on the hog

22 cases which are so important in the sausage
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1 market.

2 Organic sausage is a growing market. 

3 It had 21 percent growth in 2016 over 2015

4 according to SPINS data. And as you all know,

5 SPINS data excludes a lot of major retailers such

6 as Whole Foods, Costco, Target, etc.

7 But the organic hog production, just

8 to put this in context for you, is 0.4 percent of

9 the hog production in the United States. So the

10 challenge that happens with casings is all about

11 aggregation.

12 I know that Jean Richardson in a

13 previous discussion with the Board was like an

14 entrepreneur can clean them and do that. It's

15 not really like that. It's a very complex

16 process. It's a salt and water cleaning and so

17 on and so forth. 

18 But there is sizing. So they're not

19 all the same size. They have to be into sizes

20 and so on and so forth. When you take a look at

21 the slaughter facilities throughout the United

22 States, the organic slaughter is a small
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1 percentage of what they do. It is very

2 challenging to aggregate organic intestines.

3 If that isn't enough of a challenge,

4 the bigger challenge comes from the aggregation

5 of all of the aggregates in order to send it on

6 for further processing to get sized. It simply

7 isn't going to happen in the very near future. 

8 The market has not reached a state.

9 I'm hoping Europe will get there. 

10 Years ago, I had some conversations with some

11 Europeans about this very same challenges. 

12 Europe has a much higher production of sausage

13 than the U.S. does. They can't make it happen.

14 So I wanted to remind you about the

15 criteria for listing on 606. It's when the

16 product is not commercially available in an

17 organic form. This is clearly not available. 

18 Thank you.

19 CHAIR CHAPMAN: Thank you, Beth. Any

20 questions for Beth? Dan.

21 MEMBER SEITZ: Is it fair to say that

22 the large majority of the raw products, the
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1 intestines, would be from factory farm animals

2 and such?

3 MS. UNGER: That very well could be,

4 Dan. They're all aggregated.

5 CHAIR CHAPMAN: Thank you. Any other

6 questions? Harriet.

7 MEMBER BEHAR: There were some public

8 comments about the concern that the animals the

9 casings come from are fed GMOs and their feed

10 could be contaminated with pesticides. Has there

11 ever been any testing or anything done on those

12 casings to see what they are or if they have any

13 residues that we might be concerned about?

14 MS. UNGER: I'm sorry, Harriet. I

15 cannot answer that question. There may be an

16 answer, but I don't have it.

17 CHAIR CHAPMAN: Any other questions?

18 (No audible response.)

19 Thank you very much, Beth. Appreciate

20 it.

21 MS. UNGER: Thank you.

22 CHAIR CHAPMAN: Up next is Chris
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1 followed by Dan Carrothers. Again, apologies if

2 I'm butchering your names. If you could start

3 with your name and affiliation for the record,

4 you can set it straight.

5 MR. CIOLINO: Sure. My name is Chris

6 Ciolino and I am with Emery Oleochemicals Agro

7 Green Business Division. We are the

8 manufacturers of ammonium nonanoate which the

9 Board has looked into off and on the last ten

10 years. I'd like to address the issue of the

11 potential future allowance of soap-based

12 herbicides for use on organic food crops.

13 In any case, one of the things I'd

14 like to point out are what I consider two

15 inconsistencies or disconnects around the whole

16 issue of soap-based products in organic food

17 production. The first one is on soap-based

18 herbicides and whether or not they are aligned

19 with organic production practices.

20 In the 2015 Sunset Review, the NOSB's

21 ruling which was a unanimous vote to not remove

22 soap-based herbicides from the approved National
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1 List, the comment was specifically made by NOSB

2 that based on the subcommittee review and public

3 comment the NOSB finds soap-based herbicides

4 compliant with OFPA criteria and does not

5 recommend removal from the National List.

6 However, over the last ten plus years

7 our company and other companies have submitted

8 ammonium nonanoate, one soap-based product, for

9 consideration as a herbicide for organic food

10 crops. And not the only reason for rejection but

11 one of the reasons was that it was cited

12 frequently that the product is incompatible with

13 organic production practices. One of the things

14 we would recommend is clearing that inconsistency

15 up if you consider that an inconsistency.

16 Another inconsistency, we all know

17 that soap-based insecticides are approved for use

18 on organic food crops. On the left side of the

19 screen, we show organic soap-based insecticides. 

20 One of these could be ammonium nonanoate used as

21 an insecticide applied directly on the crop. 

22 Whatever does not fall onto the crop falls into
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1 the ground and then is decomposed by microbes as

2 shown there.

3 In the same example of ammonium

4 nonanoate used as a herbicide, this time it is in

5 the row middles. And whatever doesn't end up on

6 a weed also falls into the ground and decomposes

7 in the same way. Clearly, there's a disconnect

8 here.

9 This chart shows that there's no

10 difference in the environmental fate of the

11 ammonium nonanoate whether it is used as an

12 insecticide or a herbicide. And yet as it is

13 used as an insecticide is sanctioned by the NOSB

14 but not its use in approximately the same area as

15 a herbicide.

16 I ask that NOSB consider the removal

17 of the annotation currently in place of soap18 based herbicides that restricts their use to

19 farmstead maintenance and ornamental crops so

20 that organic farmers can use these materials as

21 herbicides around organic food crops.

22 CHAIR CHAPMAN: Thank you. Any
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1 questions? Thank you very much.

2 MEMBER BRADMAN: I'm sorry. I do have

3 a question.

4 CHAIR CHAPMAN: Sorry. Asa.

5 MEMBER BRADMAN: What are the

6 restrictions for the EPA registration for these

7 materials?

8 MR. CIOLINO: I'm sorry. Say that

9 again.

10 MEMBER BRADMAN: Are there any

11 restrictions by EPA on the registration of these

12 materials?

13 MR. CIOLINO: No.

14 CHAIR CHAPMAN: Sorry. Steve as well. 

15 Chris, we have another question.

16 MEMBER ELA: Sorry. I'm slow in

17 formulating my question. But are there different

18 rates used for herbicide versus insecticide?

19 MR. CIOLINO: Yes.

20 MEMBER ELA: And could that have a

21 reasoning behind? I mean I don't know the labels

22 off the top of my head. Are the insecticide
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1 lower rates than herbicide?

2 MR. CIOLINO: Yes, you're absolutely

3 correct. But I guess it would be my question

4 back to the Board. Is that the reason why it is

5 approved for use as an insecticide but not as a

6 herbicide even though the same environmental fate

7 of the product is the same whether it's used on

8 crop? In fact, the herbicide is used in such a

9 manner that it's not intended to ever touch the

10 crop. It's to be the weeds in the row middles or

11 underneath the orchard trees, that type of thing.

12 MEMBER ELA: Can I ask a follow-up?

13 CHAIR CHAPMAN: Yes, but then we'll

14 stop it there.

15 MEMBER ELA: A quick follow-up. I

16 mean some of our materials show that it does have

17 toxicity to soil organisms. So rate effect could

18 be pretty important in that.

19 MR. CIOLINO: Yes, and we'll address

20 that with the third speaker in this series. 

21 She'll address some of that on the differences

22 between what happened in 1992 versus 2015 on the
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1 assessment of that. Thank you.

2 CHAIR CHAPMAN: Thank you, Chris. Up

3 next is Dan followed by Darlene Florence. Dan,

4 if you would start with your name and affiliation

5 for the record.

6 MR. CARROTHERS: Yes. My name is Dan

7 Carrothers and I'm the Global Business Director

8 for Emery Agro Green Solutions. We're based in

9 Cincinnati and we've been in business for about

10 177 years.

11 First of all, I do want to thank the

12 Board for letting us have the opportunity to

13 speak and also to the NOP.

14 For my comments today, I want to

15 address a couple of areas. One is address

16 previous NOSB assertions that ammonium nonanoate,

17 soap-based herbicides are not required or not

18 needed in organic production and that there are

19 suitable alternatives already approved and then,

20 secondly, for the removal of the annotation on

21 soap-based herbicides.

22 During 2016, Emery conducted a fairly
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1 detailed field trial across the United States

2 with organic farmers. We asked them to take the

3 opportunity to use the product and provide us

4 with their insight as to their effectiveness,

5 ease of use, etc. and then also compare it to

6 existing options.

7 As you might see here from the chart

8 behind you, there were a couple of things that

9 came out of it. First of all, there were

10 hundreds of farmers that took part in this in

11 over 20 states across the U.S.

12 What we learned was that 54 percent of

13 those that actually used the product and provided

14 feedback to us said that the current methods that

15 are approved today are not adequate and do not

16 work. Of the ones that did say that they were

17 working, they listed the inability to scale, the

18 labor and the expense associated with it.

19 Eighty-four percent of those people

20 said that if the product were approved by the

21 NOSB they would use it. And finally 51 percent

22 of them said that this was the best natural
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1 product that they had ever used.

2 Clearly, from our perspective, there

3 is a disconnect between what has been cited as

4 recently as a 2011 NOSB review and what organic

5 farmers are actually saying across the United

6 States. The products that they're currently

7 using now are not working and they are looking

8 for new alternatives.

9 In addition to the survey, we've

10 gotten feedback from the general public. We've

11 gotten feedback from academia. And to quote one

12 here, Dr. Doohan from Ohio State University who

13 is the Professor of Horticulture and Crop Science

14 "Current practices for weed control are woefully

15 insufficient." Our survey has in fact support

16 that comment.

17 The fact is even more revealing when

18 you look at the disconnect today between organic

19 demand and supply for organic foods. Part of the

20 problem we think can be highlighted around weed

21 control practices which are inadequate. The

22 production capability of organic versus
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1 conventional I think most people would agree is

2 somewhere around 20 percent less.

3 What's happening is this supply that

4 we're currently not meeting is being met by

5 imports. We would ask that the NOSB look at

6 first of all taking the annotation off soap-based

7 herbicides and give the U.S. organic farmer an

8 opportunity to have better technology. Thank

9 you.

10 CHAIR CHAPMAN: Thank you. Any

11 questions? Francis and then Harriet and then

12 Steve.

13 MEMBER THICKE: So do you see this as

14 being a nonselective herbicide used pretty much

15 everywhere, kind of like inorganic Round-up?

16 MR. CARROTHERS: I'm not sure I would

17 use that exact term. But what I would say is

18 that we certainly see the opportunity for this

19 product to be used in crop and as my colleague

20 just showed the product as an insecticide is

21 already approved. People can go in and spray

22 their crops with it. All we're asking is that
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1 the annotation be in symmetry with the

2 insecticide so that they can certainly spray

3 where weeds are between the rows.

4 There was a question about rates. I

5 think one thing to also keep in consideration is

6 for insecticides there are also multiple

7 applications versus in herbicides. Often one

8 application is all that's used. Sometimes with

9 the rate issue you have to look at the number of

10 applications as well.

11 CHAIR CHAPMAN: Harriet.

12 MEMBER BEHAR: Is this product being

13 used in conventional agriculture? And would

14 there a risk of resistance over time?

15 MR. CARROTHERS: Very good question. 

16 The answer is yes, it's being used in

17 conventional today. One of the things about

18 soap-based herbicides, fatty acids, is that we

19 have not seen any documented resistance at all

20 because of the way it works. It actually works

21 by when you spray it on the leaf surface it rips

22 the cuticle open and the weed in this case
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1 desiccates.

2 But we have not seen any resistance at

3 all. In fact, in other studies where we looked

4 at combinations with fatty acids with things like

5 pyrethroids or whatever, we see that you can

6 actually get control of some insects that are

7 resistant to certain conventional or synthetic

8 because of the way the fatty acids work. We

9 actually think it could be a good tool in

10 breaking resistance.

11 CHAIR CHAPMAN: Thank you very much. 

12 We have Steve and then we'll stop there for the

13 sake of time. Steve.

14 MEMBER ELA: I'll ask a similar

15 question. If these material have toxicity to

16 soil organisms such as earthworms and insects and

17 things, I mean it seems like as an organic mantra

18 or principle we want to avoid those kinds of

19 materials. Could you address why if you're going

20 to use it more widespread how we deal with those

21 toxicities?

22 MR. CARROTHERS: Good question. My
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1 colleague, Dr. Florence, will get into it in a

2 little more detail. What we can say is this. In

3 the 1992 EPA Red there were some gray areas

4 around how fatty acids worked in the soil and

5 what they did in terms of some of the

6 microorganisms, etc. 

7 In the most recent 2015 Red, they've

8 actually brought a lot of transparency. It

9 actually cleared up a lot of questions about what

10 kind of harm it could have for the soil. I think

11 what we would say at this point is that the way

12 it breaks down and the fact that fatty acids are

13 a food source for microorganisms is actually a

14 positive thing. And we don't believe that that

15 would be an issue whatsoever. My colleague will

16 touch on that in more detail.

17 CHAIR CHAPMAN: Thank you.

18 MR. CARROTHERS: Thank you.

19 CHAIR CHAPMAN: Up next we have

20 Darlene Florence followed by Anais Beddard. If

21 you could come to the on deck circle. And,

22 Darlene, if you could start with your name and
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1 affiliation. 

2 MS. FLORENCE: Absolutely. My name is

3 Darlene Florence. And I'm a Research Manager

4 with Emery Agro Green Division.

5 I wish to express my support for

6 retaining soap-based herbicides on the National

7 List due to their favorable environmental

8 footprint. Soil microorganisms rapidly break

9 down soap salts into the fatty acid and salt

10 components. Both are naturally occurring.

11 Fatty acids are a significant part of

12 commonly eaten foods. However, soap salts occur

13 in such small quantities that they are unable to

14 be extracted from the environment in an amount

15 sufficient for organic agriculture. Many soap

16 salts also exhibit antimicrobial properties which

17 makes fermentation an economically unviable

18 production method.

19 There are currently approved organic

20 weed control methods that have negative 

21 environmental impacts. As a PhD soil scientist,

22 I understand how tillage introduces oxygen into
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1 the soil in quantities disproportionate to what

2 would be achieved in a natural ecosystem. This

3 accelerates the breakdown of organic matter which

4 microorganisms and plants depend on for

5 nutrients.

6 Thermal controls such as weed flaming

7 product air pollutants from the combustion of

8 non-renewable, petroleum-based products Vinegar

9 is a human health hazard. The person is subject

10 to severe irritation to the lungs, skin burns and

11 potential loss of vision.

12 Even though soap salts have been used

13 for many years, the data regarding the

14 differences in fatty acid lengths in salts was

15 limited until 2015 when the EPA conducted a

16 revised environmental fate in ecological risks. 

17 Previous petitions of soap-based herbicides such

18 as ammonium nonanoate were reviewed using only

19 the EPA's re-registration data from 1992 where

20 only long chains of potassium soaps were

21 considered.

22 For midchain soaps such as ammonium
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1 nonanoate there were unknowns regarding the

2 environmental impact. Those questions were

3 answered in the EPA 2015 revised assessment.

4 The effect of either salt potassium or

5 ammonium on honey bees was unknown in 1992. In

6 1995, the EPA determined that both salts are

7 practically benign to honey bees.

8 In 2015, the EPA also revisited the

9 effect of soap salts on aquatic invertebrates. 

10 Only potassium salts were considered in 1992.

11 However, due to land restrictions and rapid soil

12 biodegradation, soap salts were prevented from

13 leaching to water sources. Again, this

14 terrestrial application which is on the label

15 mitigates any potential negative effects.

16 Therefore, I ask the NOSB to retain

17 the listing of soap-based herbicides. And I also

18 ask the Crops Committee to consider removing the

19 annotation for these herbicides to provide

20 growers a National List that is consistent with

21 the EPA's 2015 Environmental Risk and Fate

22 Assessment as well as organic philosophy. Give
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1 organic growers a competitive advantage by

2 allowing them to control weeds with the same

3 product they already are allowed to use for

4 controlling insects. Permit them to use a

5 material to protect their health and the

6 environment.

7 CHAIR CHAPMAN: Thank you very much. 

8 I have Emily and Dave.

9 MEMBER OAKLEY: Hi. Thank you. I

10 wanted to elaborate on your freshwater

11 invertebrates and the toxicity notice and ask if

12 there's a concern of migration or runoff with

13 this product into ponds or other freshwater

14 sources as we see with other conventional

15 herbicides.

16 MS. FLORENCE: In this case there is

17 not. The material is intended to only be applied

18 to the leaf tissue that is unwanted. It dries

19 very quickly. And anything that drops into the

20 soil the microorganisms will consume very

21 quickly. Therefore it's not very mobile. It

22 won't leach down in through the soil and won't
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1 leach into water sources.

2 The EPA label prohibits application to 

3 or near water sources. That's a very clear

4 limitation by the EPA.

5 MEMBER OAKLEY: Can you just define

6 very quickly for me?

7 MS. FLORENCE: Less than 24 hours.

8 CHAIR CHAPMAN: Dave.

9 MEMBER MORTENSEN: Yes. A question

10 was asked earlier about the rates of the

11 difference between insecticide and herbicide use

12 rates.

13 MS. FLORENCE: Yes.

14 MEMBER MORTENSEN: Could you address

15 that?

16 MS. FLORENCE: Absolutely. 

17 Insecticides are used at one to two percent and

18 herbicides are used at four to five percent.

19 CHAIR CHAPMAN: Steve and we'll stop

20 there.

21 MEMBER ELA: I'm wrestling in my head

22 a little bit here because I mean since this is a
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1 synthetic substance the other ones you showed,

2 vinegar and such, are naturally occurring

3 materials.

4 MS. FLORENCE: Certainly.

5 MEMBER ELA: And so it seems like the

6 same argument could be made for potentially a

7 variety of other synthetic substances. I mean we

8 know weed control is an issue. But how do you

9 set aside that soaps are more special as a

10 synthetic and should be used versus possible

11 other synthetics?

12 MS. FLORENCE: I look at the safety

13 profile of soaps. They have no mammalian

14 toxicity. No toxicity to birds or any of the

15 other terrestrial organisms. They're used in the

16 soil. They reduce the reliance on tillage which

17 destroys soil structure, introduces oxygen which

18 breaks down organic matter and then reduces that

19 sequestration of carbon. I think this would be

20 a very important tool to be able to kill the

21 weeds and then have them on the soil so that they

22 decompose in the soil and add organic matter to
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1 the organic system.

2 CHAIR CHAPMAN: Thank you very much.

3 MS. FLORENCE: Thank you.

4 CHAIR CHAPMAN: Up next is Anais

5 followed by Thomas. But please start with your

6 name and affiliation for the record.

7 MS. BEDDARD: Hi. My name Anais

8 Beddard and I represent the second generation at

9 Lady Moon Farms. This is my third time speaking

10 in front of the NOSB and I see some new faces. 

11 Welcome. Everything you guys do is so important

12 and highly valued.

13 Lady Moon is the largest organic

14 vegetable grower east of the Mississippi with

15 farms in Florida, Georgia and Pennsylvania

16 providing year round produce. My parents started

17 farming organically 30 years ago because they

18 felt strongly about growing healthy, delicious,

19 good-for-you food, food that was grown in the

20 soil.

21 At the time, organics did not carry

22 the same weight it does now. It had been around
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1 since the beginning of the 19th century

2 officially. But it hadn't received any respect

3 in the larger agricultural industry.

4 My parents were part of a group who

5 believed that this age-old system of growing was

6 the best way of producing food. They fought to

7 heard, struggled to be respected, and were

8 passionate about their cause. And in time, the

9 name organic took on meaning and earned trust in

10 the marketplace.

11 These revolutionaries didn't start

12 farming organically because they could get higher

13 prices for their produce. They started because

14 they believed in the process which focused on

15 soil as the foundation.

16 It is an expensive production system

17 that requires a lot more effort, time and

18 investment to be successful. You aren't only

19 focusing on producing a strong harvest during

20 season but on cultivating an entire ecosystem for

21 the years to come.

22 Crop rotation, cover crops, green
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1 manure, these are just a few of the practices in

2 our toolbox and in OFPA that we must utilize to

3 be effective. You aren't an organic grower just

4 by using OMRI-approved inputs. That was and is

5 the whole point of the organic farming model. It

6 is not an input-based system. It is a

7 regenerative model focused on building the soil.

8 When you read OFPA, soil is prevalent

9 throughout all the guidelines. Why hydroponic

10 operations were ever allowed to be certified is

11 beyond me. We diluted the labels integrity while

12 nearly every other country made it stronger.

13 Now we're faced with an industry that

14 continues to post two digit growth, but to what

15 extent. New growing systems based on evolving

16 technology will continue to be developed. That

17 does not mean they should wear the same labels as

18 those systems that are well defined and rooted in

19 the system.

20 It is more important now than ever

21 before to maintain the organic label's integrity. 

22 I agree with the discussion document in that
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1 hydroponics, aquaponics and aeroponics should be

2 excluded from organic. Container systems that

3 rely predominantly on liquid nutrients are no

4 different from hydroponics.

5 We should adopt the EU's standards. 

6 Organic was founded on the principle of enriching

7 the soil which means in the ground. I urge the

8 NOSB to make a recommendation as soon as

9 possible. The expansion of hydroponic operations

10 continues as an astonishing rate and the

11 uncertainty in the marketplace is increasing. 

12 The farmers performing fought hard to make

13 organic a respected system. We cannot let their

14 work be lost. Thank you.

15 CHAIR CHAPMAN: Thank you very much. 

16 Any questions?

17 (No audible response.)

18 Thank you.

19 MS. BEDDARD: Thank you.

20 CHAIR CHAPMAN: Up next is Thomas

21 followed by Will Hemker. Thomas, if you could

22 start with your name and affiliation for the
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1 record. 

2 MR. BEDDARD: Thomas Beddard, Lady

3 Moon Farms, and I'm not sure I can follow my

4 daughter, but I'll try. I'm here today to voice

5 my opinion as to what will become of a production

6 system as old as human agriculture yet with its

7 modern roots in post-World War II society.

8 This system was called organic as a

9 nod to the fact that a well-balanced ecosystem

10 needs to be viewed as a living organism. And

11 this system can be summed up in one word, soil.

12 And the OFPA Act, of which the NOP is

13 based on, clearly got this right when soil

14 fertility was the benchmark for being a certified

15 organic farm.

16 It seems there are two sides to this

17 issue. On the one side are those that say

18 hydroponics -- and this does include container19 grown crops that get the majority of their

20 nutrients from soluble fertilizers -- should be

21 able to be certified organic, as long as all

22 inputs are allowed under the national law, that
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1 their systems contain biology without soil, that

2 they represent new technologies and innovations

3 for producing food.

4 They maintain that allowing

5 hydroponically-produced foods the same organic

6 status as soil-grown foods is progress. One of

7 their chief arguments is that the marketplace

8 needs more organic food.

9 And they are expanding quickly because

10 it is lucrative and growing hydroponically with

11 allowable organic inputs is much easier than

12 growing in the soil.

13 On the other side are those who've

14 maintained that OFPA got it right when it made

15 soil the centerpiece of being a certified organic

16 farm. And my question is, how in a short 27

17 years could something so essential, in fact that

18 which is the whole point of the production system

19 become something old fashioned, something that

20 needs to step aside for progress, something that

21 needs to make way for innovation?

22 No, my friends, innovation was
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1 realizing that a truly healthy sustainable

2 farming system that could call itself organic, it

3 had to without compromise be centered around the

4 soil as a living entity. That is innovation. 

5 That is progress.

6 And as a farmer looking at his 30th

7 year of being certified organic, I can tell you

8 we have just barely scratched the surface of what

9 all this means, because the complexity is so

10 great.

11 To allow a much simpler, less complex

12 production system to wear a highly coveted and

13 extremely hard-earned seal as certified organic,

14 that to me is not progress. That is capitulating

15 to market forces.

16 When one of your main arguments is to

17 allow a system that is not compatible with OFPA

18 to wear the same seal as a system that is because

19 the market needs more organics to sell seems like

20 watering down the wine.

21 You don't do this to a production

22 system that is not easy to emulate and therefore
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1 so well respected around the world. Hydroponic

2 farming is missing the most essential ingredient

3 there is to organic farming, soil.

4 And you can't have organic farming

5 without soil. Organic farming is not about

6 allowable inputs. It's about feeding the soil,

7 not the plant. Hydroponics is the opposite of

8 that. My vote is for the integrity of the

9 production system, not for the benefit of

10 personal interest, and I hope yours will be too. 

11 Thank you all for your service.

12 CHAIR CHAPMAN: Thank you. Questions? 

13 I have Emily, Harriet, Dan, Ashley and Steve,

14 then we'll stop it there for the sake of time.

15 MEMBER OAKLEY: You thought you were

16 just going to sit back down, huh?

17 MEMBER BEHAR: Well, you had this very

18 interesting --

19 MR. BEDDARD: I was certainly hoping.

20 MEMBER BEHAR: You have this very

21 interesting --

22 CHAIR CHAPMAN: Yes, the slide up here
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1 --

2 MEMBER BEHAR: -- title here, like is

3 there a study here?

4 CHAIR CHAPMAN: This slide here is not

5 related to him. It's the next speaker.

6 MEMBER BEHAR: Oh, that's the next

7 one.

8 MR. BEDDARD: Oh, I'm sorry, yes,

9 those weren't my slides. And I'm glad I didn't

10 notice them. I would've been like, what?

11 CHAIR CHAPMAN: Emily?

12 MEMBER BEHAR: So I have a different

13 question then.

14 CHAIR CHAPMAN: I'm sorry, Emily was

15 up first. Harriet, sorry, Emily was up first.

16 MEMBER OAKLEY: Sorry.

17 MEMBER BEHAR: Oh, okay.

18 MEMBER OAKLEY: You mentioned

19 containers, so I wanted to ask if you can

20 envision a system or a proposal that the NOSB

21 might put forth that allowed for container

22 growing based on a high percentage of soil within
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1 the container and a limited amount of liquid

2 fertility feeding or if you are opposed to any

3 container growing?

4 MR. BEDDARD: You know, I can't

5 imagine you could actually grow a 90-day crop or

6 something, crops that give out good fruit -- and

7 I mean, in the greenhouses these things go six,

8 eight, nine months -- in a container with the

9 soil without mostly relying on soluble

10 fertilizers.

11 I have tried it years ago up in

12 Pennsylvania in my greenhouse just messing

13 around, and I mean, it's almost a completely

14 different thing. It's so hard to get the

15 balance, and you have to feed it with solubles

16 continuously. So I think the short answer from

17 me to you would be no.

18 CHAIR CHAPMAN: Harriet?

19 MEMBER BEHAR: So in your process, I

20 mean, do you find that you are profitable in your

21 farming system by growing in soil?

22 MR. BEDDARD: Yes, absolutely.
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1 CHAIR CHAPMAN: Dan?

2 MEMBER SEITZ: I was wondering if

3 there are any studies out there -- it seemed like

4 the slide that was on there referred to that --

5 that compares the nutritional quality and content

6 of hydroponically-grown crops with the similar or

7 same crops grown in soil?

8 MR. BEDDARD: You know, from what I

9 have read -- and I'm not an expert -- there's

10 just a lot of different studies out there. And I

11 think that it comes down on both sides of it that

12 -- I mean, even between conventional and organic,

13 organics always likes to say it's more nutritious

14 and some studies prove that.

15 I really believe that a society's

16 strength does come from its soils and highly

17 enriched, highly mineralized soils have to be

18 good for all of us. So without any hard evidence

19 -- I'm just not expert enough to really answer

20 that.

21 MEMBER SEITZ: And then just one other

22 question. Sometimes proponents of the hydroponics
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1 or container-growing methods cite the fact that

2 you could have degraded soils in which you're

3 growing crops and perhaps you would get something

4 less nutritious. I'm just curious, how would you

5 respond to the fact that the soil quality can

6 vary fairly greatly?

7 MR. BEDDARD: Well, as someone who

8 farms in Pennsylvania, Georgia and Florida in a

9 wide mix of soils, I can attest to the fact that

10 soils change widely from farm to farm, let alone

11 from state to state. But, the basis of organic

12 farming is soil improvement, and you have to show

13 your soil -- your farm plan is improving every

14 year.

15 And from my experience, you can't be

16 successful growing crops unless you are actively

17 improving your soils and making them fertile

18 organically, because we can't rely on solubles,

19 which is an easy, quick fix. We're relying on

20 the complex biology in a healthy soil, but soils

21 always need improvement.

22 CHAIR CHAPMAN: Thank you. Ashley?
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1 MEMBER SWAFFAR: What percentage of

2 your nutrients come from liquid fertilizers or

3 solubles?

4 MR. BEDDARD: What percentage of ours

5 come from soluble? We stay well below the 20

6 percent, and it depends on the crop and the time

7 of year. Usually in the colder months -- like in

8 Florida if the weather gets cold -- the solubles

9 react quicker, and we'll use a small amount of

10 that.

11 But, almost all of ours is green

12 manuring, cover cropping and then fertilizers

13 that need to be broken down with the soil

14 biology.

15 CHAIR CHAPMAN: Steve?

16 MEMBER ELA: Following up on that

17 question, if you were just to in your system add

18 water and nothing else, how long would your

19 system sustain itself and keep producing?

20 MR. BEDDARD: So do you mean --

21 MEMBER ELA: I mean, given your soil

22 building and what you're talking about the soil,
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1 if you were just to add water to your system and

2 not add any outside nutrition, how long would it

3 continue to produce?

4 MR. BEDDARD: Soils that we have built

5 up over time, you mean?

6 MEMBER ELA: Yes.

7 MR. BEDDARD: You mean, would we be

8 able to pull off a crop?

9 MEMBER ELA: I'm just curious, I mean,

10 how --

11 MR. BEDDARD: Yes.

12 MEMBER ELA: -- how sustaining is your

13 system from the soil? Is it --

14 MR. BEDDARD: I mean, soils need

15 constant improvement, you know, and fertility is

16 important. So no, you have to constantly feed

17 the soil and then allow the soil to feed the

18 plants. You just can't stop feeding the soil and

19 expect your plants to grow.

20 CHAIR CHAPMAN: Thank you. Thank you

21 for your comments.

22 MR. BEDDARD: Thank all of you. I
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1 really mean it. You guys -- the volunteer work's

2 unbelievable.

3 CHAIR CHAPMAN: Thank you. And up

4 next we have Wil Hemker followed by Anthony

5 Duttle. If you look at your agenda, for those

6 keeping score, you do notice that we were going

7 to take a break at 4 o'clock, key word is were.

8 We are 30 minutes behind schedule, so

9 we will be not taking that break. We're beyond

10 30 minutes behind schedule. So if you do need to

11 use the restroom or step out, please do so.

12 If you could start with your name and

13 affiliation for the record.

14 MR. HEMKER: I'm Wil Hemker, a fellow

15 at the University of Akron Research Foundation. 

16 This board and the NOP must uphold the organic

17 standards so that the consumer can trust the

18 label.

19 The NOSB should not recommend changes

20 to cultivation guidelines counter to the Organic

21 Foods Protection Act. Certified organic,

22 controlled environment, soilless growers do so in
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1 a biodiverse environment and deliver quality,

2 safe crops meeting consumer's expectations for

3 certified organic labeled food.

4 Today, I'm going to focus on two

5 attributes of crop grown organically, root zone

6 ecology and heavy metals presence in leafy

7 greens.

8 Organic farming tradition is based on

9 conserving biodiversity. Science has proved

10 diverse and plentiful root zone mircobiomes are

11 the outcome of organic farming.

12 Some organic farming advocates say

13 soil biological activity is one of the vital

14 processes enhanced by organic practices. Their

15 inference is that soil has biological activity,

16 and controlled environment soilless has little or

17 none.

18 Well, in 1990s, NASA's Controlled

19 Ecological Life Support System program

20 investigated hydroponic production. They

21 demonstrated that their model crop -- which was

22 wheat grown without soils -- its rhizospheres
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1 microbiome was teeming with life at a level of 10

2 to the eleventh, or that's 100 billion cells per

3 gram.

4 Therefore, both soil and hydroponic

5 growing display a similar plentiful root zone

6 microbiome. The microbiome is a symbiosis that

7 brings those elements to the roots.

8 When you survey consumers around the

9 globe, their perception for selecting organic

10 foods have a hierarchy of three importances, food

11 safety, human health and environmental concern.

12 Let us take a look at human safety and

13 human health for organic leafy greens. When we

14 surveyed and we looked at heavy metals analysis

15 of USDA organic certified versus greenhouse

16 hydroponic-grown spinach, we found six times more

17 copper and 60 times more cadmium in field grown

18 than in hydroponics.

19 Thus, the sampling of fresh, field20 grown organic spinach cadmium levels exceeded

21 EPA's drinking water limits by 10x. 

22 Anthropomorphic pressures are challenging
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1 agriculture and production of sufficient

2 quantities of safe food in our world.

3 The NOP must retain standards under

4 the Organic Food Production Act for all

5 cultivation techniques using certified inputs and

6 methods. This program needs to be rooted in

7 strong science and good agricultural practices to

8 certify safe organic crops that are available to

9 the U.S. public.

10 CHAIR CHAPMAN: Thank you. Questions? 

11 I see Francis and Steve. Francis?

12 MEMBER THICKE: You mentioned -- over

13 here, sir. You mentioned that the

14 microbiological activity was as high in a

15 hydroponic system versus soil, which is not

16 surprising if you have a lot of labile organic

17 material fed into it.

18 But, what about the diversity of the

19 ecology of the different organisms. Did you

20 measure that?

21 MR. HEMKER: No, those particular

22 scientists did not. They looked at the
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1 microbiome as the key intermediate between the

2 elements moving from the medium -- whether it be

3 soil or water -- into the plants.

4 And that's the critical zone if you

5 look at that symbiotic relationship, so that's

6 where the action is.

7 MEMBER THICKE: I mean, if you're

8 throwing in some labile material, you're probably

9 going to get a lot of nitrifying bacteria,

10 certain things that will break that down and feed

11 it to the plant. But is that as diverse as a

12 soil that has a more complex -- I mean, I would

13 think that --

14 MR. HEMKER: That wasn't reported in

15 that literature piece. But, they did do two

16 following studies showing that those were

17 beneficial organisms, and they inhibited

18 pathogenic organisms, such as E. coli and

19 Listeria.

20 CHAIR CHAPMAN: Thank you. Steve?

21 MEMBER ELA: Kind of following up on

22 Francis' question, I was going to ask a very
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1 similar thing, but I mean, we're seeing more and

2 more effects of mycorrhiza and that root-soil

3 interaction in terms of nutrition and things for

4 the plants.

5 Any thoughts on that in the sense of

6 -- I mean, you know, Francis was asking about

7 biodiversity within that solution. I'm curious

8 about the same thing, especially with mycorrhiza

9 and some of these other very beneficial things.

10 MR. HEMKER: No. There needs to be

11 more funded research on that to really look at

12 the diversity of the microbiome, and it's

13 complex. Soil is a very complex medium, but all

14 fermentation systems are complex.

15 If you look at it in the processed

16 food industry, hydroponics is beer production and

17 soil production is kimchi.

18 CHAIR CHAPMAN: I'll go with Dave and

19 we'll cut if off there. Dave?

20 MEMBER MORTENSEN: Yes, it seems to me

21 that one of the things that we miss when we're

22 talking about hydroponics is that soils and the
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1 dynamics of nutrient delivery by the soil is

2 driven largely by mineralization rates in the

3 soil that is a function of the carbon content and

4 the diverse microflora.

5 That's arthropods, hundreds of them

6 per gram of soil, thousands, maybe millions of

7 fungi and bacteria. It's hard for me to imagine

8 how that diversity -- you just were saying

9 hydroponics are diverse, soils are diverse and

10 they're complex.

11 But the complexity that comes with

12 mineralization of organic matter in a complex

13 colloidal mass just seems to me to be orders of

14 magnitude more complicated and diverse.

15 MR. HEMKER: I agree. It's very

16 complicated. But if you look at an organic

17 soilless grower, they use that same diversity. 

18 They just convert it over to -- from that animal

19 or that green manure, compost it into a nutrient

20 medium. They then move that by liquid into the

21 system.

22 I heard this morning a soil-based
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1 greenhouse grower that doesn't rotate his crops,

2 but he rotates the soil. What's the difference

3 between that -- other than physical form of a

4 solid -- to that of hydroponics by rotating that

5 crop liquidly coming from a compost system?

6 MEMBER MORTENSEN: I think a

7 difference would be the difference in the

8 complexity of the substrate.

9 MR. HEMKER: It depends on the inputs.

10 MEMBER MORTENSEN: An order of

11 magnitude more complex.

12 CHAIR CHAPMAN: Okay. All right.

13 MR. HEMKER: If you have a complex

14 inputs of compost that make up that beginning of

15 that nutrient solution, then you've got that

16 similar complexity that can take place.

17 I mean, let's take it from this

18 perspective. Organic farming is a technology. 

19 You know, it's a know-how, and it's evolved. Now

20 my hometown is Dayton, Ohio. And we're kind of

21 proud about two brothers in that town called

22 Orville and Wilbur Wright.
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1 Now, if they started out aviation as

2 a biplane design airplane, and they said anything

3 with less than two wings is not an aircraft, we

4 would be pretty far behind the curve.

5 CHAIR CHAPMAN: Okay. Thank you very

6 much.

7 MR. HEMKER: Let's take a look at

8 technology. How can technology help us feed the

9 world --

10 CHAIR CHAPMAN: Wil, I have to --

11 MR. HEMKER: -- and take care of the

12 planet?

13 CHAIR CHAPMAN: Wil, I'm going to have

14 to cut you off there. Thank you very much for

15 your comments. Appreciate it. Next up, we have

16 Anthony Duttle followed by Haley Walsh.

17 Haley can go to the on-deck chair. 

18 And Anthony, if you can start with your name and

19 affiliation for the record.

20 MR. DUTTLE: Yes. Good afternoon, my

21 name is Anthony Duttle, and I am the Director of

22 Agronomic Services for Tanimura & Antle, the
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1 employee-owned, family farm based in Salinas,

2 California, which produces both conventional and

3 organic field vegetables, as well as berries. 

4 And we also have a greenhouse hydroponic

5 operation in Tennessee.

6 I'm also a certified crop advisor and

7 a licensed pest control advisor. A primary

8 function in my role is to improve the quality of

9 crops while improving the sustainability and

10 long-term health of our farming operations.

11 I'd like to speak in support of

12 organic production in hydroponic systems,

13 particularly regarding the sustainability and the

14 basis of biological processes in hydroponic

15 production.

16 In our hydroponic system, we use a

17 combination of soil media, natural and derived

18 nutrients, as well as additives to the water --

19 organic-based additives to the water, which we

20 use for hydroponic production.

21 In the United States, we have

22 flourished with the healthiest, most diverse food
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1 supply in the world. As I am at the forefront of

2 a very small and shrinking proportion of the

3 population that's responsible for keeping the

4 food supply filled, I'm compelled to speak of the

5 responsibility of understanding and improving all

6 aspects of sustainability of our organic

7 production system.

8 As of 2014, the U.S. population was

9 318.9 million people with 54 percent of that

10 population residing in ten states, which include

11 California, Texas, Florida, New York, Illinois,

12 Pennsylvania, Ohio, Georgia, North Carolina and

13 Michigan.

14 Of that 54 percent -- 86.9 million or

15 57 percent of that percentage in those 10 states

16 -- live in states where soil-based farming of

17 temperate vegetables is not possible six to eight

18 months out of the year.

19 To maintain a consistent, viable

20 supply of organic produce flowing, current

21 production practices forced production to parts

22 of the country -- California, Texas and Florida -
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1 - where vegetable production is possible for

2 extended periods of the year.

3 Observation of the 2011 USDA

4 statistics of organic production indicate that

5 there were a total of 86,000 acres of lettuce and

6 mixed vegetables produced in the United States,

7 of which 45,682 acres were produced in California

8 alone. That represents 53.2 percent of all the

9 organic production in the United States came from

10 California.

11 Those that are familiar with vegetable

12 production are keenly aware that there are

13 precious few areas in the United States where

14 vegetables can be grown at various points in the

15 calendar to maintain the variety of produce we

16 have grown to expect in our grocery stores every

17 month of the year.

18 The majority of vegetable production

19 areas are vast -- as we've heard, are vast

20 distances from the main markets where organic

21 produce is consumed. The perception that organic

22 or conventional vegetable production is
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1 sustainable in 45 of the 48 continuous United

2 States is sadly not feasible.

3 And basically, I want to indicate that

4 the hydroponic production and the use of those

5 facilities facilitates a greatly reduced

6 reflection of inputs that are required to produce

7 those organic crops in those areas and it

8 diversifies --

9 CHAIR CHAPMAN: Thank you for your

10 comments. I'm going to have to stop you there. 

11 Questions? I see Emily and Joelle.

12 MEMBER OAKLEY: Hi, thank you. You

13 mentioned that you have mixed conventional and

14 organic production, and I was wondering what's

15 preventing you from being an entirely organic

16 operation?

17 MR. DUTTLE: Mainly the primary focus

18 of that is again, we do both conventional and

19 organic. We have a large production

20 responsibility for supplying both the

21 conventional systems in the United States.

22 We reflect what our customers are
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1 looking for in what we're doing. And, yes, we

2 have a desire to increase our organic production. 

3 We are working towards that, and we are shifting

4 towards that.

5 CHAIR CHAPMAN: Joelle and then

6 Francis.

7 MEMBER MOSSO: I had a question

8 regarding your hydroponic operation. First is if

9 it's certified organic and second is what kind of

10 substrate --

11 MR. DUTTLE: No, we are not certified

12 organic at this point, and we had entered into

13 switching our operations over to organic

14 production, but because of the issues around the

15 uncertainty of that, we are -- you know, because

16 of the investment that goes with that, we have

17 to, you know, consider all the options with it.

18 We have fully capable of pursuing the

19 organic certifications, but we have not pursued

20 that yet.

21 MEMBER MOSSO: If I may ask a follow22 up?
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1 CHAIR CHAPMAN: Quickly.

2 MEMBER MOSSO: What would be the

3 change if you were to convert to organic?

4 MR. DUTTLE: The main primary that we

5 would do is, you know -- we undertook this a

6 year-and-a-half ago, and the main things that

7 were limiting us are basically the discussions

8 that we're having here, whether or not it's worth

9 the investment to pursue the certifications.

10 CHAIR CHAPMAN: Francis?

11 MEMBER THICKE: In your hydroponic

12 that you want to switch to organic, what percent

13 of the nutrients come from liquid and what is the

14 makeup of that liquid?

15 MR. DUTTLE: Okay and basically to

16 answer your question, it depends on which

17 nutrient specifically you're looking for. In

18 some cases, we're getting as much as 80 percent

19 of the nutrients from the peat and the media that

20 we're using for our system.

21 We use a combined media, peat media

22 combined on a float system for that. Total
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1 amount -- and again going back to the -- and I

2 would challenge this question. So I'll answer

3 your question, but I'm going to answer in part

4 with a question.

5 In terms of organic leafy vegetable

6 production, some of the -- and I'm familiar with

7 this because I'm involved with conventional

8 organic production in an agronomic environment as

9 well. And in those systems, the primary

10 nutrients of nitrogen, potassium are fed through

11 that system -- through a drip system through the

12 majority of the season.

13 So nitrogen and potassium, a

14 significant portion of those nutrients are fed

15 through and supplemented throughout the season,

16 because you can't put enough nitrogen on that

17 through that system.

18 So to answer your question, that needs

19 to be qualified when we're talking about that. 

20 So in a hydroponic system -- the system that

21 we're using -- we're using potentially 30 to 40

22 percent of the nutrients that we're providing are
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1 from the media that we're using.

2 CHAIR CHAPMAN: Okay. Thank you very

3 much. I have to stop you there, but thank you

4 very much for your comments. Up next, Haley

5 Walsh, is Haley Walsh here? Seeing no one, we're

6 going to move on to Marni Karlin. Is Marni here?

7 CHAIR CHAPMAN: Marni is coming back

8 in a moment here. Is -- oh, she's coming up. 

9 Sorry, I was unaware of changes. Marni, are you

10 ready to go? All right.

11 MS. KARLIN: I sure am.

12 CHAIR CHAPMAN: Real quick, though. 

13 On deck is Amalie Lipstreu. And Marni, if you

14 could start with your name and affiliation for

15 the record.

16 MS. KARLIN: Yes. Thank you, Mr.

17 Chair. My name is Marni Karlin. I'm here from

18 Karlin Strategic Consulting, consulting on

19 organic food and agriculture policy. And I'm

20 here today representing Naturipe and Munger

21 Farms, a grower-owned producer and international

22 marketer of blueberries, strawberries,
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1 blackberries and raspberries, including certified

2 organic blueberries grown both in ground and in

3 containers.

4 Our growers are dedicated to

5 responsible organic container production and

6 comply with the letter and intent of the OFPA and

7 the NOP regulations. And we would love to invite

8 any of you to visit our operations to learn more

9 about our certified organic blueberry container

10 production.

11 My colleague will speak tomorrow about

12 more specifics dealing with our production, and I

13 know he will be best able to answer your

14 questions regarding specific production

15 practices. I'm going to speak a little bit about

16 process and what we believe is an appropriate

17 approach to the certified organic container

18 issue.

19 First, we urge you not to blur the

20 line between hydroponics and container production

21 when considering the compatibility of various

22 production systems with the OFPA and the NOP
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1 regs.

2 The discussion document being

3 considered does blur that line in a way that

4 Passports have not done. Passports have

5 considered separate documents and had separate

6 discussions regarding these different growing

7 methods, and we urge you to return to that

8 approach going forward.

9 Second and related, when you continue

10 your work on these issues, we urge you to revise

11 the proposed definition of hydroponics to ensure

12 that it does not inappropriately impact container

13 production. This is important both from a

14 substantive and procedural perspective.

15 Substantively including the term

16 biologically recalcitrant makes the definition

17 over broad and apply not only to hydroponic

18 operations but also to container operations that

19 grow crops with mixtures of soil, compost, peat

20 and coconut core, all certified organic materials

21 that are a mainstay in certified organic

22 production.
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1 And procedurally, an attempt to create

2 a hydroponics definition that then applies to

3 container production could be seen as

4 consideration of container production without

5 adequate notice and opportunity for stakeholders

6 to comment.

7 That is that container production

8 considerations are hidden in a document

9 purporting to be about hydroponics. This would

10 not be the open process that Congress expected

11 when it created the NOSB and the OFPA.

12 Third, we would respectfully like to

13 suggest this discussion may be in need of

14 reframing, and the best way to do so is through

15 convening a panel of neutral scientific experts.

16 Rather than asking and answering

17 questions designed to reach one outcome or

18 another, we need to understand the science and

19 through that find a way to compromise and

20 consensus based on the science. 

21 We encourage the board to continue

22 work on a discussion document specific to
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1 certified organic container production, and we

2 renew our request that the board convene a panel

3 of expert scientists on substrate in soil to

4 present at the next meeting in advance of any

5 determinations on certified organic container

6 production.

7 On behalf of Naturipe and Munger

8 Farms, I thank the NOSB for its service and for

9 the opportunity to comment. Thanks.

10 CHAIR CHAPMAN: Thank you. Questions? 

11 Okay. So we're going to start with Steve, Asa

12 and Ashley, and then we're going to hold it there

13 for the sake of time. Steve?

14 MEMBER ELA: So I'm curious with you

15 saying where we're blurring the lines between

16 container and hydroponics, if 100 percent of the

17 nutrition of something grown in a container was

18 say an inert material, would you call that

19 hydroponic or would you call that container? 

20 Could you tell me how that line is blurred?

21 MS. KARLIN: So I want to start by

22 saying that I am not a scientist, and this sort
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1 of goes right into my suggestion that what we

2 need is have is scientists sort of discussing

3 what the distinctions here are.

4 I would argue that there is a

5 difference between hydroponics and something that

6 is grown in a substrate. And I think that where

7 that difference lies really needs to be informed

8 not by the opinions necessarily of folks in the

9 sector, folks who are growing, but actually some

10 science that understands what the differences

11 are.

12 CHAIR CHAPMAN: Asa?

13 MEMBER BRADMAN: You suggested there

14 should be a panel of experts to discuss some of

15 these issues, and I guess my question would be

16 what specific topics do we really need more

17 discussion on from a panel of experts?

18 And, you know, are we talking about

19 soil biological activity and is the degree of

20 activity kind of a key broker in what's

21 acceptable and what is not acceptable?

22 Do we need information on water use,
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1 sustainability, impact on landscapes,

2 environmental degradation, conversion of native

3 landscapes to agriculture?

4 It seems to me that the issues are

5 really broad and that when we say we need a panel

6 of experts, we need clarity. So I'm curious what

7 your vision of that is.

8 MS. KARLIN: Thanks, Asa. I mean, I

9 think really what is primarily needed from my

10 perspective is experts on the biological activity

11 in the soil or the substrate. I think that's

12 what will really get to what the OFPA requires

13 and what the NOP regs require.

14 As to the other things that you've

15 noted, I think some of those are considered and

16 required by the OFPA and by the regs but some of

17 them aren't, and I think that it's important to

18 sort of stick to where the authority lies and so

19 to me that begins with the biological activity.

20 CHAIR CHAPMAN: Ashley?

21 MEMBER SWAFFAR: Okay. So you said

22 blueberries, right, is what you're --
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1 MS. KARLIN: Yes.

2 MEMBER SWAFFAR: Do you know what

3 percentage of blueberries are grown in containers

4 that are organic?

5 MS. KARLIN: I knew you were going to

6 ask that question. I don't know the answer to

7 that question, I'm sorry.

8 CHAIR CHAPMAN: Thank you very much.

9 MS. KARLIN: Thanks, Tom.

10 CHAIR CHAPMAN: Up next we have Amalie

11 and following is Jo Ann Baumgartner. Jo Ann, if

12 you could go on deck. And if you could start

13 with your name and affiliation for the record.

14 MS. LIPSTREU: Thank you. My name is

15 Amalie Lipstreu, and I'm a policy coordinator for

16 the Ohio Ecological Food and Farm Association. 

17 At the last NOSB meeting, I shared the story of

18 an organic farmer trying to maintain the

19 integrity of his farm in the face of proposed

20 construction of two pipelines.

21 Today, James, a fourth generation

22 dairy farmer is dealing with construction of dual
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1 42-inch pipelines diagonally across his grazing

2 fields.

3 Thanks to the Organic Agriculture

4 Impact Mitigation Plan that he used prior to

5 signing an easement, an organic inspector is

6 monitoring the progress of construction, ensuring

7 that all construction equipment is taken off the

8 field at the end of each day, wash stations are

9 utilized to prevent the introduction of

10 prohibited substances, hay bales used for silt

11 fence are inspected to ensure they are certified

12 organic and proper segregation of soils is

13 monitored.

14 It's been a learning experience both

15 for James and for OEFFA as we continue to refine

16 the tools and resources for organic producers

17 working to keep their certification in the face

18 of energy infrastructure. While James is very

19 appreciative of the measures that have been put

20 in place, his experience has revealed additional

21 impacts that could be prevented on other farms.

22 Knee-deep ruts have resulted from
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1 construction during heavy rains causing concerns

2 about soil compaction and the possibility of

3 topsoil being washed into subsoil. According to

4 James, this is really disturbing to see

5 considering how we care for the land.

6 Farmers like James are the backbone of

7 the National Organic Program, the stewards of the

8 land, water, air and animals that the public is

9 increasingly looking to support.

10 We can take discrete and deliberate

11 steps to ensure they're supported as they face

12 the challenges posed by the development of oil

13 and gas infrastructure.

14 I cannot stress enough that the

15 operation of these large pipeline projects and

16 the high-pressure hydraulic fracturing wells are

17 much different than the small oil and gas wells

18 farmers have had on their land in the past.

19 Additionally, the high standards of

20 organic production systems mean that those

21 impacts have to be considered well in advance and

22 mitigated.
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1 The workload of the NOSB is immense

2 and includes other issues that lack clear

3 regulatory authority, such as genetic

4 engineering. We would not persistently request

5 NOSB involvement in this area if it were not for

6 the fact that farmers are faced with these

7 situations that can and have resulted in the loss

8 of their operations.

9 The NOSB is not going to fix this

10 issue, but there are ways the NOSB can provide

11 clear guidance to organic certifiers and

12 operations. Please consider this issue through

13 the development of a discussion document.

14 CHAIR CHAPMAN: Thank you very much. 

15 Any questions? Emily?

16 MEMBER OAKLEY: I just want to

17 reiterate what we spoke with with Food and Water

18 Watch about asking for assistance and helping us

19 figure out how these issues align with OFPA and

20 the standards and where we can specifically

21 tackle them. And then I also wanted to ask how

22 these issues are affecting certification.
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1 MS. LIPSTREU: Thank you. I

2 definitely am glad to assist by looking at OFPA

3 and thinking about how we can really find those

4 connections. You know, I guess first I would ask

5 that NOSB can look more closely at this issue.

6 Again, we're by no means asking NOSB

7 to stop fracking. Rather, we're asking that you

8 address these real issues with the attention and

9 respect that you've given other difficult issues

10 in organics, such as the impact of genetic

11 engineering on farms. And that's why we

12 suggested using a familiar tool like a discussion

13 document to start understanding the issue.

14 Secondly, I think by taking a look at

15 organic agriculture impact mitigation plans, it

16 might not only help better think through the

17 issue, but it could also provide ideas for a

18 structure with which to address it.

19 And then I guess there's an

20 opportunity to share as you go both with USDA and

21 other state departments of agriculture. Harriet

22 shared some examples of some states that are very
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1 proactive. I would unfortunately say that there

2 are many states that are not only not that

3 proactive but barely even recognize organic

4 agriculture.

5 Almost all states are required to have

6 agriculture impact mitigation plans when

7 pipelines go through, but when we've looked at

8 those agriculture impact mitigation plans

9 developed at the state level, they do not do

10 anything near to what needs to be done to protect

11 the status of organic certification.

12 So finally, you know, and this would

13 definitely take more time, you could advocate for

14 the authority of certifiers to be informed of

15 proprietary chemicals used in the process so that

16 when, again not if but when, accidents occur,

17 certifiers are prepared and know what substances

18 for which to test.

19 CHAIR CHAPMAN: Thank you very much. 

20 Up next we have Jo Ann Baumgartner and following

21 that, Lori Klopf. Sorry if I said your name

22 wrong. Jo Ann, if you could start with your name
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1 and affiliation for the record.

2 MS. BAUMGARTNER: I'm waiting for my

3 slides. Hi, I'm Jo Ann Baumgartner with Wild

4 Farm Alliance, and we promote a healthy, viable

5 agriculture that protects and restores wild

6 nature.

7 With over 450 comments submitted

8 encouraging the elimination of the incentive to

9 convert native ecosystems, it's clear that the

10 NOSB must adopt a policy now that fixes the

11 unintended consequences of destroying nature

12 caused by the three-year waiting period for land

13 with prohibited materials.

14 In the last 40 years, the earth has

15 lost half of its wildlife populations. 

16 Agriculture is predicted to expand by 30 percent

17 into natural ecosystems by 2050. While

18 biodiversity is decreasing, organics increased

19 market share will exacerbate the biodiversity

20 crisis until a new policy is in place.

21 We conducted an informal survey with

22 inspectors and others asking them about native
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1 ecosystem conversions. They've seen, and we

2 heard about conversions in the native sagebrush

3 in Oregon and Washington, prairies in Colorado,

4 wetlands in New Mexico, forests in California,

5 native desert and subtropical scrub forest in

6 Mexico and grasslands and wetlands in China.

7 The high conservation value area four8 part definition outlined in the discussion

9 document should be used. It addresses rare

10 species, large landscape level ecosystems, rare

11 ecosystems and critical ecosystem services.

12 We agree with the ineligible period

13 for five years after conversion of high

14 conservation value areas. Land coming out of CRP

15 should be part of the assessment. CRP lands are

16 enrolled because they are environmentally

17 sensitive, many are highly erodable and about

18 half the federal status animal species occur on

19 or near CRP lands.

20 In order to determine if an area is of

21 high conservation value, first a desk evaluation

22 is conducted. In the continental U.S., a
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1 screening tool can be developed by the

2 NatureServe for the organic community that

3 determines the presence of rare species and

4 ecosystems. About 85 to 90 percent of the land

5 would be excluded.

6 If the land is in the 10 to 15 percent

7 category, producers can request assistance from

8 their state natural heritage programs, which

9 often provide free field environmental reviews

10 worldwide.

11 A desk evaluation can be done using

12 IUCN's Red List, government protected species

13 lists and use the Global Forest Watch free online

14 tool seen here that tracks forest destruction

15 shown in pink.

16 The pink area on this map is the

17 Salinas Valley of California and ground truthing

18 shows that a riparian area forest was cut down. 

19 It's not, here we go. We urge you to agree that

20 a new policy is required.

21 Let's keep the process moving forward

22 to determine the best implementation, then NOSB
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1 should recommend a rule change and new guidance

2 to the NOP. We cannot wait. Too much is at

3 stake from rare species to the integrity of

4 organic agriculture. Thank you.

5 CHAIR CHAPMAN: Thank you very much. 

6 Questions for Jo Ann? Emily, Dan. Okay, I'm

7 going to stop at those two. Emily, go.

8 MEMBER OAKLEY: What do you think

9 about a definition of not converting any land

10 that hasn't been previously cropped or grazed for

11 pasture as opposed to the high value conservation

12 definition? So something a little broader to

13 protect land that is wild in any state.

14 MS. BAUMGARTNER: I think there's real

15 value in considering that. The reason why we

16 went to suggesting the high conservation value

17 areas is because it narrows the scope of how much

18 land would be taken out of that organic

19 agriculture.

20 But the value in what you suggest is

21 it's very simple or maybe not very, but it's much

22 simpler. Farmers who haven't been well educated
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1 and certifiers who don't have a lot of background

2 in conservation can understand it. But, it also

3 excludes CRP land, which is a problem like I

4 described.

5 CHAIR CHAPMAN: Dan?

6 MEMBER SEITZ: This is a question for

7 Miles. I've occasionally seen in grocery stores

8 products that are sold as being grown on

9 transitional land. And I think I had read

10 somewhere that there may be some support for

11 people who are transitioning to organic.

12 So I was just curious what can be done

13 on the other side with supporting people

14 transitioning over the three years in order to

15 make the competition here for high value land

16 less dramatic.

17 MR. MCEVOY: Yes, USDA has a lot of

18 different things to support, information for

19 growers that might be interested in converting to

20 organic production.

21 The Natural Resource Conservation

22 Service has grant programs to support the
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1 transition from conventional to organic

2 production will help with various kinds of farm

3 plans and some cost share for that transitional

4 period.

5 We provide a lot of information

6 through the one-stop organic portal at USDA about

7 what the regulations are and what the standards

8 are to help people understand what they're

9 getting themselves into.

10 So there's a number different things

11 that USDA has done to provide information about

12 what the standards and how to comply with organic

13 through that transitional process.

14 MEMBER SEITZ: And so my question

15 would be then why is this not enough of an

16 incentive for people to take current land and

17 transition it as opposed to these high value

18 ecosystems?

19 MS. BAUMGARTNER: Because it takes

20 three years to transition that land with

21 prohibited materials. You can transition a

22 prairie overnight. And maybe that prairie has
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1 rare species on it, but nobody has looked. And

2 the problem is that we are incentivizing that

3 conversion, whereas conventional agriculture

4 isn't. There isn't anything like that.

5 CHAIR CHAPMAN: Thank you very much,

6 Jo Ann. Up next we have Lori. Following Lori,

7 Caroline Froning is on deck and after Caroline is

8 Peggy just so you guys know the order. Lori, if

9 you can start with your name and affiliation for

10 the record.

11 MS. KLOPF: Okay. All right, thank

12 you. Good afternoon. My name is Lori Klopf, and

13 I am in Regulatory Affairs at ICL Food

14 Specialties, which is a food ingredient company. 

15 I'm here to support the continued listing of

16 sodium phosphates on the national list for use in

17 dairy foods.

18 Our company is a member of the

19 International Food Additives Council trade

20 association, and we've submitted very detailed

21 written comments to the NOSB through IFAC.

22 Sodium phosphates have been on the
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1 national list for this limited use in dairy foods

2 for many years. They are safe in human foods and

3 have an essential functionality for preparation

4 of certain types of dairy foods. Today, I would

5 like to address some of the concerns and

6 questions that the handling committee has

7 expressed.

8 The listing for sodium phosphates

9 includes ingredients which provide emulsification

10 and stabilization of the natural protein, fat and

11 water in cheese sauces and powders, as well as pH

12 buffering, all of which promote the smooth cheese

13 texture.

14 In the NOSB discussion document, there

15 were several questions raised about sodium

16 phosphates. One was whether phosphates interfere

17 with the human body's absorption of calcium. The

18 answer is no, this is not a concern. Scientific

19 studies have shown that calcium is still

20 bioavailable in the gut whether in dissociated

21 form or as intact complexes.

22 Another similar question was about a
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1 relationship between sodium phosphate and calcium

2 sequestration. Again, phosphates do not

3 negatively affect the body's ability to use

4 calcium. More detailed information is provided

5 in our written comments.

6 A comment was made in the discussion

7 document that while sodium phosphates do not

8 cause human health problems, the long-term

9 cumulative impacts are not fully understood. On

10 the contrary, sodium phosphates have been used

11 and studied for decades and found to be safe for

12 humans.

13 Phosphorus is an essential mineral

14 required by the body to function properly. Any

15 extra phosphorus not needed is then excreted in

16 the urine. So there is no accumulation of

17 phosphate in the body.

18 Once again, the discussion document

19 brought up the concern of possible health impact

20 due to the use of phosphates and bowel purgatives

21 and cleansers.

22 Non-food uses of phosphates such as
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1 these are not at all relevant since both the

2 method and the levels of use are very different

3 from the low levels that are used in foods.

4 In summary, sodium phosphates have

5 been determined to be safe for human consumption

6 by U.S. and international regulatory agencies for

7 many years. Sodium phosphates are essential in

8 dairy foods, especially in cheese sauces and

9 powdered cheeses to provide texture, taste and

10 stability to these foods.

11 There are not suitable alternatives

12 that provide the same properties in these foods. 

13 Without this allowance on the national list,

14 several traditional U.S. foods would no longer be

15 available to the organic food consumers.

16 On a previous slide, I showed a

17 picture of a macaroni and cheese comfort food,

18 and this slide shows some additional organic

19 foods, which use sodium phosphate for their

20 smooth cheese properties. Thank you.

21 CHAIR CHAPMAN: Thank you very much. 

22 Questions? I see Harriet and then Lisa.
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1 MEMBER BEHAR: Can't sodium citrate be

2 used as well in the same dried cheese products?

3 MS. KLOPF: Sodium citrate has been

4 tested as an emulsifier in some products. It has

5 not in particular these types of products that

6 I've shown as cheese sauces and cheese powders,

7 it is not very effective. It does not provide

8 the same level of both the texture and the taste

9 and the stability.

10 CHAIR CHAPMAN: Lisa?

11 MEMBER DE LIMA: Over here. Hi.

12 MS. KLOPF: Oh, sorry.

13 MEMBER DE LIMA: A previous commenter

14 said that there were similar products on the

15 market, some that contained sodium phosphates and

16 some that did not. So do you know what accounts

17 for that difference? How can one exist with it

18 and one without?

19 MS. KLOPF: Yes. Actually, I'm glad

20 you asked that question, because when I was at

21 the store getting some recent photos, I did

22 notice that as well. So what we did is purchased
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1 some of the mac and cheese with no sodium

2 phosphate and did an informal blind comparison

3 test.

4 In our company, there were 14 people

5 who tasted both of these, and it was remarkable

6 the difference. The one with no sodium phosphate

7 was, in my opinion, not a good product. And 13

8 of the 14 people who, you know, did this blind

9 study agreed.

10 It was not a smooth, creamy cheese. 

11 It was very grainy. There was no emulsification,

12 so no ability to coat the pasta. The taste

13 itself was not good at all.

14 So, you know, the product is out

15 there. I don't think it will be very long-lived,

16 and it's unfortunate if that's the only product

17 that organics consumers would have.

18 So I would stand by my previous

19 comments that right now sodium phosphates are

20 still essential to be able to produce these

21 products.

22 CHAIR CHAPMAN: Thank you very much. 
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1 Thank you for your comments. Up next is Caroline

2 Froning, and Peggy Miars is on deck. After Peggy

3 is Shannon Helms.

4 MS. FRONING: Good afternoon. My name

5 is Caroline Froning. I am with Innophos. 

6 Innophos is a U.S. company that manufactures

7 ingredients for foods, including phosphates.

8 The company I work for has made

9 phosphates in different forms for over 100 years. 

10 From this experience we do understand how sodium

11 phosphates work in dairy foods as an emulsifier. 

12 We have spent decades studying them in our

13 research labs.

14 Food manufacturers today are not

15 putting in more sodium phosphates in their dairy

16 foods compared to prior years. If you use too

17 much sodium phosphate in the food, it changes the

18 properties and it makes them unappetizing, the

19 flavor unappealing and so people won't want to

20 buy them.

21 The typical use in dairy products,

22 particularly in processed cheeses is 1 percent to
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1 3 percent. Sodium phosphates are also not hidden

2 in dairy foods. The FDA regulations on

3 ingredient labeling clearly require that all

4 sodium phosphates be on a label when they are

5 present.

6 It is true that the amount of

7 phosphorus, which is the elemental form which a

8 phosphate gets its name from, is not listed by

9 amount per serving on a nutrition facts panel.

10 The FDA does not require this, and

11 this is a position the FDA continued even after

12 their careful deliberation in 2016 on revising

13 other aspects of the nutrition panel.

14 Sodium phosphates are safe for the

15 consumption by the general population, and the

16 FDA agrees with that. Typically, the U.S. daily

17 diets are nowhere near the Institute of

18 Medicine's safe upper limit of 4,000 milligrams

19 for daily intake of phosphorus from all sources.

20 We work with food manufacturers all

21 over the world and different food markets have

22 different types of dairy products and different
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1 tastes and preferences.

2 The discussion document asks what the

3 EU, European Union, uses in place of sodium

4 phosphates since they are not allowed on the

5 organic list in the EU.

6 The markets are not comparable because

7 the consumer tastes are not the same. That is

8 particularly true when you look at the

9 organically labeled, prepared foods and snacks

10 containing dairy.

11 In our experience, the European

12 organic market has few to none processed powdered

13 cheese and cheese sauce products while the U.S.

14 market does. Because of that, the NOSB should

15 not base its sunset review of sodium phosphates

16 on the EU market.

17 We understand that the National

18 Organic Program is a philosophical goal of

19 organically labeled foods being made of wholly

20 organic and agricultural ingredients, but that

21 goal is not achievable if you would like to

22 maintain the current product offerings in this
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1 segment.

2 There are not suitable organic

3 alternatives or agricultural alternatives to

4 replace what phosphates can do for prepared

5 organically labeled foods. So sodium phosphates

6 make it possible for consumers to access the

7 convenience of prepared foods containing dairy.

8 In summary, to keep available the

9 kinds of prepared organic products we have today

10 in the United States, we need to keep sodium

11 phosphates on the allowed list. Thank you.

12 CHAIR CHAPMAN: Thank you. Questions? 

13 Thank you very much for your testimony.

14 MS. FRONING: Thank you.

15 CHAIR CHAPMAN: Up next is Peggy

16 Miars. On deck is Shannon Helms and after

17 Shannon is Nate Lewis. If Shannon could come to

18 the on-deck chair. Peggy, if you'd start with

19 your name and affiliation for the record.

20 MS. MIARS: Good afternoon. I'm Peggy

21 Miars, executive director of OMRI, the Organic

22 Materials Review Institute. Welcome to the new
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1 NOSB members and thank you all for your hard work

2 on behalf of the organic industry.

3 My colleague, Johanna Mirenda will be

4 talking more about OMRI in her comments tomorrow. 

5 So I'll take off my OMRI hat and put on my hat as

6 the North American representative on the

7 Volunteer World Board of IFOAM Organics

8 International.

9 IFOAM is a 45-year-old nonprofit

10 organization that represents organic around the

11 world. We have 800 members in 120 countries and

12 many of those members are farmer groups.

13 We formed a regional IFOAM North

14 America group last year to both bring North

15 American organic issues to the international

16 table and to bring international organic issues

17 to North America. I'm sure you'll be hearing

18 more from IFOAM North America in the future.

19 I want to briefly address a hot topic

20 that many people are concerned about and which

21 Miles mentioned this morning. That's the massive

22 increase in organic grains being exported from
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1 Turkey to the United States. This is also

2 happening in Canada and perhaps other countries

3 as well.

4 There are a lot of suspicions and

5 rumors, but no facts of fraud at this time. It's

6 a concern because it affects confidence in the

7 organic label globally. We heard this morning

8 that the NOP is continuing to investigate this.

9 And I want to let the U.S. organic

10 community know that IFOAM Organics International

11 is participating in an anti-fraud workshop in the

12 Ukraine this September, where representatives

13 from around the world will be discussing this

14 topic. This is not solely a U.S. issue. I also

15 want to invite everyone to participate in the

16 19th IFOAM Organic World Congress in New Delhi,

17 India, this November.

18 Putting my OMRI hat back on, I invite

19 you to use OMRI as a resource regarding input

20 materials. We're the materials experts. We're

21 not the government, and we're here to help. 

22 Thank you.
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1 CHAIR CHAPMAN: Thank you. Any

2 questions for Peggy? Asa?

3 MEMBER BRADMAN: If this is going to

4 be addressed tomorrow, we could put it off, but I

5 wonder if you had any thoughts on the issues that

6 have been raised around inerts?

7 MS. MIARS: Any issues around inerts?

8 MEMBER BRADMAN: Raised around inerts?

9 MS. MIARS: I would defer that to

10 Johanna. She'll talk about that tomorrow or can

11 answer that tomorrow.

12 CHAIR CHAPMAN: Thank you very much,

13 Peggy. You gave us a minute back on our very

14 behind of schedule. Shannon Helms is up next,

15 followed by Nate Lewis, and after Nate will be

16 Alesia Bock.

17 MS. HELMS: I can probably give you a

18 few minutes back as well. Okay, sorry.

19 CHAIR CHAPMAN: If you could speak up

20 and also start with your name and affiliation for

21 the record.

22 MS. HELMS: Yes. My name is Shannon
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1 Helms. I am a global regulatory manager with CP

2 Kelco. I think some of my colleagues spoke to

3 you earlier about pectin, and I'm just here

4 really to fill in what was left off with that.

5 It's important for us to let you know

6 that the 21 CFR 150, 110, 140 and 160 list pectin

7 in a quantity which is reasonable to compensate

8 for deficiency, if any, of the natural pectin

9 content of the fruit ingredient. Therefore, we

10 feel pectin is essential in these foods, as does

11 the FDA.

12 And in my slides I've also listed --

13 go to the next one. You did it for me? Sorry,

14 thank you. Yes. So in my set of slides I've

15 also listed each of the individual 21 CFR 150,

16 110 as it pertains to fruit butter, 150, 140 as

17 it pertains to the different fruit jellies, as

18 well as 21 CFR 150, 160 as it pertains to fruit

19 preserves and jams.

20 I can read through all of those, but

21 you guys can see them yourselves as well. We

22 just really wanted to stress the imperative point
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1 that they are essential to these fruits, and they

2 are in the standard of identity. Okay?

3 CHAIR CHAPMAN: Thank you very much. 

4 Any questions? Thank you.

5 MS. HELMS: Thank you.

6 CHAIR CHAPMAN: Several short

7 speakers, really appreciate it. Up next is Nate

8 Lewis followed by Alesia Bock on deck and after

9 that's Nicholas Gardner. Nate, if you can start

10 with your name and affiliation for the record.

11 MR. LEWIS: Yes. My name is Nate

12 Lewis, foreign policy director with the Organic

13 Trade Association. I've been with OTA for about

14 three years. Prior to that, I was with

15 Washington State Department of Agriculture doing

16 organic certification.

17 I did inspections, certification work. 

18 I managed the brand new material list. I'm an

19 expert in residue sampling under the organic

20 regulations. So I want all the new board members

21 and existing ones to consider us a resource.

22 I want to bring your attention to an
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1 issue that's come to our attention, which is this

2 concept of bogoponics, where we've converted or

3 we've seen really high value peat bogs being

4 converted to hydroponic operations using BPA5 lined containers and bio-based biodegradable

6 mulch films.

7 I'm just joking, but I'm bringing this

8 to do my part in keeping satire alive these days,

9 so I'm not trying to make light of these things. 

10 These are very, very important things, but I

11 thought everyone could use a little humor at this

12 moment.

13 On hydroponics, OTA's historical

14 position has been to support the 2010

15 recommendation, which to remind you all defined

16 hydroponics, recommended prohibiting hydroponics

17 and provided strict guidelines around container

18 production and thereby allowing container

19 production. So that's our position. We

20 supported that then.

21 We haven't really seen a full proposal

22 come out to really support or not support on the
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1 issue recently, so that position hasn't changed. 

2 We provided written comments to you all on the

3 specifics in your discussion document. I hope

4 you took a look at them.

5 But, I think what we really need on

6 hydroponics, this whole issue, is to look for

7 areas of consensus and compromise. Without

8 consensus and compromise, we're not going to get

9 any further down the road.

10 And the status quo is going to remain,

11 which is the allowance of hydroponics, the

12 allowance of container production and a lack of

13 clear guidelines around how those operations

14 should be viewed under the organic regulations.

15 We also think that a scientific panel

16 or an expert panel could be of use, particularly

17 in the areas of agronomy, soil biology and

18 nutrient cycling. I keep hearing this idea that

19 liquid fish fertilizer is somehow a soluble

20 nutrient.

21 My understanding, again I have enough

22 soil science to be dangerous, but my
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1 understanding is it's not a soluble nutrient like

2 ammonium nitrate is. It still needs

3 mineralization, you still need biology. So I

4 think getting some clarity there, Mark, please

5 don't take my picture, I would -- okay.

6 And then I've also had some thoughts

7 on the fracking wastewater discussion, which kind

8 of ties into the residue sampling work that I've

9 done with Washington State, where I think it

10 could be a good first step there is to identify

11 the compounds in fracking wastewater which can be

12 tested and which may have some other federal

13 guidelines around health and safety.

14 Our ability to enforce regulations

15 using residue sampling, which certifiers are

16 allowed to do and must do hinges around the EPA

17 tolerances, which are another federal agency that

18 have to do human health and safety. So I'm happy

19 to discuss that a little bit further with folks

20 if you're still interested, but I think there's

21 some first steps we can be taking there.

22 CHAIR CHAPMAN: Than you, Nate. 
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1 Questions for Nate? I see Francis, Emily,

2 Harriet, Ashley, Steve, Joelle and Asa.

3 MEMBER THICKE: Well --

4 CHAIR CHAPMAN: Hold on. I need to

5 make a list. But we're going to stop you here, so

6 get on the list. 

7 MEMBER THICKE: Thank you, Nate. 

8 You're popular here.

9 MR. LEWIS: What's that?

10 MEMBER THICKE: You're going to be

11 popular here, looks like.

12 MR. LEWIS: Okay, I guess so, yes.

13 MEMBER THICKE: Say, in your written

14 comments you mentioned that the definition of

15 hydroponics should be amended to include the word

16 sterile. So that means that only sterile systems

17 would be called hydroponic.

18 And I'm wondering if that would -- I

19 can understand that you might start with a

20 sterile media. But then, when it's open to the

21 atmosphere

22 it's going to be, have -- it's going to be alive. 
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1 And I wonder if, by putting the word sterile in

2 there, it would be a way to define hydroponics

3 away, that wouldn't be any hydroponics because

4 nothing is sterile.

5 MR. LEWIS: Okay, that's a fair point,

6 right. I think we offered it partly because the

7 term bioponics had been removed, which, I think,

8 more accurately describes the types of systems

9 which are currently certified organic that fall

10 sort of in this gray area.

11 I mean, organic operations that are

12 currently certified at -- in a hydroponic sense

13 are substantively different from their

14 conventional counterparts in that they are

15 relying on biology to get those nutrients

16 available, right.

17 So the -- if you don't have the term

18 bioponics, it just becomes really complicated. 

19 And I think that the definitions still need a

20 little work to get consensus around.

21 CHAIR CHAPMAN: Emily?

22 MEMBER OAKLEY: I was just going to
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1 ask that you use the open docket to provide any

2 fracking comments or areas for the regulation

3 that you think we might work on then.

4 MR. LEWIS: Sure.

5 MEMBER OAKLEY: Thanks.

6 MR. LEWIS: I'd be happy to.

7 CHAIR CHAPMAN: Thank you. Harriet?

8 MEMBER BEHAR: Did you have anything

9 to say about biodegradeable bio-based mulch?

10 MR. LEWIS: Well, there aren't any

11 products on the market that can, that are, that

12 align with the current annotation. So just the

13 mechanics in my brain kind of think it's a little

14 bizarre to add something on the list that wasn't

15 actually petitioned to be added to the list.

16 So working on that issue and trying to

17 remedy it so that the annotation more accurately

18 reflects what actually was petitioned, I think is

19 an appropriate thing.

20 As far as the science about

21 biodegradability and all that kind of stuff,

22 absolutely outside of my wheelhouse.
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1 CHAIR CHAPMAN: Thank you. Ashley?

2 MEMBER SWAFFAR: So my question that

3 I keep asking everybody, is do you know what

4 percentage of organic vegetables, herbs, fruits

5 are grown in containers and hydroponics?

6 MR. LEWIS: No, and I think that's

7 largely due to the vagaries of the definition. 

8 It's hard to ask producers whether or not they're

9 growing hydroponically if we don't have a

10 definition for that term.

11 So what one person might consider

12 hydroponic, may not be but what -- something

13 else, to someone else. So I think that's a

14 challenging number to get to because of the

15 vagaries there.

16 CHAIR CHAPMAN: Steven?

17 MEMBER ELA: Where would you draw the

18 line between hydroponics and containers?

19 MR. LEWIS: I've done a lot of

20 thinking on that. It's challenging but I think

21 what, where I would draw the line is on what,

22 what's the matrix in which the biology lives. Is
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1 the biology that is ultimately cycling the

2 nutrients and bringing things to, making them

3 available to plants in suspension, in solution,

4 or is it living in a solid matrix?

5 And if it's living in a solid matrix,

6 like it is in a container production, you know,

7 2010 recommendation was that that should be

8 allowed, and we continue to think that that

9 should be allowed.

10 CHAIR CHAPMAN: Joelle?

11 MEMBER MOSSO: I'm curious to know

12 what your opinion would be on having an alternate

13 labeling for hydroponics. Should it remain

14 allowed?

15 MR. LEWIS: We had that brought up in

16 our task force as a potential area of compromise. 

17 With the proposals getting released with only

18 nine days to comment on them or get our

19 membership together, we weren't able to get to a

20 point where we could really take a position on

21 it.

22 But I think that's an example of an
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1 area of compromise that should be considered, or

2 at least talked about. And I am aware that

3 California Certified Organic Farmers came out in

4 support of that in their written comments. And

5 so I think that might be a good group to ask

6 about the thoughts there.

7 CHAIR CHAPMAN: Asa?

8 MEMBER BRADMAN: She kind of asked my

9 question. And I know I would like to hear more

10 about what proposals there are to compromise on

11 the hydroponic container issue.

12 And then also the comment earlier of

13 submitting more comments around fracking and

14 perhaps oil-produced water and, you know, ways to

15 approach that.

16 I'm interested in hearing more about

17 that and -- 

18 MR. LEWIS: Yes, I can briefly give

19 you just a rundown right now -- and I think --

20 MEMBER BRADMAN: Okay.

21 MR. LEWIS: -- it comes down to three

22 issues. First, you need to know what's in
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1 fracking water and what can be tested from an

2 accredited lab. That's a critical piece of, the

3 foundation of residue sampling.

4 Without a threshold that is

5 established by a federal other agency like FDA or

6 EPA around acceptable limits on that, it's hard

7 to take compliance action or say products can't

8 be on or off the market.

9 So doing a research on, you know, what

10 those identifiable compounds may have other, you

11 know, whether they have other federal oversight. 

12 And then it would probably require an amendment

13 to the regulations to, you know, give authority

14 to exclude products from market that exceeded

15 those requirements.

16 CHAIR CHAPMAN: Thank you. Thank you,

17 Nate.

18 MR. LEWIS: All right, thanks.

19 CHAIR CHAPMAN: I'd like to make a

20 note here that we had asked members of the public

21 to refrain -- yes, you're done, Nate -- to

22 refrain from interrupting or distracting speakers
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1 in the use of media. So I'd just like to remind

2 the public of that. If you are going to be using

3 your media, please give public speakers

4 sufficient space to be able to continue their

5 public comment without distraction.

6 Up next, we have Alesia Bock with

7 Nicholas Gardner on deck and Isaura Andaluz after

8 that. Sorry, if I butchered that.

9 Alesia, if you'd start with your name

10 and affiliation for the record.

11 MS. BOCK: Okay. Hello, my name is

12 Alesia Bock with AgriSystems International and

13 I'm here on behalf of our clients who are

14 certified entities across several processing, as

15 well as handling and growing categories, such as

16 coffee, juices, meat, dairy, cheese, greenhouses

17 and farms. We are here to comment on behalf of

18 our clients for Sunset 2019 materials for the

19 national list. So thank you for the opportunity

20 to speak today.

21 In essence of time, many of the

22 materials on the list for the handler of Sunsets
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1 have written comments already submitted through

2 the OTA member surveys to NOSB.

3 We are in support that those materials

4 remain on the list for the reasons given: Due to

5 essentiality, lack of organic alternatives, or

6 having been through several years of Sunset cycle

7 review.

8 Specifically, our clients support

9 relisting the following handling materials: 

10 Bentonite, diatomaceous earth, sodium carbonate,

11 nitrogen, carbon dioxide, magnesium chloride,

12 sodium phosphates, pectin, and potassium acid

13 tartrate.

14 These are critical processing agent

15 ingredients for our clients where no alternatives

16 are available or not consistently in use. We

17 support that casings also remain on the list

18 because the organic meat industry supply is

19 small, as you heard earlier, and organic casing

20 options are not yet widely available.

21 In reference to chlorine materials and

22 acidified sodium chlorite, we have specific
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1 feedback on these as critical parts of food

2 safety toolboxes for handlers and growers.

3 ASC or acidified sodium chloride is a

4 processing aid that controls microbes on the

5 surfaces of meat, poultry, seafood, and produce -

6 - thoroughly tested and necessary to prevent some

7 of the most pathogenic organism from making

8 people sick, such as E. coli, Salmonella,

9 Listeria.

10 Over 36 major processors use ASC with

11 citric acid to treat their organic products. 

12 This is a critical food safety regulation tool,

13 especially in regards to produce safety.

14 Regarding chlorine materials on the

15 Sunset list, this goes across handler, crops, and

16 livestock. I cannot reiterate enough how

17 critical and effective these materials are for

18 sanitation of equipment for organic producers.

19 There needs to be a large enough food

20 safety toolbox to minimize the likelihood that

21 microbials will become resistant or have

22 superbugs. Consumers are counting on safe food
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1 and organic food safety recalls tarnish the

2 entire industry and erode consumer confidence.

3 Finally, on Crop Sunset 2019 list, we

4 have support for keeping the following items on

5 the list. Herbicide, soap-based allow the safe

6 control of weeds around facilities.

7 Sticky traps are critical to monitor

8 and trap pests which reduces the need to apply

9 further organic pesticides. Boric acid is a more

10 benign pest control material than many others in

11 use. Fixed copper is in several fungicides that

12 are used as safe options against leaf and stem

13 diseases. Thank you.

14 CHAIR CHAPMAN: Thank you very much. 

15 Questions? Thank you very much. Up next is

16 Nicholas Gardner, following that is Isaura

17 Andaluz on deck.

18 Nicholas, if you could start with your

19 name and affiliation for the record.

20 MR. GARDNER: Good afternoon. My name

21 is Nick Gardner and I'm the manager of Regularity

22 Affairs for the International Food Additives
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1 Council or IFAC. IFAC is a global association

2 representing manufacturers of food ingredients

3 including a number of additives allowed in

4 organic foods and beverages.

5 IFAC supports the relisting of

6 non-amidated pectin, konjac flour, and sodium

7 phosphates. Non-amidated pectin is used to

8 thicken and gel organic products, particularly

9 jams and jellies, as well as fruit fillings

10 commonly found in baked good. No suitable

11 alternatives exist and organic pectin is not

12 available.

13 Delisting pectin would impact the

14 availability and variety of organic products on

15 the market. Sodium phosphates are also essential

16 for organic production of certain organic dairy

17 products, particularly shelf-stable cheese

18 powders and cheese sauces.

19 We note and support the comments from

20 several organic producers that indicate the

21 essentiality of sodium phosphates. Phosphates

22 are among the most useful and functional food
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1 ingredients in the world. Phosphates, including

2 sodium phosphates, have been determined to be

3 safe by regulatory authorities around the world

4 and are used in multiple conventional and organic

5 foods.

6 Alternatives simply cannot compare in

7 many applications. IFAC was disappointed to see

8 continued references in the spring meeting

9 materials to the 2016 technical report on

10 phosphates despite the errors and concerns that

11 we identified with TR in our fall 2016 written

12 and oral comments.

13 Many of the assertions made about the

14 safety of phosphates in the TR are not supported

15 by the majority of scientific literature on the

16 topic. Phosphates additives do not increase

17 serum phosphorus more so than naturally occurring

18 phosphorus.

19 IFAC also objects to TR claims that

20 elevated serum phosphates contributes to the

21 development of renal and vascular disease in the

22 general population. Furthermore, many of the
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1 selected studies in TR are observational without

2 measured control of intakes of phosphate

3 additives.

4 Under basic scientific principles,

5 observational studies, at best, can only support

6 correlation not causation. I'll note the Cato

7 report that we have submitted with our comments

8 to the written record. That report was a

9 literature review commissioned by IFAC conducted

10 by the clinical research experts at Cato.

11 They looked at 110 articles about

12 phosphate and potential health impacts compared

13 to 30 by the TR. Cato found that scientific

14 evidence does not support a conclusion that

15 consumption of phosphates results in negative

16 health impacts for the general population.

17 Cato also confirmed that the phosphate

18 additives do not have an accumulative effect on

19 healthy populations and do not contribute to a

20 higher phosphorus load. Thank you.

21 CHAIR CHAPMAN: Thank you. Any

22 questions? Steve?
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1 MEMBER ELA: You mentioned you're in

2 favor of relisting konjac flour given that there

3 are organic forms available. Why should we

4 relist it?

5 MR. GARDNER: Yes, so with konjac, one

6 of the things that we've heard is issues with

7 consistency and availability of organic supply. 

8 There are probably others here who are organic

9 formulators who could provide a better statement

10 on that, but based upon our survey is it's been

11 inconsistency and quality issues.

12 Having it on the national list for

13 another five years perhaps would allow that

14 supply to catch up. You know, certainly

15 documenting the concern in the transcript of this

16 meeting may help suppliers catch up with the

17 demand.

18 CHAIR CHAPMAN: Dan and Scott, and

19 then I have a question, and we'll cut if off

20 there.

21 MEMBER SEITZ: I think I read a

22 reference to konjac flour that it is a GE crop as
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1 well, and I'm wondering if you're aware of that

2 and how do people source their konjac flour to

3 make sure it is not genetically modified?

4 MR. GARDNER: Yeah, actually to the

5 best of my knowledge, it is not a GE crop. I'm

6 certainly happy to look into that, but I am not

7 aware of a GE source of konjac.

8 CHAIR CHAPMAN: Scott?

9 MEMBER RICE: If I could just ask to

10 get more specific data on what the issues in the

11 supply and the quality are, that would be helpful

12 in our decision-making.

13 MR. GARDNER: Sure. Absolutely.

14 CHAIR CHAPMAN: And then my notes

15 about the Cato study. I know it's not available

16 in its entirety. If that was able to be made

17 available between now and the fall meeting in its

18 entirety?

19 MR. GARDNER: Yes. Tom, I -- I think

20 the timing will work out for the fall. You know

21 that the difficulty is getting it through the

22 peer review process and getting it published. 
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1 That is ongoing.

2 It was ongoing actually in the fall as

3 well. We fully intend to submit that with our

4 comments in the fall, assuming it's available,

5 and we're doing everything we can to get it for

6 you all.

7 CHAIR CHAPMAN: Okay. Thank you very

8 much.

9 MR. GARDNER: Thank you.

10 CHAIR CHAPMAN: We'll move on to our

11 next speaker which is Isaura and on deck is

12 Lauren Stansbury. 

13 Isaura, if you could start with your name

14 and affiliation for the record.

15 MS. ANDALUZ: Isaura Andaluz, with

16 Cuatro Puertas in New Mexico. We are working to

17 revive originally Adaptive Seeds in New Mexico. 

18 I also sit on the board of OSGATA and the Organic

19 Farmers Association steering committee. My

20 comments today regard the strengthening of the

21 organic seed guidance.

22 We appreciate the efforts NOSB has
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1 taken to improve this guidance, yet at what point

2 do we all come together and protect the integrity

3 of organics?

4 Organic seed is the basis of organic

5 production. The growth of organics has not been

6 reflected in organic seed production due to the

7 continuous exemptions by the NOP for the use of

8 commercially produced seed.

9 Ironically, this endless loophole and

10 the lack of standards for seed purity has put the

11 organic market at risk. Organic consumers know. 

12 They, like I, want organic products free of

13 pesticides and GE contaminates. If at-risk crops

14 can no longer be considered organic because of

15 uncontrolled contamination, then the facts need

16 to be reflected in the market.

17 The U.S. is unable to meet the demand

18 for organic integrity due to the allowed

19 practices of GE farmers. Continuous usage of

20 contaminated seed can only increase the amount of

21 contamination.

22 Split operations exacerbate this. 
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1 Cuatro Puertas and OSGATA advocate that organic

2 seeds should have a non-detectable genetic

3 engineer contamination. Many farmers fear this

4 because of the history of cost and the burden put

5 on them. When I asked Secretary Vilsack twice,

6 who would pay for the tests with contaminated

7 corn, which is a staple and sacred food crop in

8 New Mexico, he never responded.

9 The polluter should pay not the

10 contaminated farmer. The polluter must contain

11 their technology. The last round of AC-21

12 committee, which I sat on, resulted in voluntary

13 guidelines that would be implemented at the state

14 level -- identity-preserved crops are to be

15 protected by the farmer. So everything becomes

16 identity-preserved except for GE.

17 If this scenario becomes a reality,

18 the burden would fall on more than the organic

19 farmer. Two recommendations that I have for this

20 committee is that they should follow up on what

21 was left over from the past administration. One,

22 assess availability of organic and non-GE seed
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1 varieties nationally, especially within the

2 adapted seeds and, two, to implement protocol

3 created by the National Germplasm collection to

4 protect the collection from GE contamination. 

5 This is essential.

6 There's not a person, a corporation,

7 or a government that created a seed. If money is

8 what runs NOSB and the USDA, then the term

9 certified organic will be short-lived. You can

10 plant seeds but you cannot plant money. Thank

11 you.

12 CHAIR CHAPMAN: Thank you. Any

13 questions? Thank you very much. Up next is

14 Lauren Stansbury and on deck is Zareb Herman.

15 Lauren, if you could start with your

16 name and affiliation for the record.

17 MS. STANSBURY: Yes, hello. I'm a

18 little bit hoarse, but hello organic community. 

19 I am Lauren Stansbury. I'm the Communications

20 Director for the Hemp Industries Association. 

21 Thank you dearly for the opportunity today to

22 explain why industrial hemp grown in the United
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1 States should be eligible for organic

2 certification.

3 Let us firstly agree on this point,

4 organic farming is the future. The current

5 schema of industrial chemical agriculture will

6 not deliver us to a promise land of food

7 security, fresh water, or healthy soil.

8 And, increasingly, the American public

9 realizes this. This is evident in the tremendous

10 growth in the organic sector since the

11 establishment of the NOP in 2000. Our mutual

12 friends at the Organic Trade Association cite

13 2015 growth have combined organic food and body

14 care sales at 11 percent over the previous year.

15 Did you know that concurrently growth

16 rate for retail sales of natural and organic hemp

17 and hemp food and hemp body care products

18 exceeded 11 percent. Organic hemp clearly also

19 has a bright future. But excluding certain parts

20 of the hemp plant from organic certification

21 wrongfully threatens this growth.

22 The whole plant, in its entirety from
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1 root to flower, is defined as distinct for

2 marijuana. The definition of hemp is a matter of

3 a modicum of THC content. It is not certain parts

4 of the hemp plant that are distinguished from

5 marijuana but rather hemp as a whole.

6 Excluding components of hemp that are

7 not fiber or oil seed, such as flowers, roots,

8 sprouts and leaves from the NOP, impedes growth

9 not only of the hemp industry but of the organic

10 market as a whole.

11 The statement of principles

12 responsible for influencing this decision to

13 exclude parts of the hemp plant from organic

14 eligibility is not legally binding and indeed,

15 the HIA feels it constitutes agency over reach

16 that attempts to regulate hemp outside of and,

17 indeed, in contravention of congressional

18 directive.

19 And this overreach has the consequence

20 of excluding American farmers from the robust

21 economic opportunity this crop offers in its most

22 lucrative form which is as an organic product.
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1 May it be clearly understood that the

2 DEA nor any federal agency has any regulatory

3 authority over industrial hemp cultivation, the

4 manufacturing or sale or consumption of hemp

5 product in the U.S.

6 Congress has made this unequivocally

7 clear, not only with the passage of Section 6706

8 of the Farm Bill but, furthermore, Congress has

9 prohibited use of federal funds for DEA or any

10 other federal agencies to inhibit hemp

11 cultivation per the Appropriations Act of 2016.

12 Let the NOP see its own role not as a

13 sycophant to the DEA's botanically uninformed and

14 prejudiced bias against hemp, but rather let the

15 NOP consider how to nurture the growth of an

16 in-demand versatile lucrative and organic crop.

17 Ten more seconds, please. On behalf

18 of the Hemp Industries Association, on behalf of

19 American Consumers of Organic Hemp Products and

20 perhaps most importantly on behalf of the great

21 multitude of farmers who seek to nurture the

22 earth with organic stewardship and to provide
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1 their small family farms with this historic

2 American crop, we beseech you to support organic

3 certification of hemp and champion its inclusion

4 in the National Organics Program. Thank you.

5 CHAIR CHAPMAN: Thank you very much. 

6 Any questions? Thank you.

7 MS. STANSBURY: And actually, just one

8 more thing. One of your questions to my previous

9 colleagues about whether Canada has an organic

10 program, certification program for hemp --

11 CHAIR CHAPMAN: I'm sorry, I have to

12 cut you off there.

13 MS. STANSBURY: The USDA organic --

14 CHAIR CHAPMAN: I'm sorry. I have to

15 --

16 MS. STANSBURY: -- certification label

17 goes on to products that are created in Canada --

18 CHAIR CHAPMAN: I'm going to have to

19 cut you off there. Thank you for your time.

20 Zareb, you're up next. Tim Gordon

21 after that. Please come to the on-deck chair. 

22 Zareb, if you could start with your name and
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1 affiliation.

2 MR. HERMAN: Good afternoon, my name

3 is Zareb Herman. I am a nutritionist with the

4 Hain Celestial Group, one of the largest

5 producers of organic products in the world.

6 I'm commenting today primarily to

7 support the continued listing of sodium

8 phosphates and pectin on the national list. Some

9 of our organic snack chips and puffs are coated

10 with powdered organic cheese.

11 This powder cheese relies on disodium

12 phosphate to emulsify the oils in the cheese. 

13 Without it, the oil would separate and the cheese

14 would form clumps. This would prevent uniform

15 application and the oily defective product would

16 be unacceptable to consumers.

17 It is well known in the industry that

18 disodium phosphate stabilizes the proteins in the

19 cheese and prevents the oil separation. There

20 are no organic alternatives and there are no

21 other alternatives on the national list that work

22 in this particular application.
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1 Regarding concerns over the over

2 consumption of phosphates in the diet, added

3 phosphates in organic foods are minor

4 contributors to total phosphorus intake. As an

5 example, in our cheese snack products, I

6 calculated that the disodium phosphate

7 contributes between 12 and 18 milligrams of added

8 phosphorus per serving. This is less than 1

9 percent of the average person's daily intake of

10 phosphorus.

11 Move onto pectin. Pectin is a vital

12 thickener and stabilizer in some in some of our

13 organic bakery products. Specifically, our

14 fruit-filled organic bars. Pectin is necessary

15 because it is the only hydrocolloid that is

16 stable in acidic products like jams and jellies,

17 fruit yogurts and fruit-filled bakery products.

18 Organic pectin is not commercially

19 available and this includes the particular pectin

20 preparation that is required for our bakery

21 applications. Therefore, we need to keep pectin

22 on the national list until the necessary organic
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1 form becomes commercially available.

2 We support also the relisting of

3 bentonite and diatomaceous earth which we use to

4 filter impurities from our expelled or pressed

5 organic oils. We support the relisting of

6 magnesium chloride for organic tofu production

7 and, lastly and importantly, we support the

8 relisting of chlorine materials because they are

9 absolutely necessary to maintain food safety. 

10 Thank you.

11 CHAIR CHAPMAN: Thank you very much. 

12 Any questions? Thank you. Up next is Tim Gordon

13 followed by Albert Strauss.

14 Tim, if you can start with your name

15 and affiliation for the record.

16 MR. GORDON: Yes. Thank you. My name

17 is Tim Gordon. I am coming to you on behalf of

18 the Colorado Hemp Industries Association and hemp

19 farmers in this great state of Colorado.

20 And I'd like to talk with you

21 specifically, well first of all, I would also

22 like to thank you guys for going through your
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1 break and related hearing and giving us solid

2 attention. That's admirable of you. Thank you

3 very much.

4 I'll get right to the point, the

5 recent statement of principles issued by the USDA

6 in regards to industrial hemp, and I can even go

7 through that for you. You've heard my colleagues

8 previously. 

9 It states this. The term industrial

10 hemp plant includes Cannabis sativa L. and any

11 part or derivative of such plant including seeds

12 and any such other part of derivative whether

13 growing or not. It is used exclusively for

14 industrial purposes of fiber and seed with

15 tetrahydrocannabinol concentration of no more

16 than 0.3 percent on dry weight basis.

17 The term tetrahydrocannabinol includes

18 isomer salts, salts of isomers, and

19 tetrahydrocannabinoids. The statement of

20 principle is completely off with the Federal Farm

21 Bill Section 706. 

22 The statement of principles, like this
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1 where we have seen, you know, large scale

2 ramifications really slow an industry's progress.

3 To my understanding, in order to change a federal

4 law like 7606, you need congressional approval

5 and this was not sought.

6 I encourage the NOSB to go back to the

7 USDA and the NOP program and make them aware of

8 Section 7606, that all parts are able to be

9 certified organic under Law 7606 of the Federal

10 Farm Bill. I thank you for your time.

11 CHAIR CHAPMAN: Okay. Thank you very

12 much. Any questions? Thank you very much for

13 your testimony.

14 Up next is Albert Straus, followed by

15 Gail Nelson. Albert, if you can start with your

16 name and association.

17 MR. STRAUS: Yes. Hi, I'm Albert

18 Straus from Straus Family Creamery. We were the

19 first certified organic dairy and creamery west

20 of the Mississippi River, in the beginning, in

21 1994. Now we have nine farms supplying our cream

22 -- we're in northern, California, excuse me.
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1 And now we have nine organic dairy

2 farms supplying our creamery. They're all non-GMO

3 verified. We test every load of feed for GMOs

4 and have a specific analysis on every load. 

5 Ninety percent of the dairies, close to 90

6 percent of the dairies in Marin and Sonoma County

7 are certified organic.

8 And we've really made a huge progress

9 for showing that dairy farms and farms, livestock

10 farms, are actually part of the solution to

11 climate change through methane digesters and

12 carbonate farming.

13 There is a -- I want to talk about the

14 risk to -- we've seen a flattening of our sales

15 in organic dairy, a flattening or declining

16 sales. At the same time, I'm bringing on more

17 dairies anticipating a higher production. And

18 we're also seeing a lot of extra label claims

19 that say the consumers are confused, that they

20 think they're as good as organic or better.

21 There's a study that just came out

22 from the University of Illinois today saying that
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1 people prefer -- the claims of no growth hormones

2 actually is more important than organic. So I

3 want to talk about organic as the gold standard

4 and all these claims that are -- talk about one

5 aspect of organic.

6 And we need to kind of work as a

7 community to educate our consumers and also to --

8 I would like to get recommendations from the

9 Board to the USDA to start regulating some of

10 these extra label claims because it's really

11 important that we hold organic as the gold

12 standard in our industry and in our communities. 

13 Thank you.

14 CHAIR CHAPMAN: Thank you, Albert. 

15 Any questions? All right, so Dan first, Harriet,

16 Emily, David, and we'll cut if off there for a

17 second time. Go ahead, Dan.

18 MEMBER SEITZ: Are these other labels

19 that you find with various claims, is there a,

20 some sort of strict regulatory process or can

21 anyone create a label and in essence make a claim

22 without there necessarily being a regulatory
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1 process backing it up?

2 MR. STRAUS: There's, I'm just going

3 through the process, like there's a lot of, now

4 organic dairies that are labeling 100 percent

5 grass fed, yet the animal was -- American Grass

6 Fed Association standards, it's not 100 percent

7 grass fed. Consumers think that the cows are in

8 pasture year-round. It's not accurate. So

9 accuracy in labeling is something that I'm

10 concerned with and I think there are regulations

11 on that.

12 I think the other parts are

13 perception. Like non-GMO, where there's actually

14 thresholds that are pretty high on, at least,

15 organic feeds, or, yes, organic feeds, there's a

16 5 percent threshold from the non-GMO project.

17 I think consumers are confused by what

18 these labels mean and that they're better or mean

19 as much as organic means, and it's only a part of

20 what organic is.

21 Animal welfare, I mean, some kind of

22 thing. So there are different certifications and
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1 things, but I think they're trying to say that

2 they're better or as good or better as organic.

3 CHAIR CHAPMAN: Thank you. Harriet?

4 MEMBER BEHAR: Hi, Albert. I know

5 that you have a very loyal following of

6 customers, but do you feel that perhaps you've

7 peaked in your customer base or, or why do you

8 think there's -- you know we have been growing

9 just exponentially in organic dairy year after

10 year. Where would you say -- you think it's a

11 labeling, that the people are confused or --

12 MR. STRAUS: I think it's a

13 combination. 

14 MEMBER BEHAR: -- you're not sure?

15 MR. STRAUS: Personally, I think it's

16 a combination of things. Between plant-based

17 milks, a lot of other label claims like grass

18 fed, non-GMO, consumers don't know.

19 There's -- I have people working for

20 me that don't know that tangerines are, that say

21 non-GMO, are not organic. So there's a lot of

22 confusion out there. And we're going out talking
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1 about this, this is what we developed. And we're

2 going to start talking more to our consumers,

3 talking more to our retailers, and everybody

4 about organic values and what it brings.

5 CHAIR CHAPMAN: Thank you. Emily?

6 MEMBER OAKLEY: I agree that consumer

7 confusion is very problematic and I'm wondering,

8 Miles, is there anything that the USDA can do in

9 the absence of the word organic being used in

10 these label claims?

11 MR. MCEVOY: Well, yes, there's a

12 diversity of regulations that oversee these

13 labels, right. So you have FDA has a truth in

14 labeling concept that they would want the labels

15 to be truthful. FSIS has oversight over meat

16 labels. There's a variety of different regulatory

17 authorities that have authority over labels, but

18 many labels making claims, as long as they're

19 truthful claims, are not specifically either

20 certified or regulated by a standard.

21 There's also standards that industry

22 has developed that can then get verified through
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1 USDA programs. For instance, the Agricultural

2 Marketing Service Process Verified Program has

3 various programs to accredit a process verified

4 claim. So there's companies that have non-GMO

5 claims that are verified through the Process

6 Verified Program.

7 There is -- the Organic Trade

8 Association has a program for transitional

9 certification that is currently under review from

10 some legal challenges to the ability for us to

11 verify that through the Quality System Management

12 Program. So there's a variety of different

13 possible tools, but organic has a clear statutory

14 and regulatory standard that is kind of somewhat

15 unique to other labeling programs.

16 CHAIR CHAPMAN: Dave.

17 MEMBER MORTENSEN: Yes, I love your

18 graphic because I think your graphic underscores

19 the market advantage of organic and I think the

20 task that in farming and the NOSB has in taking a

21 systems perspective on assessing any of the

22 changes of the kinds of things that we've been
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1 talking most all of the day today, so I really

2 appreciate the graphic.

3 MR. STRAUS: Thank you.

4 MEMBER MORTENSEN: I also, having

5 spent a lot of time in my previous, before NOSB,

6 life, I think we're not telling a very good story

7 from a marketing point of view about what, for

8 example, GMO crop production means. For example,

9 that we're increasing pesticide use to the tune

10 of something like 120 million pounds per year on

11 the backs of that technology.

12 So I think the labeling is really

13 problematic in lots of different ways and we

14 should do a better job marketing what it is that

15 we're selling, which is a system, and I like your

16 approach to describing the system.

17 MR. STRAUS: Thank you.

18 CHAIR CHAPMAN: Thank you very much. 

19 Thank you, Albert. Up next is Gail Nelson

20 followed by Greg Cunningham on deck.

21 Gail, if you could start with your

22 name and affiliation for your record.
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1 MS. NELSON: Yes. My name is Gail

2 Nelson. I'm with G&G Connections. We put people

3 in projects together with an emphasis on

4 hydroponic markets, both here and abroad.

5 Sometimes we have to get out of our

6 comfort zone and not be afraid to change as we

7 are an evolutionary civilization. We are also

8 improving our technology to be more efficient and

9 to satisfy the customer, and we cannot hold back

10 progress for long.

11 The naysayers said that the earth was

12 flat before explorers proved otherwise. People

13 were afraid to change from the horse and buggy to

14 the Model T, a revolutionary intervention.

15 Now we have cars that can park

16 themselves. We've gone from a phone on the wall,

17 to a phone on our wrist. Organic farming

18 technology has not been left behind in this world

19 of evolution. We've gone from plowing fields

20 with horses to new efficient methods of growing

21 organic crops.

22 You've heard today that traditional
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1 organic farming in soil has a high-risk of crop

2 contamination, and weed and insect control is

3 difficult. It cannot always be grown locally and

4 it takes up large acres of land while usable land

5 and fresh water is decreasing.

6 As our population grows, so does our

7 need for more organic food. The consumer's

8 demanding chemical-free, healthy, nutritious, and

9 environmental friendly produced food.

10 Traditional organic farmers cannot

11 meet this demand on their own and increased

12 shortages are already being felt in the organic

13 marketplace. Hydro-organic growing fits the

14 criteria and the demands of the consumer. It

15 also fits the criteria of organic with organic

16 inputs and practices while avoiding synthetic and

17 harmful chemicals.

18 There are benefits to growing in soil,

19 but soil is a medium to hold the roots of the

20 plant, and it is difficult to maintain at the

21 organic level. Yes, it has biological activity

22 in the root zone of soil-grown plants, but this
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1 activity also takes place in hydroponically grown

2 plants with organic inputs.

3 We know that this type of

4 hydro-organic growing is chemical-free, is

5 healthy, and nutritious. It is earth friendly,

6 respecting, conserving, and preserving land and

7 water. Therefore, it is environmentally resource

8 sufficient.

9 We need to embrace CEA as an

10 organic-growing method made possible because of

11 innovations and technology. Hydro-organic

12 farming has taken organic farming to a higher,

13 safer standard.

14 We have made great strides in

15 eliminating the contamination aspects of organic

16 farming. The term organic is a very effective

17 marketing tool and has become a household brand. 

18 Hydro-organic growing can deliver the

19 needs of the consumer. I urge you to recommend

20 the hydro-organic farming certification to

21 continue with added guidelines for hydro-organic

22 growing just as there are guidelines for organic
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1 soil growing. Thank you.

2 CHAIR CHAPMAN: Thank you. Any

3 questions? Thank you very much.

4 CHAIR CHAPMAN: Up next is Greg

5 Cunningham, followed by Phil LaRocca.

6 MR. CUNNINGHAM: Hello. Greg

7 Cunningham from the Scotts Company. Thanks for

8 this forum. Yesterday's hydroponics is different

9 than today's hydroponics which will be different

10 than tomorrow's hydroponics.

11 We would ask that the NOSB Board to

12 keep an open mind when evaluating the future of

13 hydroponics and container growing by allowing the

14 USDA, accredited certifying agents, to continue

15 to evaluate each individual operation for its

16 consistency with the NOP rather than implementing

17 a blanket ban on these operations.

18 With today's agriculture becoming even

19 more attuned to water conservation, reduction of

20 pesticide use, pathogens, and GMOs, banning

21 hydroponics for organics use is counterintuitive.

22 Hydroponics is known to reduce
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1 inadvertent environmental contamination such as

2 pesticide spray drift, increased pathogen levels

3 from flooding or contact with wildlife and GMO

4 contamination from nearby fields.

5 Hydroponics allows the farmer to

6 ensure every input to the plant as a USDA and NOP

7 allowed substance. As the world's population

8 grows and land that is suitable for agriculture

9 shrinks, the need for evolving agriculture

10 including farming on urban and less than ideal

11 land will continue to be of the utmost

12 importance.

13 We ask that you do not shut out the

14 growth and availability of organic food for

15 future generations. The Scotts Company would be

16 happy to assist the NOSB Board with items such as

17 consumer insights in research and development in

18 order to support the NOSB Board in their further

19 discussion and decisions on the future of

20 hydroponics and container growing. Thank you.

21 CHAIR CHAPMAN: Thank you very much. 

22 Any questions? Emily, Scott.
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1 MEMBER OAKLEY: Thank you. Do you

2 have any products that the Scotts Company is

3 selling to hydroponic growers currently?

4 MR. CUNNINGHAM: We have some hybrid

5 hydroponic products, we have some synthetics, and

6 we have a few organic, like OMRI-listed

7 hydroponic liquids, and a couple of solids,

8 actually. So, a lot of the products are solid or

9 liquids.

10 And I hear water-soluble a lot, but

11 the water-soluble does not mean it's water

12 soluble or readily available. It actually still

13 needs to be converted to a plant available form. 

14 So even in a hydroponics or a container system,

15 that water-soluble has to be converted, to my

16 understanding, to a urea or ammonium nitrogen.

17 MEMBER OAKLEY: Could you provide us

18 with some product lists and the materials within

19 them that you are currently selling to organic

20 hydroponic growers?

21 MR. CUNNINGHAM: Yes, so, our organic

22 hydroponic base is not huge, very small, but we
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1 do have, as far as for orienting growers, we are

2 mainly, we have some retail options that we can

3 give you, some formulas and products, yes.

4 CHAIR CHAPMAN: Okay. Thank you very

5 much.

6 MR. CUNNINGHAM: Thanks.

7 CHAIR CHAPMAN: Up next is Phil

8 LaRocca, followed by --

9 MR. CUNNINGHAM: I'm sorry. Does she

10 have a question?

11 CHAIR CHAPMAN: I'm sorry. Can you

12 come back up? We had a question I missed. My

13 apologies. Sue?

14 MEMBER BAIRD: Yes. I thought I heard

15 you say that you have a synopsis of consumer

16 education and preferences for hydroponics. And

17 that would be very helpful if we can have that.

18 MR. CUNNINGHAM: So we don't have

19 that.

20 MEMBER BAIRD: Oh.

21 MR. CUNNIGHAM: But we're more than

22 happy to work with the Board on generating that
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1 data. We'd be more than happy to work with you

2 guys in developing a protocol or a statistical

3 analysis that you guys would find valuable. I

4 mean, we're more than happy to work with you

5 guys.

6 MEMBER BAIRD: I think that would very

7 valuable to know what the consumers are actually

8 perceiving, if its organic or not.

9 MR. CUNNINGHAM: Correct. I agree

10 that we're worried about the integrity of the

11 seal, but do we actually know what the consumer

12 feels --

13 MEMBER BAIRD: Right.

14 MR. CUNNINGHAM: -- the seal means. 

15 So, we'd be more than happy to work with you

16 guys.

17 MEMBER BAIRD: Thank you.

18 CHAIR CHAPMAN: Thank you.

19 MR. CUNNINGHAM: Thanks.

20 CHAIR CHAPMAN: My apologies. Phil

21 LaRocca up next. After that's Kelly Damewood. 

22 Phil, if you could start with your name and
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1 affiliation.

2 MR. LAROCCA: I will try to be as

3 concise as possible. I know everybody's got to

4 be tired. My name is Phil LaRocca. I am the

5 owner and winemaker of LaRocca Vineyards. I'm

6 also the chairman of the board of directors for

7 CCOF, the California Certified Organic Farmers.

8 I have been an organic farmer for 44

9 years. I was first certified back in 1975, and I

10 can honestly say, I've probably spent about half

11 my life in building soil. And I had this concept

12 that when I got older, which I am now, that I

13 would have this rich soil that my plants would

14 love, and it would cut my work down.

15 Well, my plants love it. I did create

16 a rich soil, however, hasn't cut my work down. 

17 We still compost and green manure our fields. 

18 With that said, I'm speaking here in favor of

19 organic hydroponics with two caveats.

20 One, we should create standards that

21 are strict with a hundred percent organic inputs

22 and two, that we should label it. Most of the
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1 growers that I know have no problem in saying

2 that. Prior to me speaking, there were several

3 colleagues of mine that have spoken against

4 hydroponics. A lot of them are friends of mine,

5 I respect them, I know they're good farmers.

6 With that said, we have a 120

7 certified farms at CCOF. And out of those

8 growers, I have several friends that I respect as

9 farmers and I respect as friends, and I know the

10 hard work that they have done to build a small

11 farm and a small business.

12 Now whether the USDA made a mistake or

13 not by certifying hydroponics, it would be so

14 unjust to pull the rug out of these people that

15 have worked so hard to create a very successful

16 business. And they have not complained about

17 strict standards. A lot of them will say give us

18 the strictest standards you can and we'll label

19 it. We have no problem.

20 Let the organic consumer decide. 

21 Sometimes we have tendency, as a group here, to

22 negate the concept and the consciousness of
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1 organic consumer. I also have a tasting room and

2 in my tasting room, we only serve my wine which

3 is organic and we serve food. Everything that we

4 serve is certified organic.

5 So we ran a little bit a poll. We do

6 have people that come in just to taste wine but

7 the majority, especially my regulars, are organic

8 consumers, organic conscious. We asked them what

9 they thought organic meant. A hundred percent

10 said no chemicals in the food and the second

11 thing that they said is, my God, if you say it's

12 organic, it better be organic.

13 So for these hydroponic people, create

14 strict standards, have them label it and let the

15 consumer decide. Thank you.

16 CHAIR CHAPMAN: Any questions for

17 Phil? I see Francis.

18 MEMBER THICKE: Quick question. I

19 understand your concern about your friends who

20 have a hydroponic operation and you don't want to

21 see them lose it. 

22 The question for you is, do you think that
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1 if hydroponics becomes accepted, that there will

2 be more and more and more and maybe 80 to 90

3 percent of the produce in California will become

4 hydroponic? And is that of concern to you?

5 MR. LAROCCA: It is not, and I'll tell

6 you why. I am an organic consumer, and I have a

7 pretty good lineage. If I'm in the store, and my

8 kids have testified to this, if I have a choice

9 between the tomato grown in soil or a tomato

10 grown in hydroponic, I'd probably take the soil

11 because I've been a soil farmer.

12 But if I go into the store and there's

13 a conventional tomato and a certified organic

14 hydroponic tomato, I'll pick the hydroponic

15 tomato in a heartbeat.

16 And we have growers that were -- some

17 of them have been certified for 11 years. So,

18 they have their market. And in that 11-year

19 period, I don't really see, at least in

20 California, that there's have been any

21 competition, but you now, if anybody should

22 complain about competition, it's me.
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1 I mean, we, I'm in California. We

2 have a minimum wage of $15 an hour. I have to

3 deal with organic wines coming in from Chile

4 where they're paying $10 a day for their labor,

5 you know.

6 I can't even produce a wine for what

7 they're selling it per bottle. But you know,

8 this is an open market, market your product. Be

9 the best and market your product. So if people

10 think that tomatoes or whatever grown in soil is

11 better, than promote that and market that.

12 CHAIR CHAPMAN: Thank you. Sue?

13 MEMBER BAIRD: I'm sorry. Are you

14 promoting then that perhaps we create another

15 label so consumers would know that it's

16 hydroponic organic?

17 MR. LAROCCA: Sure. I don't have --

18 as long -- but most of the growers are very proud

19 that they have developed techniques that are a

20 hundred percent organic. So they do want that

21 organic in the label.

22 MEMBER BAIRD: Okay. Thank you.
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1 MR. LAROCCA: You're welcome.

2 CHAIR CHAPMAN: Thank you. Next up is

3 Kelly, followed by Tina Ellor. Kelly, can you

4 start with your name and affiliation for the

5 record?

6 MS. DAMEWOOD: Okay. Thank you. My

7 name is Kelly Damewood with CCOF, California

8 Certified Organic Farmers. We certify and

9 advocate on behalf of organic producers

10 throughout the U.S., majority in California.

11 I'd be happy to answer questions about

12 produce water in California. We have looked at

13 this issue and continue to advocate that

14 California authorities adequately oversee the use

15 of this water. But today I'm going to focus on

16 hydroponics and encourage the NOSB to shift its

17 focus from what to exclude and focus on what to

18 require.

19 By only focusing on prohibition, we

20 are missing the opportunity to recommend clear

21 guidance and standards that ensure these unique

22 and evolving systems consistently implement
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1 organic principles.

2 No matter where you are on this issue,

3 nobody wants to see a producer just dumping

4 nutrients into water. So it's really time to get

5 detailed feedback from certifiers and producers

6 about what sets organic hydroponics apart from

7 their conventional counterparts.

8 And, as Phil noted, we would encourage

9 exploring options for labeling. It's going to be

10 challenging but perhaps it's a middle road, a

11 solution to move the issue forward.

12 So USDA Organic seal with the term

13 hydroponically grown on primary packing, for

14 example. You know, on one hand, it supports that

15 hydroponic grower who has built their business on

16 USDA Organic Certification while providing more

17 transparency and choice for the consumer.

18 And finally, I would urge the NOSB to

19 look at the big picture and consider that food

20 production has evolved since 1990 and is going to

21 continue to evolve. 

22 As a millennial, my generation has
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1 been number one consumer of organic product. And

2 I don't want to see a lot of competing labels

3 because I know they are not going to do as good a

4 job as USDA Certified Organic.

5 And it really seems that this is a

6 critical opportunity where we get to decide the

7 future of our movement. Are we going to be an

8 inclusive movement? An exclusive movement? Or

9 the movement to transform our food system? Thank

10 you.

11 CHAIR CHAPMAN: Thank you. Please

12 refrain from clapping. Emily and Steve.

13 MEMBER OAKLEY: I wanted to ask you

14 about something other than hydroponics, if that's

15 all right?

16 MS. DAMEWOOD: Sure.

17 MEMBER OAKLEY: About soil-based

18 herbicides. It seems that you have a number of

19 producers that are certified by CCOF using them.

20 But some of the public comments from

21 both farmers and others seem to indicate that

22 people are using it beyond the annotation for
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1 field production, perhaps in orchards and other

2 uses, and so I was wondering, if you're aware of

3 any of those off-annotation uses?

4 MS. DAMEWOOD: I'm not aware, but I

5 would be happy to look into it and follow up with

6 you.

7 CHAIR CHAPMAN: Steve.

8 MEMBER ELA: I'm curious. So since

9 1990, you know, organics have evolved, what you

10 just said. And since 1990, our understanding of

11 soil ecosystems has also evolved significantly. 

12 I mean, we always knew they were complex but I

13 think we're moving into where we, you know,

14 realize how much we don't know.

15 And so, in terms of hydroponics, I'm

16 curious, you know, we're manufacturing a system

17 and we're trying to rebuild an organic system

18 similar, you know, something like soils -- and

19 the regulations, you know, you mentioned soils a

20 number of times. How can we as smart humans,

21 recreate a system, hydroponically, that we don't

22 even understand, you know, as a soil and as a
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1 soil-based system?

2 MS. DAMEWOOD: If you're asking how --

3 I think it takes all types of production. I

4 mean, that's what we see in California. 

5 Hydroponic growers often have in-field production

6 too and are working with, to build soil health as

7 well.

8 I don't think it's about mirroring

9 soil so much as doing the best job possible with

10 inorganic principles for these types of systems. 

11 And that's why I'd encourage more detailed

12 comments directly from certifiers, organic

13 producers, about what practices are they using,

14 what is setting them apart from their

15 conventional counterparts.

16 And I think you will get to the core

17 answer of your question, but so far the

18 discussion documents we've been responding to

19 have been on how to be a lot of the defense of,

20 well, if we're going to broadly be prohibiting

21 these types of operations, then we're going to

22 miss the opportunity to consider just what you're
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1 asking. How do we ensure that any system bearing

2 the UDSA organic label is aligning with the

3 intent and principles of organic.

4 CHAIR CHAPMAN: Thank you. I'll take

5 it back to Emily and then we'll stop it there.

6 MEMBER OAKLEY: I think that's a good

7 point about asking for the inputs that are being

8 used in the systems. But, I feel when we've

9 asked some of those questions, we've been told

10 that it's proprietary information, and it's been

11 extremely difficult to find out what those

12 systems actually are. So I'm not sure how that

13 conversation would go forward, but I just wanted

14 to put that out there that it's not been easy to

15 get that information.

16 MS. DAMEWOOD: I would also say that

17 I think people are hesitant to put forth what

18 they're doing because of the uncertainty, where

19 it feels like they're being attacked and doing

20 something wrong. And I would be happy to work

21 with our producers to provide us much detail as

22 possible for next commenting.
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1 CHAIR CHAPMAN: Thank you. Up next is

2 Tina, followed by Jonah Beeken. Jonah, if could

3 come to the on-deck chair and Tina, if you can

4 start with your name and affiliation

5 MS. ELLOR: My name is Tina Ellor. 

6 I'm with Phillips. I'm a mycologist and

7 Technical Director of Phillips Mushroom Farms. 

8 And that's a hard act to follow. Well done.

9 Mostly, I'm a mushroom geek, for those

10 who don't know me. There're some up here who do.

11 We've been growing certified organic mushrooms in

12 the mushroom capital of the world, certified by

13 the best certifier. I got to put that in because

14 I heard some of you say that today, PCO, since

15 1997, so 20 years now.

16 Welcome NOSB members, new ones,

17 veterans. I've been at this podium any number of

18 times and this just looks like a great group of

19 people to work with, and thank you so much. I

20 did sit in that seat at one time, and I have some

21 idea of how difficult it is, but in a universe

22 zooming towards complexity, I think your job is
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1 on the fast track.

2 I did submit written comments with

3 answers to questions that you put out

4 specifically, so I'm not going to talk about that

5 too much. I want to put in a word for some

6 materials that we would like to see remain on the

7 list. We would like chlorine materials to remain

8 on the list, please. Where possible, we

9 substitute hydrogen peroxide. That's not always

10 possible or safe as it's not as stable.

11 We absolutely depend on sticky traps

12 as part of our integrated pest management. We'd

13 like to see humic acid stay on the list because

14 they help keep our mushroom culture strong and

15 happy, and this helps them resist diseases and

16 pests.

17 I would like to see boric acid remain

18 on the list as sometimes we have, recalcitrant,

19 if I could borrow your word, cockroach problems

20 in our breezeways, and that's a good alternative

21 to, you know, some -- when all else fails, we

22 would like to keep that in our toolbox.
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1 I'm going to zoom past, soil is

2 agriculture, because I really wish you wouldn't

3 call it that. There's a lot of great things

4 including mushrooms that don't grow on soil.

5 Now, I realize that we are not

6 excluded by the definition, but because of my

7 perspective of a mushroom geek and all that it

8 implies, all the different ways mushrooms are

9 grown, I think I just have a different

10 perspective on that which, if I have time, I'll

11 talk about, I might not.

12 I want to go down to container growing

13 and I do want to bring up some of those questions

14 because a lot of mushrooms are grown in

15 containers. We do depend on artificial lighting

16 to grow mushrooms. All mushrooms, excluding the

17 white button mushroom, require some light, and we

18 do grow indoors, so we do need to provide some

19 artificial light. Artificial heating and cooling

20 also is necessary.

21 Some species of mushrooms are grown in

22 plastic or wooden trays, and in various types of
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1 plastic bags. So just when you're talking

2 through these recommendations, just always keep

3 mushrooms in mind.

4 And I guess we would consider -- oh,

5 I'm sorry. Boy, that was really fast. Thank you

6 so much.

7 CHAIR CHAPMAN: Thank you, Tina. Any

8 questions for Tina? Please stay, Tina. Asa?

9 MEMBER BRADMAN: I have a couple of

10 questions. You mentioned you had problems with

11 hydrogen peroxide. Was that accelerated hydrogen

12 peroxide and have you looked into other

13 alternatives -- 

14 MS. ELLOR: Oh --

15 MEMBER BRADMAN: -- cleaning

16 materials?

17 MS. ELLOR: No. It's more that we

18 can't always use hydrogen peroxide in place of

19 chlorine because it is not as stable and it's

20 different to use. So, you know, we need to keep

21 chlorine on the list for, especially, food safety

22 concerns.
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1 MEMBER BRADMAN: Okay. And then you

2 mentioned keep humic acid. I'm curious, how you

3 use humic acids and whether you made a

4 differentiation between coal-based or kind of

5 natural-based derived humic acids?

6 MS. ELLOR: I don't believe coal-based

7 are allowed. Correct me if I'm wrong, but, no,

8 we don't use coal-based.

9 MEMBER BRADMAN: Okay, thank you.

10 CHAIR CHAPMAN: Thank you very much. 

11 Up next is Jonah followed by, is Jonah here? 

12 Jonah going once, Jonah going twice. We just

13 saved three minutes.

14 Next up is Jeff Dean. Is Jeff Dean

15 here? Yes, I believe that's Jeff Dean walking

16 up. And on deck is Jody Mason.

17 Jeff, if you could start with your

18 name and affiliation for the record.

19 MR. DEAN: Okay. I'm Jefferson Dean. 

20 I'm a member of the Organic Grain Growers Chapter

21 of OEFFA, Ohio Ecological Food and Farm

22 Association.
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1 We have about 68 members, average

2 about 300 to 400 acres. I've been farming

3 organically in Northern Ohio for about 25 years. 

4 I have 600 acres of certified organic ground. We

5 have raise corn, beans, wheat, sunflowers and

6 clover.

7 About 20 years ago, the organic

8 industry requested USDA to get involved in the

9 organic to help standardize the rules and

10 regulations and to help enforce them.

11 We asked to be regulated with the one

12 set of standards for everybody. As producers,

13 it's our job to follow these rules. It's your

14 job, along with USDA and the certifiers, to help

15 enforce these rules and to preserve and protect

16 the integrity of organic.

17 But the organic industry is under

18 siege on two fronts. First, GMO contamination. 

19 Our seed is contaminated, pollinators and wind

20 are contaminating our fields and grain to become,

21 our grain becomes contaminated from them. We

22 know it's coming from our neighbors and it's
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1 costing us in sales and in integrity and organic.

2 If my cows were to get out and damage

3 a neighbor's crops, I'd have to pay for the

4 damage. But my crops get contaminated by GMO

5 drift from my neighbors and I have to pay for

6 that too. I don't think that's quite right.

7 The second front is imports. Corn

8 coming in from Turkey increased by 500 percent

9 from 2015 to 2016. That's unbelievable. It's

10 just unimaginable. Most of this is certified by

11 a questionable certifier going through

12 non-certified handlers and brokers. That's

13 unbelievable also.

14 We figured it's costing us about $3 a

15 bushel. At 18,000 bushels that I produced last

16 year, well, you can do the math. It's not an

17 insignificant amount. We abide by extensive

18 rules and regulations, inspections, a paper trail

19 back to the field where it was grown. If they're

20 following the same rules, that's great. If they

21 are, then it should be easy to verify. So make

22 them verify everything just like we do.
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1 When consumers hear about these

2 questionable imports -- and they are hearing

3 about them more and more -- it's disastrous for

4 the integrity of organic.

5 We can't lose this battle. We can't

6 lose our integrity. We, as farmers, are doing

7 our part. You need to do your part. The USDA

8 needs to take decisive action on this right now,

9 immediately. Thank you.

10 CHAIR CHAPMAN: Thank you very much,

11 Jeff. Any questions for Jeff? Thank you.

12 Up next is Jody Mason. Is Jody here? 

13 Going once, going twice, that's another three

14 minutes we've just banked.

15 After that is Gerald Davis. Is Gerald

16 Davis here? All right. As Gerald makes it up to

17 the front, after him is Brunno Da Silva Cerozi. 

18 Sorry if I butchered that.

19 Thank you, you're on deck. If you can

20 move to the on-deck chair. On deck, so you're --

21 wait. Was the person moving not Gerald? So,

22 Gerald -- Gerald, you're up right now. Brunno
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1 you're on deck.

2 And if you can state your name and

3 affiliation for the record.

4 MR. DAVIS: Gerald Davis, Grimway

5 Farms, former NOSB member from 2005 to 2010. I

6 was a primary contributor to the 2010 Crop

7 Subcommittee document concerning container-based

8 greenhouse growing and hydroponics.

9 This document was intended as an

10 interim-type of document, in my opinion, to move

11 forward the development of organic standards for

12 greenhouse growing. Seven years later, we are

13 finally returning to this task.

14 I also contributed in a small way to

15 the Hydroponics Task Force work last year. At

16 the meeting I attended, I was taken aback by the

17 boldness of the hydroponic representatives, the

18 liquid substrate version of hydroponics, and

19 their boldness in saying it should be allowed as

20 organic. And we all heard a lot of statements at

21 this meeting that their claims are really strong

22 and they're really pushing hard for that.
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1 Grimway farms produces 30-plus

2 different vegetables grown organically on over

3 35,000 certified acres. We're a very large farm. 

4 Since 2007, we have produced organic greenhouse

5 tomatoes in a ten-acre facility. So a small

6 project by our standards, but, our scale that is.

7 It's a container-based system

8 utilizing a mixture of coco coir, compost, ground

9 rock minerals, organic fertilizers, mycorrhizal

10 soluble bacteria and fungal inoculants. It's

11 been a ten-year testing excursion trying to

12 perfect a container-based system that

13 incorporates as much of the organic practices

14 from field-based organic growing methods as

15 possible.

16 Grimway strongly urges the NOSB and

17 NOP to reject allowing liquid substrate

18 hydroponics and to define and come up with

19 guidelines and rules governing container-based

20 production in greenhouses. Any questions?

21 CHAIR CHAPMAN: Thank you. I see

22 Emily, Francis, Ashley, Joelle, and I'm going to
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1 start with that. Emily.

2 MEMBER OAKLEY: So are you in

3 agreement with the definitions and the proposed

4 motions that are in this discussion document for

5 hydroponics, aeroponics, and aquaponics?

6 MR. DAVIS: Yes, pretty much. I'm the

7 one who that came up with most of those, so, yes,

8 I'm in agreement with it.

9 MEMBER OAKLEY: Speak a little louder,

10 please.

11 MR. DAVIS: I wrote that language. 

12 So, yes, I'm in agreement with that.

13 CHAIR CHAPMAN: Francis?

14 MEMBER THICKE: Do you have any

15 general guidelines to what you think for

16 container growing should be, the rules for

17 container growing? Any parameters, standards?

18 MR. DAVIS: It really needs to be

19 strongly defined because container growing, from

20 my experience and working with it for ten years

21 now, you know, in reference to tomatoes, which is

22 a longer period of crop growth than, say, lettuce
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1 or something like that.

2 For a long duration crop like

3 tomatoes, what starts out as a very vibrant crop4 supplying soil mixture that you concoct and put

5 all the right ingredients and make it

6 biologically alive, at some point, it breaks down

7 and it begins to require more and more liquid

8 feed, nutrients, to keep that production going.

9 So I would not want to disallow

10 container production but it needs to be very

11 specific on the guidelines you put forth. So we

12 just don't have a kind of a cheap way of doing

13 hydroponics and calling it container-based

14 growing.

15 CHAIR CHAPMAN: Thank you. Ashley.

16 MEMBER SWAFFAR: So I have two

17 questions for you. Do you think the current

18 document that's written on hydroponics is clear

19 enough that containers are completely separated

20 out of that? It draws a line in the sand

21 basically between hydroponics and containers

22 clearly?
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1 And then what percentage of your

2 nutrients come from liquid fertilizers in your

3 container system?

4 MR. DAVIS: There's a lot of ways you

5 can produce growth from liquid fertilizer

6 extracted from compost. We did that for a number

7 of years. Works great. Very difficult.

8 You can revert to just using sodium

9 nitrate if you want to as a nitrogen source. 

10 Works okay, I guess, but is that what we want? 

11 So it's the language we put in that document

12 really is just a starting point.

13 This really needs to be developed if

14 you're going to allow it as organic, because

15 otherwise people just game the system and they

16 start inserting hydroponics in and calling it

17 something that's good. And with organic

18 principles and biological farming, and all the

19 things that are really important with the root

20 dynamics in a soil media, I don't know. It's a

21 big subject that I don't know if it's going to be

22 that easy for a board like this to come up with.
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1 CHAIR CHAPMAN: You, no. Do I have

2 someone over here. Joelle. Sorry. Joelle,

3 you're up. Yes.

4 MEMBER MOSSO: Question on your

5 substrate. So you're not including soil as it's

6 currently defined in the discussion document in

7 your substrate mix, is that accurate?

8 MR. DAVIS: Not fuel soil. There is

9 a significant portion of ground rock minerals

10 that we use. So it's not all coco coir.

11 MEMBER MOSSO: So is it of your

12 opinion that if we were to have container growing

13 stipulated with how much soil as it's defined in

14 the discussion document, would there -- what's

15 your opinion on that?

16 MR. DAVIS: The problem with that,

17 containers, most of the greenhouse systems are

18 based on gutter based systems where the container

19 has to sit on top of a support structure which we

20 call gutters, which provides the drain for the

21 water to filter through, and we recirculate it,

22 and reuse, so it's not just thrown off to waste
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1 somewhere.

2 You have some weight constraints. If

3 you start adding more and more soil, it becomes

4 too heavy, and we have actually pushed it to the

5 limit with as big a grow bag as we could even

6 without soil and collapsed gutters.

7 So a container based system with soil

8 in it wouldn't look like the standard

9 conventional gutter based system just with soil

10 added because you can't handle the weight.

11 MEMBER MOSSO: Thank you.

12 CHAIR CHAPMAN: Thank you very much. 

13 Up next is Brunno, and on deck is Richard

14 Matthews.

15 And if you could start with your name

16 and affiliation for the record?

17 MR. CEROZI: Yes, my name is Brunno

18 Cerozi and I'm here representing Superior Fresh.

19 That is an aquaponics facility located in Hixton,

20 Wisconsin.

21 So traditionally animals were an

22 integral part of agricultural systems. They
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1 provided food and fiber, powered farm machinery,

2 and most importantly, were the major means of

3 recycling nutrients back to the soils and

4 nourishing our crops.

5 But since the rise of factory farming

6 with intensification of agriculture and animal

7 production into industrial operations, animals

8 were divorced from our once vastly diversified

9 farms.

10 But in 1980, USDA reporting

11 recommendations of organic farming stated, and I

12 quote, "Animals comprise an essential part of

13 operation of many organic farms. Organic

14 agriculture strongly emphasizes the application

15 of compost and manure and other organic materials

16 to improve soil fertility and its structure."

17 Still in the 80s, following the same

18 trend, research at the University of Arizona,

19 using plants as a natural filter within fish

20 farms began which is known today as aquaponics.

21 So since then, fish became more and

22 more integrated into a comprehensive agricultural
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1 analysis. Aquaponic systems surged as an

2 alternative to the indiscriminate overuse of

3 chemical fertilizers in our intensive production

4 systems to re-establish the link between animal

5 and crop production.

6 However, there has been a recent

7 movement to limit the use of the organic label to

8 operations in which plants are cultivated are not

9 directly rooted in soils. But plants do not

10 absorb nutrients directly from soil or the soil

11 particles.

12 Even though there is direct physical

13 contact between a soil particle and the root

14 surface, they need a special medium so important

15 called soil solution. And chemically and

16 functionally speaking, an aquaponics nutrient

17 solution is not different than a soil solution.

18 They contain comparable amounts of

19 dissolved nutrients and an incredibly diverse

20 microbial community lives in there. Think about

21 this, today we face prospects of an emerging food

22 crisis due to a rising world population that
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1 wants to eat more high quality food in a changing

2 climate system that is diminishing harvests all

3 over the world.

4 So all organic practices, whether

5 soil-based or aquaponics, I think could join

6 forces to increase food production using our

7 limited natural resources more efficiently.

8 So I'd like to recommend, just a

9 close, the NOSB and USDA to guarantee that

10 aquaponics farmers continue to be part of the

11 USDA organic program. And I encourage the NOSB

12 to get the right information about both systems.

13 CHAIR CHAPMAN: Thank you. I have to

14 stop you there. Thank you.

15 MR. CEROZI: Thank you.

16 CHAIR CHAPMAN: Any questions? Lisa,

17 was that your hand up or no? No. Okay. Not

18 seeing any questions. Oh, we do have one. Emily

19 or Sue?

20 MEMBER BAIRD: Just because they told

21 me I needed to ask it.

22 CHAIR CHAPMAN: Okay.
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1 MEMBER BAIRD: No. My question is,

2 the manure from the fish that is being recycled

3 back into the plant operation, what's the waiting

4 period between the time of that water having

5 fresh fish manure in it and then being delivered

6 to the roots of the plants?

7 MR. CEROZI: So I wouldn't call it

8 manure. I would call it aquaponics nutrient

9 solution, and I would say that it would be waited

10 until 24 hours between, when you feed the fish,

11 and that's the similarity between organic,

12 traditional organic practices, and aquaponics.

13 Because when you feed the fish and you

14 can imagine, the food will have to go through the

15 digestive system and usually in tilapia, for

16 example, it would take 24 hours for those

17 nutrients to be fully digested and then released

18 into the water.

19 And the form that the nutrient is

20 delivered in the water, they're readily available

21 for nutrient uptake. So it's quick, and it

22 mimics what happens in the soil, right there in
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1 soil solution.

2 As the nutrients are absorbed, there

3 is always a resupply of nutrients in the water. 

4 So you see a steady state of a nutrient

5 concentration in the water. So there's never an

6 increase in the nutrition concentration in

7 aquaponics nutrient solutions.

8 CHAIR CHAPMAN: Do that, yes, go

9 ahead.

10 MEMBER BAIRD: So I just want to

11 clarify, so 24 hours between when they excrete

12 the nutrients and it goes to the plants' roots,

13 is that correct?

14 MR. CEROZI: Yes.

15 MEMBER BAIRD: Okay. Thank you.

16 MR. CEROZI: Or less.

17 CHAIR CHAPMAN: Any additional

18 questions? Yes, Harriet.

19 MEMBER BEHAR: Is there an intervening

20 activity where enzymes are added to that nutrient

21 solution before it goes to the plants?

22 MR. CEROZI: Intervening in terms of
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1 --

2 MEMBER BEHAR: I thought, aquaponics,

3 there was a use of some enzymes to help digest

4 the nutrients.

5 MR. CEROZI: So, yes, that's a great

6 question. Aquaponics usually picture in fish and

7 plants. But without microorganisms there is no

8 aquaponics. So, yes, there is an intermediate

9 process between when the fish release the

10 elements in the water.

11 For example they release ammonia, and

12 ammonia can be highly toxic for fish if it

13 increases in the water -- the concentration's

14 increased in the water. So you need

15 nitrification to have -- the same thing that

16 happens in soil, the same nitrification, the same

17 microorganisms that live in soil, live in

18 aquaponics, and they're needed.

19 Without microorganisms, there is no

20 aquaponics. And I published, I did my doctorate

21 at the University of Arizona. I spent four years

22 studying aquaponics and the phosphorus dynamics
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1 in aquaponics. So not only microorganisms are

2 important for the nitrification process in

3 aquaponics but also for the phosphorus cycle.

4 So I published a paper, and you can

5 find the literature and it's cited in the

6 document that I made available for everyone, that

7 without microorganisms, plants do not thrive in

8 aquaponics.

9 CHAIR CHAPMAN: Thank you. Thank you

10 very much. Up next is Richard Matthews. And if

11 you can start with your name and affiliation.

12 MR. MATTHEWS: I am Richard Matthews,

13 the Executive Director of the Western Organic

14 Dairy Producers Alliance. The organic dairy

15 sector is in a crisis of oversupply, falling farm

16 gate prices, and struggling organic farmers and

17 struggling small organic handling operations.

18 The oversupply, and thus the crisis,

19 is directly attributable to the failure of AMS

20 and the NOP, to perform in conformance with

21 USDA's mission statement. AMS and the NOP have

22 failed to provide leadership, sound public
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1 policy, and efficient management.

2 These failures are having an adverse

3 impact on the sustainability of organic dairy

4 producers and small organic handling operations. 

5 NOP's failure to complete the origin of livestock

6 rule-making commenced on April 28, 2015, is

7 directly responsible for the dairy sector crisis.

8 AMS leaves WODPA with no choice but to

9 take the origin of livestock issue to, one, the

10 House Committee on Oversight and Government

11 Reform; two, the Senate Subcommittee on

12 Regulatory Affairs and Federal Management and,

13 three, District Court. Any questions?

14 CHAIR CHAPMAN: Thank you. Questions? 

15 Ashley?

16 MS SWAFFAR: I have a very off the

17 topic question for you. I didn't see any

18 comments from you guys on emergency use of

19 parasiticides, and I was just wondering if you

20 have any thoughts on that? Or if that puts you

21 on the spot, I'd encourage to use the open docket

22 after this meeting to give us your thoughts on
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1 them.

2 MR. MATTHEWS: I can do that. Okay.

3 CHAIR CHAPMAN: Any other questions? 

4 Thank you very much. 

5 MR. MATTHEWS: Oh, Mark, thank you for

6 the photo op. Thank you for the photo op.

7 CHAIR CHAPMAN: Thank you.

8 MR. MATTHEWS: I will post it on O9 Dairy.

10 CHAIR CHAPMAN: Thank you, Richard. 

11 Surprise, surprise. This actually concludes our

12 public comment today. We are only 11 minutes

13 over so it worked out kind of in the end. So we

14 are about to go into recess but we will start

15 again tomorrow with public comment and the

16 meeting time is 8:30, so 30 minutes earlier than

17 today's was.

18 But without objection, we will move to

19 recess.

20 (Whereupon, the above-entitled matter

21 went off the record at 6:11 p.m.)

22
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A

A-Dae 2:7 10:1,1,5

145:15

a.m 1:20 6:2 95:18,19

aback 450:16

Abby 4:22 185:8 196:11

196:13,15,17 199:18

199:19

abide 448:17

ability 161:4,12 255:9

371:3 374:12 386:14

421:10

able 15:17 22:3 36:16

61:5 66:8 84:3,10

99:4 110:3,6 159:8

161:1 203:5 210:5

235:1 236:3 247:4

253:9 254:21 288:16

319:20 324:21 333:8

351:13 374:20 391:19

394:4 402:16 415:8

aboard 286:19

above-entitled 95:17

215:13 465:20

abroad 423:4

absence 420:9

absolute 114:20 244:9

absolutely 172:18

229:1 243:18 306:2

314:2 318:16 329:22

389:22 402:13 413:9

443:11

absorb 458:10

absorbed 461:2

absorption 370:17

abundant 231:12

AC-21 405:11

ACA 262:4 263:6,12

ACA's 263:13

academia 309:11

accelerated 445:11

accelerates 315:3

accept 148:7

acceptable 90:12,14

167:8,13 168:10

180:19 355:21,21

393:6

accepted 434:1

access 30:16 31:3

88:10 97:10 120:3

146:18 161:8 187:9

202:22 266:12 378:6

accidents 362:16

accompanying 221:6

accomplish 61:6 277:7

accomplishment 18:20

86:15,22

accomplishments

18:15

account 88:18

accounts 373:16

accredit 421:3

accreditation 14:5

28:12,14 29:13 32:7

38:11 42:9,15 51:21

64:1 197:11

accredited 3:4 32:22

33:2 43:4 47:3 208:3

250:11 262:3 393:2

426:14

accredits 13:19 206:2

accumulation 371:16

accumulative 400:18

accuracy 418:9

accurate 54:11 139:4

418:8 455:7

accurately 388:8

389:17

ACE 64:20

achievable 377:21

achieved 315:2

acid 11:7 74:17,18,20

75:1 235:2 239:10,11

314:9 315:14 395:12

396:11 397:9 443:13

443:17 446:2

acidic 235:4 236:11

412:16

acidified 395:22 396:3

acids 278:11 297:20

311:18 312:4,8 313:4

313:12 314:11 446:3

446:5

acknowledge 262:13

acknowledges 199:2

acre 16:15

acres 141:10,12,13

225:20 345:5,7 424:4

447:2,4 451:3

act 27:20 40:14 71:15

72:2 89:19,22 195:4

220:12 243:19 251:4

284:5,8 324:12

334:21 337:4 409:11

442:8

acted 288:9

acting 29:4 281:4

action 34:10 38:3,10

39:15 53:4 195:19

201:1 282:13 338:6

393:7 449:8

actions 28:20 37:1,7,21

38:6 42:19 52:14

269:11 278:1

active 112:22 183:1

195:16 216:13 272:15

273:2 284:9,11,18,21

285:1

actively 197:19 331:16

activities 7:16 20:11

28:13 29:13 30:11

32:8 44:1 51:11 55:3

57:2 65:16 66:6 69:6

152:16 159:5 197:16

activity 27:2 37:12

98:22 100:16 110:7

114:7 132:2 140:13

197:3 335:13,15

337:14 355:19,20

356:10,19 424:21

425:1 461:20

actual 82:3,8 141:13

272:1 284:17

acute 290:8

ad 159:1

adapted 56:17 159:16

266:13 406:2

Adaptive 403:17

add 72:20 79:18 88:15

101:16 123:18 128:16

145:11 169:3,3

177:21 178:4 247:22

319:22 332:17 333:1

333:2 389:14

added 75:21 79:14

101:14 235:18 276:16

389:15 412:2,7

425:21 456:10 461:20

adding 124:3 144:21

145:13 244:3 456:3

addition 15:14 54:8

72:10 73:21 125:5

137:16 175:20 249:6

268:4 309:9

additional 36:19 41:15

50:22 72:9 75:1 76:14

87:11 92:13 94:21

104:9 107:11 123:7

124:8 139:7 162:5

180:20 198:16 204:22

221:6 233:18 242:22

358:20 372:18 461:17

Additionally 359:19

additive 201:16

additives 3:16 201:18

203:21 204:19 279:5

343:18,19 369:19

397:22 398:3 399:16

400:3,18

address 32:4 101:15,22

102:2 124:12 148:18

149:20 174:12 177:14

193:10 214:16 218:16

238:9 240:5 261:15

271:17 291:10 302:10

306:19,21 307:15,15

312:19 318:14 361:8

361:18 370:5 379:19

addressed 74:14

101:18 125:4 155:22

281:10 282:19 293:9

381:4

addresses 364:9

addressing 71:2 151:14

175:4 193:1

adds 145:9

adequate 52:15 60:22

168:6 308:15 353:5

adequately 290:10

436:14

Adjourn 5:18

adjust 255:9

adjuvants 72:11

admidated 242:16

administration 20:9

22:16 23:6 25:19 28:2

31:22 48:7,7,22 63:3

69:2,17 84:19,22 85:4

87:12 135:14,15

158:3 196:22 258:6

405:21

administrative 39:8,17

40:3 191:3

administrator 2:14 7:4

8:19 28:2 29:4,6,8

258:13

admirable 414:2

admit 148:18 286:15

adopt 270:19 288:17

323:5 363:10

adopted 101:10 281:19

282:15,20

adopting 198:8

advance 89:16 96:7

98:14 354:4 359:21

advanced 45:19 80:8

80:17 81:12

Advancement 4:15

157:15

advances 31:11

advancing 266:11

267:16

advantage 91:1 124:15

317:1 421:19

advantages 113:17

adventure 59:21

adverse 38:3 39:15

464:2

adversely 269:5

advertise 171:8

advice 90:8,8 205:18

advisor 4:11 174:6
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289:22 343:6,7

advisory 2:11 7:7 16:7

89:18 191:15

advocacy 4:1 262:11

265:2,5 274:22

advocate 62:3 172:22

362:13 405:1 436:9

436:13

advocates 199:4

335:12

advocating 47:8

aerates 234:21

aeration 117:12,16

aeroponics 174:16

275:1 323:1 452:5

Affairs 3:15 4:4 230:18

369:13 397:22 464:12

affect 69:4 76:3 154:1

159:22 181:21 212:9

371:3

affidavits 58:4,5

affiliated 224:1 259:13

affiliation 98:1,10 99:13

122:6 130:11 162:10

174:4 185:11 196:14

200:6 205:12 220:4

223:20 230:14 233:22

237:22 243:7 248:16

251:11 259:9 262:2

264:21 271:9 274:18

280:16 289:18 292:14

298:8 302:3 307:4

314:1 320:6 323:22

334:13 342:19 350:14

357:13 363:1 369:9

378:19 381:20 383:10

394:10 397:19 403:14

406:16 411:1 413:15

422:22 431:1 436:4

442:4 446:18 450:3

456:16 463:11

affiliations 91:11 97:19

98:3 111:20 139:11

147:13 157:13 181:3

216:1

afraid 423:6,13

Africa 49:22

afternoon 196:17

264:22 289:20 342:20

369:12 375:4 378:20

397:20 411:2

ag 12:16 14:3 24:15

158:11 206:2

age 278:8 283:16 296:7

age-old 321:5

agencies 22:14 25:12

25:22 64:3 250:12

258:3 263:11 372:6

409:10

agency 24:13,14 26:3

26:11 27:9 88:17

386:17 393:5 408:15

409:2

agenda 5:3 8:15,18 9:9

70:3,7 71:3 72:14,15

72:19,22 75:22 76:22

77:8 78:20 79:1 83:20

85:8,12 95:16,22

199:22 267:10 287:19

334:5

agent 395:14

agents 33:1 65:7

284:13 426:14

ages 296:6

aggregate 300:2

aggregated 301:4

aggregates 300:5

aggregation 299:11

300:4

ago 38:15,16 44:8

49:10 67:10 116:1,10

136:13 189:4,4

224:22 285:3 300:10

320:17 329:11 348:6

447:7

agree 84:6,10 88:22

152:10 162:20 171:13

310:1 322:22 340:15

364:12 365:19 407:3

420:6 430:9

agreed 72:22 191:12

278:12 374:9

agreeing 39:14

agreement 225:1,3,8

273:14 452:3,8,12

agreements 24:18 27:4

37:5 44:12

agrees 275:2 376:16

Agri-Food 114:4

agricultural 7:4 24:12

25:13 26:1 29:5 37:18

56:13 77:15 79:8,9

130:18,19 160:3,6

194:10 209:22 214:13

256:3,5,11 289:21

290:9 321:3 337:7

377:20 378:3 421:1

456:22 457:22

agriculture 1:1 6:13

10:18 20:5 85:3,7

114:4 138:16 146:20

158:4 160:2 163:5

199:2 205:18 206:1

211:11 229:21,22

243:21 279:18 291:19

291:20 311:13 314:15

324:6 337:1 350:19

356:3 358:3 361:15

361:21 362:4,6,8

363:5,16 366:4,19

369:3 383:15 407:5

426:18 427:8,9 444:2

457:6,14

agriponic 100:2

AgriSystems 2:20

394:12

Agro 2:22 3:2,13 302:6

307:8 314:4

agro-infiltration 198:13

agroindustrial 131:20

agronomic 3:9 291:10

342:22 349:8

agronomy 385:17

agroponic 176:6

ahead 96:10 265:17

286:2 417:17 461:9

aid 396:4

aids 72:11

air 132:10 181:21 215:2

217:6 218:4,14 275:8

315:7 359:8

aircraft 342:3

airplane 342:2

AITC 73:8

Akron 3:21 334:15

Alan 4:6 219:19,19,21

219:22 220:3,7 223:9

223:13,14

Albert 4:17 413:13

415:14,15,17 417:14

419:4 422:19

alcohols 73:22

alert 195:18,20

Alesia 2:20 381:16

383:8 394:6,9,12

Alfalfa 169:22

algae 72:17 76:3

align 83:5 360:19

389:12

aligned 302:18

aligning 441:2

aligns 201:6

alike 85:9

alive 384:8 387:22

453:6

all-fruit 235:17

alleged 51:1

allergen-free 234:20

allergy 295:5

Alliance 2:18 4:1,10

265:2,15 363:4

463:14

allies 250:3

allotment 96:16

allow 179:9 239:20

326:11,17 333:17

397:5 401:13 454:14

allowable 288:20 289:4

325:11 327:6

allowance 159:20 262:9

302:11 372:13 385:11

385:12

allowed 98:16 135:3

155:4,9 156:16 274:6

275:5 276:6 289:3

292:1,2 293:21 317:3

322:10 324:22 328:21

377:4 378:11 386:16

391:8,9,14 398:3

404:18 427:7 446:7

450:19

allowing 88:9 123:7

155:1 160:8 184:3,5

188:8 223:4 242:2

317:2 325:4 384:18

426:13 451:17

allows 46:3 56:19 96:8

123:15 207:4 208:7

427:5

allyl 73:7

almonds 256:9

alternate 391:12

alternative 177:16

178:6 191:7 297:7

443:20 458:2

alternatives 242:6

274:3 279:7 297:5,9

307:19 309:8 372:11

378:3,3 395:5,15

398:11 399:6 411:20

411:21 445:13

alumni 157:17

Amalie 4:8 350:13

357:10,15

amazing 18:19 45:11

Amazingly 164:21

amended 79:12 387:15

amendment 393:12

America 14:10 49:22

141:8 379:14,17,18

American 50:17 221:2

227:17 379:6,15

407:8 408:20 409:19

410:2 418:5

Americans 202:15

amidated 242:6,10,13

amino 278:11 297:20

ammonia 462:11,12

ammonium 73:13 302:8

303:8,20 304:3,11

307:16 315:18,22

316:5 386:2 428:16
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amount 22:7 29:21

41:20 51:5,9 57:16

69:11 217:11 243:13

314:14 329:1 332:9

349:1 376:6,9 404:20

448:17

amounts 458:18

ample 100:12

AMS 2:14 19:3 20:7

25:20 26:10 27:3 29:1

37:7 38:3,5 42:2,3

82:15 258:13 278:12

463:19,21 464:8

AMS's 27:5 51:22

anaerobic 73:22 78:7,8

Anais 2:18 313:20

320:4,7

analysis 26:7 58:1

67:11 100:19 161:15

214:7 336:14 416:4

430:3 458:1

analyst 4:19 200:9

279:15

ancillary 76:6 122:16

122:22 123:7,14

125:16 127:9 202:6,8

274:6

Andaluz 2:16 394:7

397:17 403:15,15

angle 192:19

angles 192:18

angry 127:15

animal 3:19 13:10

25:14 130:17 202:20

203:8 221:16 274:20

294:17 340:18 364:18

418:5,21 457:6 458:4

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457:7,12

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362:20,22 363:3

366:6 369:6

annotation 76:1 282:6

288:17 289:9 291:4,6

292:6 293:12 304:17

307:20 310:6 311:1

316:19 389:12,17

438:22

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263:3 264:1,4 270:6

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ANSI 34:8

answer 87:11 103:2

106:5 116:12 118:13

129:2 135:22 179:1

193:12 227:18 229:3

241:2 256:12 257:5

270:16 294:20 301:15

301:16 311:16 329:16

330:19 348:16 349:2

349:3,18 351:13

357:6 370:18 381:11

436:11 440:17

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121:16 129:6 173:16

316:3

answering 109:4

111:13 166:17 353:16

answers 15:11 136:7

189:20 443:3

Anthony 3:9 334:4

342:16,18,21

Anthropomorphic

336:22

anti-epileptic 252:15

anti-fraud 380:11

anti-inflammatory

253:3

antibiotics 247:6

291:15

anticipating 416:17

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antioxidants 183:5

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222:3

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440:14

APHIS 25:14 35:13

64:12 65:6,17

APHIS's 64:5

apiculture 15:17 68:13

69:9

apologies 302:1 429:13

430:20

apologize 8:1 55:6

89:16 98:14 130:11

185:10

Appalachian 32:10

apparently 125:18

appeal 38:3,5,17 39:9

39:10,11,13 41:18

appealable 38:7,9,11

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38:12,20 39:5 209:15

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273:7

appearance 91:2

apple 231:18

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316:14 318:2 411:15

411:22 457:14

applications 62:16

238:6,7,14 239:9

240:7 311:7,10 399:7

412:21

applicator 289:22

applicators 207:3

290:17

applied 44:22 112:18

303:21 317:17

applies 353:2

apply 45:2 72:6 132:20

352:17 397:8

appointed 25:8 89:19

appointees 23:17,22

appointment 23:19

85:7

appreciate 62:2 70:1

128:9 174:11,22

199:15 243:14 301:19

342:15 383:7 403:22

422:2

appreciated 129:17

130:2 173:22 220:2

249:5

appreciates 86:2

276:18

appreciative 358:19

approach 35:4,5,18

105:2 112:10 175:4

176:17 179:17 262:10

271:4 281:13 351:17

352:8 392:15 422:16

appropriate 113:19

171:5 269:12 277:12

278:7 297:13 351:16

389:19

appropriately 60:3

290:10

appropriations 158:12

409:11

approval 253:15 415:4

approve 18:1

approved 18:2,4 74:9

140:6,8 141:4,8

238:13 272:1 302:22

303:17 306:5 307:19

308:15,20 310:21

314:19

approximately 125:6

304:14

April 1:14 32:20 48:17

94:18 100:3 224:22

225:4 464:6

apropos 256:15

aqua-culture 161:9

aquaculture 69:11

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275:15 458:1

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452:5 456:19 457:20

458:16 459:5,10

460:8,12 461:7 462:2

462:6,8,18,20,22

463:1,3,8

aquatic 316:9

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ardent 165:15,16

area 12:17 31:14 33:15

33:21 38:18 44:1 45:3

49:12 58:18 61:17

62:3 65:18 95:6

149:21 160:14 161:3

198:1 208:1 218:2

228:10 260:5 304:14

360:5 364:7,20

365:16,18 388:10

391:16 392:1

areas 20:13 24:1,3 30:2

142:16 145:19 146:7

201:3 218:14 277:17

278:2 307:15 313:3

345:13,19 346:7

364:14 366:17 385:7

385:17 389:2

Argentina 44:22 53:5

argue 160:3 355:4

argument 319:6

arguments 325:7

326:16

arid 105:4

Arizona 105:4,6,9

108:11 109:18 457:18

462:21

Arkansas 13:9

armory 285:17

arrangements 24:17

28:16 34:21 44:9

65:13

arrive 95:3

Arsenault 2:11 7:6 9:16

arsenic 297:18

art 284:10

arthropods 340:5

articles 151:2,5,17

157:5 400:11

articulate 89:20

articulated 254:2
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92:18 106:3,22 165:2

170:8 171:4 172:4

245:10 295:16 305:4

354:11 355:12 356:8

381:2 387:2 392:7

445:8

ASC 396:3,10

Ashley 2:8 13:7 62:9

89:1 106:2 109:1

115:12 118:12 120:5

134:14 165:2 166:20

168:13 327:13 331:22

354:12 356:20 387:2

390:1 451:22 453:15

464:15

Asia 49:22 260:14

aside 176:19 319:9

325:20

asked 72:20 94:12 96:7

97:18 121:5,15

135:20 136:4,5

137:14 158:8 170:7

202:21 308:2 318:10

373:20 392:8 393:20

405:5 433:8 441:9

447:11

asking 73:11 79:13

97:19,22 98:9 129:3,7

154:11,14,15 160:15

192:20 218:15 224:13

258:21 280:3 310:22

339:6 353:16 360:18

361:6,7 363:22 390:3

440:2 441:1,7

asks 377:2

aspect 417:5

aspects 141:3 344:6

376:13 425:15

assertions 307:16

399:13

assess 405:22

assessing 421:21

assessment 28:17 44:7

255:4 307:1 316:3,22

364:15

assessments 12:20

34:13,14 44:5,11

assist 361:2 427:16

assistance 21:11

360:18 365:7

assistant 32:7

Associate 29:6

associated 78:15 90:20

201:14 308:18

association 3:4,8,18

4:7,8,12,16,20 12:16

14:10 173:1 174:7

217:20 230:17,22

231:4,4 249:8,9

259:14 262:4 357:16

369:20 383:13 398:1

403:19 406:20 407:12

409:18 413:18 415:16

418:6 421:8 446:22

associations 87:7

assumed 151:10

assuming 82:4 403:4

Assurance 108:17

astonishing 323:10

at-risk 404:13

atmosphere 387:21

atrazine 244:19

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attack 100:8 284:12

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attacks 98:18

attain 254:21

attempt 195:6 353:1

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attend 8:4

attendance 83:15

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attending 95:1

attention 31:16 34:18

44:18,20 197:9

213:22 254:18 266:4

278:13 361:8 383:22

384:1 414:2

attest 331:9

attestation 54:22

attorneys 130:16

attractions 221:18

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attribute 35:17

attributes 335:5

attuned 426:19

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274:11 279:22 292:11

298:2 301:18 323:17

audience 293:6

audit 34:20 42:17,19

54:14 59:4

audit-able 57:6

audited 57:4,12 58:8

auditing 60:22

auditor 43:20

auditors 43:16,21

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42:16,17 43:1,5,6,11

43:12,17,18 54:15

263:4

Australia 43:7

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399:3 420:17 436:14

authority 27:19 47:10

49:7,15 52:13,20

58:15,16,17 133:6,7,8

193:3 356:18 360:3

362:14 393:13 409:3

420:17

authors 159:20

auto-immune 181:9

automated 64:22 131:8

automobile 135:12

availability 267:19

268:1 270:13 398:14

401:7 405:22 427:14

available 34:11,16 59:6

59:8 60:5 63:8 70:22

74:10 75:11 77:11

78:18 81:14 84:20

85:16 111:6 138:3

232:11,16,22 233:11

233:17 255:12,13

260:11 273:6 300:16

300:17 337:8 372:15

378:8 388:16 391:3

395:16,20 398:12

401:3 402:15,17

403:4 412:19 413:1

428:12,13 460:20

463:6

avenue 211:1

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217:16 412:9 447:1

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aviation 342:1

avoid 191:18 312:18

avoiding 163:3 204:18

424:16

aware 150:15 186:11

187:19 195:14 287:3

296:20 345:12 392:2

402:1,7 415:7 439:2,4

Awareness 294:21

Axe 182:21

axiom 132:15

B

B 183:5

back 7:12 47:19 67:10

70:10 73:16 95:13

106:12 111:3 117:18

121:4,16 131:21

151:12 164:5 179:9

185:14,15 187:11

200:4 215:9,10,18

224:11 267:9 286:18

287:18,19 288:15

306:4 327:16 349:1

350:7 380:18 381:13

381:18 415:6 423:9

429:12 431:9 441:5

448:19 457:3 460:3

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367:1

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bacterial 108:2,4

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Badger 2:17 111:18

122:3,7,7 125:14

126:5 127:10 128:6,9

129:8,10,12

bag 456:5

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Baird 2:2 14:8,9 104:5,8

105:11,13,20,22

154:7 429:14,20

430:6,13,17 435:13

435:22 459:20 460:1

461:10,15

baked 398:10

bakery 235:6 412:13,17

412:20

balance 54:15 107:20

108:2 329:15

bales 358:10

ballpark 95:10

Ballroom 1:18 95:2

ban 112:11 188:20

189:6 426:17

banked 449:14

banned 189:3

banning 426:20

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bar 17:9 93:6 276:21

barely 326:8 362:3

barrier 233:5,8

bars 412:14

base 257:13 270:17

377:15 419:7 428:22

based 6:13 31:7 49:17

80:9 81:13 90:9

100:13 118:3 123:7

128:18 142:13 145:22

170:19 172:13 179:6

182:16 183:3,6 221:1

254:15 267:8 270:16

273:20 276:20 281:18

289:5 303:2 304:18

307:8 322:15 324:13

328:22 335:8 343:1
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basic 53:12 177:3 250:1

400:4

basically 16:15,16 23:6

179:12 181:11 224:17

242:8 346:3 348:7,15

453:21

basil 144:6

basing 254:1

basis 72:3 143:18

212:11,15 232:17

244:9,18 270:6

331:11 343:14 404:4

414:16

batch 254:7

battle 449:5

Baumgartner 2:17

357:11 362:20 363:2

363:3 366:14 368:19

bean 239:15

beans 131:9 259:21,21

260:6 447:5

bear 83:12

bearing 84:18 441:1

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becoming 45:17 186:11

186:13,15 254:15

426:18

Beddard 2:18,19

313:20 320:7,8

323:19 324:2,2

327:19 328:8 329:4

329:22 330:8 331:7

332:4,20 333:4,7,11

333:14,22

bedding 143:22 176:20

bedtime 56:9

beekeeper 11:6 15:15

15:16

beekeeping 15:22

Beeken 442:2

beer 339:16

bees 316:5,7

beet 241:6,11,14

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beg 255:8

began 252:12 457:20

beginning 67:7 229:15

321:1 341:14 415:20

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behalf 90:14 112:4

139:14 201:1 222:10

230:16 259:15 298:15

354:7 379:2 394:13

394:17 409:17,18,20

413:17 436:9

Behar 2:3 15:1 270:10

301:7 311:12 327:17

327:20 328:2,6,12,17

329:19 373:1 389:8

419:4,14 461:19

462:2

belief 114:19

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103:11 115:6 141:21

163:7 165:7 167:14

167:22 171:5 175:2

176:10 197:1 199:4

201:7 257:21 266:16

268:9 270:4 313:14

330:15 351:16 446:6

446:15

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338:17 339:9

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93:11 237:5 327:9

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158:1 163:7 168:2

169:11 424:18

benefitting 131:12

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benzene 76:19 148:3

184:5,13

Berkeley 10:16 194:14

214:7

berries 117:14 138:11

343:3

berry 165:22

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175:4 179:17 182:22

193:4,9 232:10,19

291:12 308:22 321:6

351:13 353:14 365:22

400:5 402:5 435:9

440:9 442:13

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298:7,9 300:19,20

301:19

betrayal 132:13

Betsy 67:8

better 33:8 46:10,14

60:21 132:4 155:5

158:2 160:4 178:21

183:15 234:9 240:3

253:14 267:22 280:9

310:8 361:16 401:9

416:20 418:18 419:2

419:2 422:14 433:12

435:11

beverage 236:13,20

239:7,9

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398:4

beyond 3:12 4:14 75:1

78:10 261:6 267:11

268:19 271:12 272:3

280:20 322:11 334:9

438:22

biannual 17:19

bias 409:14

big 23:19 27:2 37:12

44:19 167:7 198:7

208:17 209:19 218:4

225:16 260:4 261:5

437:19 454:21 456:5

bigger 186:6 188:17

300:4

biggest 108:6 196:7

260:7

Bilchak 2:19 199:20

205:13,13 208:12

210:3 212:19 213:2

bill 45:5 158:12,21

189:4,5 253:20

256:20 409:8 414:21

415:10

billion 33:4,7,10 50:8

65:21 336:2

bills 57:19

bind 206:21

binder 17:21

binding 408:14

bio- 281:17

bio-based 80:22 282:1

288:13 289:13 384:5

389:9

bio-diversity 160:2,6

bioavailable 370:20

biodegradability

389:21

biodegradable 80:21

281:17 384:5

biodegradation 316:12

biodegradeable 389:9

biodiverse 335:1

biodiversity 335:9

339:7 363:18,19

biological 100:8 110:7

114:7 132:2 140:9,13

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335:13,15 343:14

355:19 356:10,19

424:21 454:18

biologically 100:7

101:4 165:10 272:12

352:16 453:6

biology 12:7 107:21

112:22 113:3,22

117:18 118:7 325:1

331:20 332:14 385:17

386:3 388:15 390:22

391:1

bioponic 171:6 176:13

bioponics 388:7,18

biotechnology 265:15

biplane 342:2

birds 131:8 319:14

Bisphenol 76:9 78:5

bit 6:9,10 20:6 25:9

31:12 59:9,16 63:14

63:16 67:3 70:16

79:22 80:5 83:13

89:16 94:14 95:15

109:17 111:3 115:14

121:18 125:16 126:4

127:3 187:12 217:2

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280:9 285:15 296:10

318:22 351:15 386:19

406:18 433:5

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blind 374:2,8

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351:2 356:22 357:3

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7:12 8:12 10:12,21

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14:7 15:19 17:5,11

18:21,22 28:7,11 31:9

34:9 61:9 62:11,17

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73:12,14,17 74:22

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92:12,21 93:17,22

94:4 97:1,13 98:4

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108:10,10 123:15

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383:20 403:18 417:9

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Board's 200:12

Boards 205:5

Bock 2:20 381:16 383:8

394:6,11,12

bodies 113:12 136:18

181:17

body 51:21 290:20

371:14,17 407:13,17

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Bolivia 43:9

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booming 171:12

border 64:21

boric 397:9 443:17

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botanically 409:13

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bottleneck 67:16

bottom 89:3 236:15

250:4

bowel 371:20

bowl 113:14

box 230:3

boxes 204:14

Boy 445:5

BPA 76:10 279:7

BPA- 384:4

Bradman 2:3 10:13,14

92:19 107:1,5,7,10

137:5 170:10,13

171:18,21 172:2,5,19

245:12 295:17,21

296:3 305:2,5,10

355:13 381:3,8 392:8

392:20 445:9,15

446:1,9

brain 252:11 389:13

brand 126:15 138:10,11

163:15 383:18 425:17

brands 298:14

Brazil 43:7

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95:13 100:8 161:16

166:7 200:3 223:11

280:7 314:8 334:7,9

338:10 414:1

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breaking 200:1 213:6

312:10

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453:6

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Brewing 108:3

brief 8:22 10:2 70:13

171:20 172:3 189:20

briefly 8:15 133:12

288:3 379:19 392:18

bright 222:17 407:19

Brines 2:12 5:10 7:18

7:19 8:20 70:5,6

81:20 82:9 83:8,9,10

129:17 130:1 293:3

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159:2 160:17 169:2

244:12 258:11 281:16

288:15 379:14,16

383:22 444:13

bringing 88:13 134:9

153:16 264:9 384:7

391:2 416:16

brings 83:18 85:8

240:22 336:7 420:4

Briones 10:5

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356:5

broader 78:10 124:17

281:15 366:12

broadly 440:20

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Brook 13:2

Brookhaven 13:2

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313:8 371:19 391:15

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456:13,17

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62:5 158:11

buffering 370:12

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Buie 2:4 5:6 13:1,2

17:18

build 31:10 84:14

164:16 296:9 432:10

440:6

building 132:2 135:8

322:7 332:22 431:11

buildings 142:17

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333:4 437:15

bulk 52:6 225:17 228:7

bully 192:19

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Burtman 2:21 139:10

147:9,14,15 151:1,19

152:2,21 153:21

154:15 155:8,16,18

157:1,4,9

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98:3 107:9 144:1,3

171:13 222:8 252:8

255:2 302:7 307:7,9

432:11,16 437:15

businesses 21:6 56:20

131:6

busy 8:14 43:16

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199:21 298:6 394:8

449:18

butchering 302:2

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149:2,6,9 150:10

155:13 202:16 261:1

375:20

buyer 58:22

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151:10 261:12

byproducts 231:20,22

C

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128:16 190:4 193:2

262:5,18,22 264:9

cadmium 336:17,20

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371:1,4

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California 3:5 17:10

148:5,9 149:3 152:8

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289:21 343:2 344:11

344:22 345:7,10

364:4 365:17 392:3

415:22 431:7 434:3

434:20 435:1 436:7

436:10,12,14 440:4

California's 214:11

call 5:2 84:12 138:15

150:4 168:3 326:2

354:18,19 444:3

455:20 460:7,8

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223:5 229:21 249:8

252:10 259:12 260:21

294:6 324:8 341:21

387:17 458:15

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calories 113:11

Cameron 3:19 271:8

274:15,17,19 278:16

280:2

Campuzano 2:21 181:2

213:7,10 215:6

Canada 43:10 55:2

114:4 224:21 257:11

257:14,21 380:2

410:9,17

Canadian 101:21

114:10 227:17

cancer 126:12,21 148:3

184:1 244:22 296:16

cancers 183:22

cannabidiol 252:3,19

252:21 253:11 255:10

Cannabis 414:10

capability 140:10

309:22

capable 347:18

capital 9:12 442:12

capitalistic 139:3

capitalized 9:20

capitulating 326:14

captured 192:22

captures 275:14

carbohydrates 294:11

carbon 319:19 340:3

395:11

carbonate 395:10
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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care 11:2 83:19 84:7,12

89:9 111:21 112:22

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careful 107:20 133:3

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376:12

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375:1,5

carrageenan 239:13

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Carrothers 2:22 302:1

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311:15 312:22 313:18

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79:13 126:7 194:19

209:6 210:4,7,8

243:22 253:4 284:6

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212:15

cases 40:5 54:20 59:1

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casing 395:19

casings 298:15,17,18

298:20 299:10 301:9

301:12 395:17

catalog 270:20

catastrophic 218:3

catch 145:19 221:5

401:14,16

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categories 242:9

394:15

category 119:4 235:16

237:6 238:10,22

239:5 365:7

Cato 400:6,10,13,17

402:15

Cattle 4:17 259:12

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183:21 218:6 244:22

321:8 371:8

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causing 148:3 359:1

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CBP 65:17

CCOF 431:7 432:7

436:7 438:19

CDA 206:2,4,14,19

207:1 208:2,3,4

212:20

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336:2

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202:8 274:6

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164:18 274:21

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central 53:10

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CEO 4:13 251:13

Cerozi 3:6 449:17

456:17,18 459:15

460:7 461:14,16,22

462:5

certain 47:6 54:20

65:12 72:21 117:5

135:12 183:22 312:7

338:10 370:4 398:16

407:19 408:3

certainly 47:11 52:7

115:17 119:19 136:15

138:15,20 184:20

221:17 310:18 311:2

319:4 327:19 401:14

402:6

certificate 46:19,21

47:9,14,16,16,21

63:10 65:9 220:17

certificates 47:2 50:20

50:22 54:19,20,21

57:17,20 58:1 63:8

65:11

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38:1,5,9 53:8 55:18

55:22 115:8 124:3

128:17 133:5 134:3

135:10 159:10 164:10

164:15 167:18 178:22

208:9 209:1,16 212:9

224:7 228:14 246:2

248:22 254:21 255:21

266:7 275:7 358:17

360:22 362:11 383:16

383:17 407:2,20

410:3,10,16 421:9

425:20 437:16

certifications 221:6

224:5 347:19 348:9

418:22

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15:14,15 16:20 17:1

20:18,20 21:2 22:11

33:3 46:2 54:3 55:19

55:21 56:3,11,16 57:2

57:9 58:11,19 103:16

108:14 116:15 139:15

141:9,22 142:20

163:14 174:10 206:19

220:15 224:21 225:10

226:6 228:3 232:9

244:17 248:19 250:10

250:10 252:7 254:8

254:15,20 255:1,10

255:16 256:5,10

258:10 263:10 266:9

322:10 324:14,21

325:15 326:7,13

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388:12 392:3 394:14

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420:20 431:7,9 432:7

433:4 434:13,17

436:8 438:4,19

442:11,12 447:4

448:10 451:3

certifier 14:2 38:4 39:14

57:5 178:13 209:14

224:19 247:14 248:1

267:14 442:13 448:11

certifier's 37:21 268:3

certifiers 3:4 6:15 14:12

22:2 28:14 30:13 33:2

42:10,11 43:4 46:6,10

46:12,20 47:3,9,13

49:6,8,11 50:6 51:16

52:1,5,5,10,22 53:10

53:14 54:16 55:3 57:7

58:9 59:19 60:3,20,22

63:9 65:21 66:9 67:22

68:14 90:2 135:3

149:22 192:14 244:16

246:18,20 262:4,9

263:21 264:1 266:19

267:18,20 268:16

360:11 362:14,17

367:1 386:15 437:5

440:12 447:14

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certify 135:4 206:3

246:21 258:21,22

337:8 436:8

certifying 33:1 49:20,21

220:10 250:11 254:2

257:22 426:14 432:13

CFR 225:12 231:2

382:6,15,18

CFS 275:1 277:8 278:5

chain 10:11 45:8 49:10

55:15 56:5 59:13

60:20 93:9 124:11

228:5

chains 49:16 61:1

315:20

chair 2:2,8 8:8,9 9:19

13:12,13,21 14:6 15:2

17:4,8,12,18,22 18:4

61:13 62:8 63:4,13

65:19 66:22 67:21

68:9 69:21 81:19 83:4

83:11 87:16 88:14

89:8 93:5 95:20 102:9

103:9,19 105:12

106:1,22 108:22

109:8 111:12,17

115:10 116:18 118:12

120:4,19 122:2

125:12 128:2 129:11

129:13,15 130:9

133:12 134:8,13

137:3 139:6,8,9

142:22 144:17 145:7

145:15 147:1,4,8

150:17 151:22 152:3

153:20 154:4 155:7

155:15,17,19 157:7

157:10 160:11 162:4

162:7 165:1 166:15

166:19 168:12 170:5

170:8,12 171:17,20

172:1,4 173:9,13,17

173:21 178:1,9 179:3

179:18 180:20 181:1

185:1,4 189:16

190:17 192:21 193:15

196:10 199:17 203:12

204:21 205:8 208:11

208:13 210:18 213:3

215:4,7,16 219:9,11

219:14 220:1,6 223:7

223:9,13,19 227:5,9

230:6,8,11 233:4,18

234:7 237:16 241:3

241:18 242:22 243:3
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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chairman 431:6

Chairperson 1:21

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161:14 299:10 300:3

300:4 349:2

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159:15 264:6 300:11

359:12 421:10

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66:13,19 177:20

291:11 300:2 336:22

390:14,20 437:10

champion 410:3

chance 130:3

change 76:2 84:18,22

85:4 169:4 175:2,10

232:20 245:20 266:18

267:11 270:3 331:10

348:3 366:1 415:3

416:11 423:6,13

changed 116:6 266:21

283:4 385:1

changes 32:11 267:1

269:10 334:19 350:9

375:17 421:22

changing 82:7 266:14

459:1

Chapman 1:21 2:2 3:2

5:4,11 8:8,9 9:19 17:8

17:9,22 18:4 61:13

62:8 63:4,13 65:19

66:22 67:21 68:9

69:21 81:19 83:4,11

87:16 88:14 89:8 93:5

95:20 102:9 103:9,19

105:12 106:1,22

108:22 109:8 111:12

111:17 115:10 116:18

118:12 120:4,19

122:2 125:12 128:2

129:11,13 130:9

134:8,13 137:3 139:6

139:9 142:22 144:17

145:7,15 147:1,4,8

150:17 151:22 152:3

153:20 154:4 155:7

155:15,17,19 157:7

157:10,11 160:11

162:4,7,8,11,11 165:1

165:13 166:15,18,19

167:5,11,14 168:12

168:17 169:19 170:5

170:8,12 171:3,17,20

172:1,4,18,22 173:9

173:13,17,20,21

178:1,9 179:3,18

180:20 181:1 185:1,4

189:16 190:17 192:21

193:15 196:10 199:17

203:12 204:21 205:8

208:11,13 210:18

213:3 215:4,7,16

219:9,11,14 223:7,9

223:13 227:5,9 230:6

230:8,11 233:4,18

234:7 237:16 241:3

241:18 242:22 243:3

245:6,10 246:11

247:19 248:13 251:6

255:17 257:8 258:1

259:5 261:18 264:15

268:22 270:9 271:7

274:9,15 278:16

279:20 280:2,12,14

283:13 286:13 288:2

289:14,16 292:9

295:15 296:8,19

297:2 298:1,5 300:19

301:5,17,22 304:22

305:4,14 306:13

307:2 310:10 311:11

312:11 313:17,19

317:7 318:8,19 320:2

320:4 323:15,20

327:12,22 328:4,11

328:14 329:18 330:1

331:22 332:15 333:20

334:3 337:10 338:20

339:18 341:12 342:5

342:10,13 346:9

347:5 348:1,10 350:2

350:7,12 354:10

355:12 356:20 357:8

357:10 360:14 362:19

366:5 367:5 369:5

372:21 373:10 374:22

378:12,15 381:1,12

381:19 383:3,6

386:22 387:4 388:21

389:7 390:1,16

391:10 392:7 393:16

393:19 397:14 400:21

401:18 402:8,14

403:7,10 406:12

410:5,11,14,18

413:11 415:11 417:14

419:3 420:5 421:16

422:18 426:2,4

427:21 429:4,7,11

430:18,20 433:16

435:12 436:2 438:11

439:7 441:4 442:1

445:7 446:10 449:10

451:21 452:13 453:15

455:1 456:12 459:13

459:16,22 461:8,17

463:9 464:14 465:3,7

465:10

chapter 3:8 133:20

446:20

character 98:18

characteristics 123:3

Charlotte 4:19 196:12

199:19 200:5,8

203:12,13 205:9

chart 304:9 308:7

chasing 105:8

cheap 453:12

check 223:1 247:10

check-off 27:3 64:7

checkbox 118:1

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372:20 373:2,6,6

374:1,10 377:13,13

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411:10,11,12,13,19

412:5

cheeses 372:9 375:22

chemical 148:3,14

154:8 184:7 194:7,14

207:20 211:18 214:10

245:1 248:6 273:11

407:5 458:3

chemical-free 424:8

425:4

chemically 272:11

458:15

chemicals 148:2

149:12 151:8 154:1,3

154:19 184:5 193:19

194:9 214:5,11

244:19,20 247:9,11

253:13 273:3 284:20

362:15 424:17 433:10

chemistry 11:8,9

Cheri 29:14

Cheryl 4:20 215:20,21

219:15,15 223:18,18

230:11,12,13,16

chicken 11:2

chickens 11:2

chief 35:13 325:7

child 10:19 127:16

296:14

child's 253:4

children 293:15,16

294:1,9,13,15,19,22

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297:12

Children's 10:15

Chile 45:1 50:17 435:3

chime 87:15

China 364:6

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chloride 126:9,13 202:7
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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445:19,21

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285:1

choice 9:21 139:4

170:2,2,4 171:2

273:12 434:8 437:17

464:8

choices 59:22,22

choose 30:19 59:20

105:9 164:21 204:17

247:15 253:14 257:17

choosing 184:17 204:4

Chris 3:2 298:6 301:22

302:5 305:15 307:2

Christie 2:17 111:18

122:3,5,7 125:13

128:3 129:11

Cincinnati 307:9

Ciolino 3:2 298:6 302:5

302:6 305:8,13,19

306:2,19

circle 313:21

circular 162:19

circulate 152:3 249:10

249:12

circumstances 175:13

192:6

cite 210:14 331:1

407:12

cited 281:22 303:11

309:3 463:5

cities 146:12 218:13

citrate 74:3 77:3 373:1

373:3

citric 396:11

citrus 231:17,21

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civil 37:10

civilization 423:7

claim 163:2 222:12

417:21 421:4

claiming 199:5

claims 399:19 416:18

417:1,4,10,19 419:17

420:10,18,19 421:5

450:21

clapping 438:12

clarification 98:6

256:14

clarify 83:4 124:20

179:4 266:2 273:21

288:7 295:17 461:11

clarity 161:2,5,13,20

198:9 209:5 267:2

356:6 386:4

class 123:8

classes 247:12

classic 101:9

classification 79:5,20

classified 79:6,6 89:17

126:13

clean 58:4,4 219:5

226:9 234:20 299:14

clean-down 226:2

cleaned 140:21

cleaner 274:1

cleaning 299:16 445:15

cleansers 371:21

clear 31:5,6 48:2 51:15

71:16 83:6 99:1 123:6

124:21 125:10 135:6

176:13 177:1,7

179:10,16 186:14

188:7 193:6 197:4

230:3 263:1,20

288:17 289:8 318:3

360:2,11 363:9

385:13 409:7 421:13

436:20 453:18

clearance 62:22 68:6

69:9 258:15

cleared 313:9

clearing 303:14

clearly 142:4,9,19

179:14 283:2 300:17

304:7 309:2 324:13

376:3 407:18 409:1

453:22

clears 288:15

click 97:16

client 184:1

clients 181:8 183:12

394:13,18 395:8,15

Clif 17:9 93:6

climate 163:10 416:11

459:2

climates 266:14

clinical 400:10

close 36:8 63:1 78:11

80:13 133:12 174:9

197:21 416:5 459:9

closed 48:17

closely 24:16 25:16

64:11 361:5

closes 48:11

closing 36:13

closure 38:13

closures 38:22

cloth 178:15,20

clover 447:6

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co- 11:13 228:11

Co-Director 4:3 130:14

co-found 10:14

Co-Founder 2:16

co-mingled 233:14

co-mingling 225:13,14

227:21

co-op 13:21 16:2

225:19

co-ops 224:2

coal-based 446:4,6,8

Coalition 2:17 3:14

4:22 112:2,5 122:8

138:16 186:2 196:16

196:19 199:2

coat 374:12

coated 411:9

cobalt 279:12

cockroach 443:19

coco 166:2,5,6 451:8

455:10

coconut 43:9 100:5,13

100:17 102:12,15

103:6,12 109:20,22

109:22 110:2,5,19

352:20

code 63:10 64:17 65:4

codes 63:7 64:18

coffee 394:16

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coir 100:5,13,17 102:12

102:15 103:13 109:20

109:22,22 110:5

166:2 451:8 455:10

cold 332:8

colder 332:7

Colfax 222:21

coli 338:18 396:8

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collaboration 268:10

collapsed 456:6

colleague 235:11

241:20 310:19 313:1

313:15 351:11 379:3

colleagues 86:12 382:2

410:9 414:7 432:3

collected 140:18

collection 406:3,4

college 213:15

Collins 218:11

colloidal 340:13

colon 183:4

Colorado 1:20 3:18

6:10,12,12,13,16,17

6:21 12:2,5 185:19

187:10 196:1,2

205:14,17 206:4

207:22 210:13 213:13

216:7,13 217:4,8,10

217:16 219:7 364:3

413:18,19

combination 103:6

275:16 284:19 343:17

419:13,16

combinations 312:4

combine 183:8

combined 348:21,22

407:13

combustion 315:7

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71:20 82:12,15 83:16

87:18 106:17 108:8

108:10,18 116:10

151:9 154:16 162:1

169:17 190:16 203:5

213:22 219:21 226:5

246:6 248:2,8 249:17

250:3 251:1 255:21

256:17 282:10 285:11

285:17 301:9 313:21

321:21 330:16 332:2

332:5 348:13 378:17

384:1,22 404:2

410:21 429:12 433:6

442:3 451:18 454:2

454:22

comes 57:5,6 82:22

117:18 125:11 150:21

153:7 166:8 187:1,11

193:17 217:5 227:20

300:4 330:11 340:11

392:21

comfort 372:17 423:6

coming 20:17 23:10,11

34:19 51:6 54:2 59:12

60:18 62:15 65:12

66:15 68:1,17 70:10

94:3 155:2 169:21

212:6 225:17 234:5

241:17 298:14 341:5

350:7,8 364:14

413:17 435:3 447:22

448:8

commenced 464:6

comment 9:1 35:7

48:10,14,16 68:22

82:18 84:20 85:18

87:4 89:11 91:8 95:4

95:21 96:2,6,16 98:8

99:9,17 100:1 101:1

101:21 102:7 106:19

107:15,16 134:16

152:7 190:11 211:4

245:9,13 246:12

248:1 280:5 298:21

303:1,3 309:16 353:6
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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99:10 373:13

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441:22

comments 5:12,16

17:21 85:17 86:2,4

88:18,19 100:11,21

121:11 128:19,20

137:6 147:5 169:14

170:15 172:20 186:3

198:5 203:10 205:2

219:12 220:20 265:22

267:4,8 271:15

298:18 301:8 307:14

333:21 342:15 346:10

350:4 363:7 369:21

371:5 374:19 375:1

379:4 385:2 387:14

389:2 392:4,13 395:1

398:19 399:12 400:7

403:4,20 438:20

440:12 443:2 464:18

commerce 64:10

commercial 11:5 14:15

15:21 231:7,8,15

232:18

commercially 11:5

232:22 260:11 300:16

404:8 412:18 413:1

commingling 59:5

commissioned 400:9

commit 251:17

commitment 86:9

200:12

committee 13:12 14:22

15:3 16:9 72:16 75:8

77:16,21 80:3 89:19

109:5 112:11 249:1

265:19 266:16 288:10

316:18 370:6 403:19

405:12,20 464:10

commodities 27:1

131:9

Commodity 26:22

common 49:20 84:16

291:10

commonly 277:5

314:12 398:10

communicates 182:5,8

communicating 158:17

communication 28:3

192:19

communications 4:16

23:20 157:22 406:19

communities 10:19

186:20 187:6 216:9

216:16 417:12

community 18:21 61:10

84:1,22 86:10 87:6

130:6 134:10 139:1

159:10 161:18 186:7

192:7 199:16 207:22

218:22 249:5 261:15

266:7 267:3 283:10

285:14 286:5,8 365:2

380:10 406:18 417:7

458:20

compaction 359:2

companies 191:12

231:4 250:11 303:7

421:4

company 3:5 17:9 93:6

93:12 141:17 220:9

254:4 293:10 303:7

369:14,18 374:4

375:6,8 426:7 427:15

428:2

comparable 377:6

458:18

compare 240:7 308:5

399:6

compared 239:18

375:16 400:12

compares 330:5

comparing 239:13

comparison 135:18

238:15 239:12 374:2

compatibility 351:21

compatible 276:20

326:17

compel 208:4

compelled 344:4

compelling 108:21

compensate 382:7

compensated 212:2

compensation 211:16

compete 131:7 139:1

217:13

competence 197:16

competent 50:18 52:19

competing 438:2

competition 239:19

367:15 434:21,22

competitive 91:1

266:12 317:1

complain 434:22

complained 432:16

complaint 39:21 40:1

67:3

complaints 28:19 36:7

36:9,13,16,22 37:6

40:11 66:15

complete 41:7 43:3

52:2 53:19 54:12 75:7

226:9 464:5

completed 36:9 44:7

77:12

completely 68:18 218:3

291:17 329:13 414:20

453:19

completes 82:15

complex 49:15 51:3

55:5 56:5 299:15

326:11 331:20 338:12

339:13,13,14 340:10

340:12 341:11,13

439:12

complexes 370:21

complexity 326:9

340:11 341:8,16

442:22

compliance 26:7 28:18

29:16 36:3,19 42:17

53:13 63:22 67:9 72:4

175:22 268:1,13

270:6 393:7

compliant 53:19,20

213:8 256:20 303:4

complicated 192:2

211:5,22 252:4 258:3

340:14,16 388:18

complicit 206:1

comply 30:22 56:21

351:6 368:12

complying 42:12 51:17

component 51:19

components 53:18

59:7 135:12,16 140:2

142:6,10 194:7

266:20 314:10 408:6

composed 140:7

composite 143:6

146:18

compost 108:3 109:19

110:17,18 117:5

140:5 142:7 143:7,9

143:12 145:2 167:2,8

169:4,22 177:8,12

282:11,13 340:19

341:5,14 352:19

431:17 451:8 454:6

457:15

composting 109:14

110:12

compound 252:22

compounds 183:5

386:11 393:10

comprehensive 19:1

51:15 274:1 457:22

comprise 457:12

comprised 250:10

compromise 137:9

326:3 353:19 385:7,8

391:16 392:1,10

compromising 154:22

computers 93:19

concentration 207:21

414:15 461:5,6

concentration's 462:13

concept 27:15 101:4

250:1 384:2 420:14

431:11 432:22

concern 59:11 127:11

160:14 260:5,16

261:5 262:14 269:4

285:5 289:7 301:8

317:12 336:11 370:18

371:19 380:6 401:15

433:19 434:4

concerned 147:17

152:12 171:1 202:5,7

250:16 297:18 301:13

379:20 418:10

concerning 56:12

450:7

concerns 125:2,16

126:4 172:8 201:20

263:21 282:4 290:15

359:1 370:5 399:10

412:1 445:22

concerted 34:3

concise 431:3

concluded 272:18

concludes 465:11

conclusion 400:14

concoct 453:4

concurrently 232:13

407:15

condition 252:10

conditions 101:19

102:2 104:19,22

105:5 113:20 118:11

232:7 296:11

conduct 43:22 44:10

54:7 268:8,11

conducted 34:8 214:7

307:22 315:15 363:21

364:22 400:9

conducting 12:11 43:5

43:17 47:1 54:15 91:4

conducts 28:19

confectionary 235:9

237:7

conference 134:1

confidence 21:15 85:14
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

476

197:17 214:17 218:18

221:22 380:6 397:2

confident 177:18

confinement 131:8

confirmation 22:21

25:7

confirmed 23:1 282:3

400:17

conflict 89:13 91:2,4,6

91:22 92:3 93:13,14

186:15 187:8,17

conflicts 90:18 91:11

91:18

conformance 463:20

conformity 28:17

confused 416:19

418:17 419:11

confusing 137:18

confusion 101:5 177:22

249:21 264:12 419:22

420:7

congratulate 61:16

Congress 158:3 159:6

353:10 380:16 409:6

409:8

congressional 408:17

415:4

conjunction 263:14

connections 4:13 361:4

423:2

conscious 213:20

433:8

consciousness 432:22

consensus 18:2 220:22

250:15 353:20 385:7

385:8 388:20

consent 37:9 40:6

consequence 269:8,21

408:19

consequences 363:11

conservation 16:10

24:6,7 174:21 175:7

273:16,19 277:16,18

278:1 364:7,14,21

366:11,16 367:2,21

426:19

conservationists 90:3

conserving 335:9 425:6

consider 41:2 115:19

134:20 137:21 149:15

214:19 277:19 302:14

303:15 304:16 316:18

347:17 360:12 383:21

390:11 409:15 437:19

440:22 445:4

consideration 80:3

93:8 124:21 266:1

272:7 303:9 311:5

353:4

considerations 353:8

considered 76:20 81:2

91:4,15 126:11,16

177:2 184:6 212:8,10

256:4,18 275:5,14

291:1 315:21 316:10

352:3,5 356:15

359:21 392:1 404:14

considering 71:6 75:9

203:10 226:22,22

270:18 279:2 295:14

351:21 359:5 366:15

consistency 46:14

262:21 267:15 269:14

401:7 426:16

consistent 178:17

197:4 272:8 291:18

316:20 344:19

consistently 395:16

436:22

constant 333:15

constantly 333:16

constituents 148:14

184:8 194:14 214:10

constitute 206:16

constituted 101:13

constitutes 408:15

constraints 456:2

construction 357:20,22

358:6,7 359:1

consulting 4:3 350:18

350:18

consume 239:7 255:7

317:20

consumed 345:21

consumer 4:19 24:20

85:14 127:14 133:10

137:19 138:8 140:12

143:19 144:20,20

145:2,6,9 147:16

181:12 184:16 196:12

200:9,15,20 202:12

214:17 221:22 222:7

222:19 237:4 274:22

334:17 377:7 397:2

420:6 424:14 425:19

427:17 429:15 430:11

432:20 433:1,15

434:6 437:17 438:1

consumer's 335:2

424:7

consumers 16:18 21:14

27:15 85:9 90:4 115:1

115:3,4 128:1 139:4

141:19 148:12 152:11

164:11 171:1,13

177:20 185:22 187:19

200:18 201:2 202:17

203:3 204:3 223:5

236:7 241:21 249:19

290:17 336:8 372:15

374:17 378:6 396:22

404:11 409:19 411:16

416:19 417:7 418:7

418:17 419:18 420:2

430:7 433:8 435:15

449:1

consumers' 218:18

consuming 253:17

consumption 146:12

372:5 376:15 400:15

409:4 412:2

cont 5:16

contact 152:18 212:17

258:13 427:3 458:13

contacted 294:20

contain 199:8 235:5

297:11 325:1 405:10

458:18

contained 373:15

container 104:6,10

105:17 107:13,14

111:4 113:3,16 114:7

114:15 117:4,15

118:22 120:16 121:3

137:11 142:1,13

165:8 166:11 167:1,4

167:7,20 168:1

170:19 172:9 176:9

176:16 179:7,13,16

179:22 237:3 244:1,3

275:18 323:2 328:21

329:1,3,8 351:5,9,17

351:20 352:12,18

353:3,4,7 354:1,5,16

354:17,19 384:17,18

385:12 391:6 392:11

426:13 427:20 428:14

444:12 452:16,17,19

453:10 454:3 455:12

455:18 456:7

container- 324:18

container-based 450:7

451:7,12,19 453:13

container-growing

331:1

containerized 142:5

containers 99:21

103:21 104:3 105:10

106:9,15 107:17

113:18 114:1,13

115:5,20 116:16

118:15 119:21 132:11

139:17 165:22 169:20

177:1 179:9 275:22

328:19 351:3 357:3

384:5 390:5,18

444:15 453:19,21

455:17

containing 231:13

377:10 378:7

Contains 45:7

contaminated 187:15

188:15 193:22 214:21

217:18 221:9,11

246:9 260:19 282:8,9

282:12 301:10 404:20

405:6,10 447:19,21

448:4

contaminates 404:13

contaminating 149:17

206:7 447:20

contamination 59:5

182:20 187:10 206:14

206:16,20 208:10

260:4,14 261:13

404:15,21 405:3

406:4 424:2 425:15

427:1,4 447:18

contempt 207:12

210:16

content 136:5 250:18

297:18 330:5 340:3

382:9 408:3

CONTENTS 5:1

context 268:11 272:5

299:8

continental 364:22

continually 209:13,14

continue 45:11 97:10

110:4 131:17 144:22

163:14 207:4,9

225:10 267:7 275:12

275:18,21 322:16

333:3 352:9 353:21

358:15 391:8 394:4

425:21 426:14 427:11

436:13 437:21 459:10

continued 50:20 94:11

115:5 208:7 265:7

369:15 376:11 399:8

411:7

continues 61:18 85:12

196:21 218:17 271:18

282:17 322:14 323:10

continuing 263:2 380:8

continuous 178:14

268:20 346:1 404:7

404:19

continuously 132:9

329:16

continuum 176:8,12,17

contract 138:17
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

477

contractors 29:18

41:15

contracts 57:20

contrary 169:6 253:22

292:4 371:10

contravention 408:17

contribute 400:19

contributed 450:14

contributes 399:20

412:7

contributor 450:6

contributors 412:4

control 20:11 30:13

34:4 50:5,13 51:13

53:2,11 58:8 236:14

289:22 291:15 309:14

309:21 312:6 314:20

317:2 319:8 343:7

397:6,10 400:2 424:2

controlled 64:22 232:5

334:22 335:16,18

controlling 240:15

317:4

controls 18:8 45:9 61:1

235:22 236:22 315:6

396:4

controversy 203:1

convene 354:2

convenience 378:7

convening 353:15

conventional 107:2

214:14 226:7 230:1,2

242:11,15 310:1

311:13,17 312:7

317:14 330:12 343:2

345:22 346:13,18,21

349:7 368:1 369:3

388:14 399:4 434:13

437:7 440:15 456:9

conversation 124:5

170:1 188:11,16

189:9 192:10,14

441:13

conversations 93:19

265:17 300:10

conversion 174:20

277:12 356:2 364:13

369:3

conversions 364:1,2

convert 340:18 348:3

363:9

converted 175:7 231:22

384:2,4 428:13,15

converting 273:16

277:9 366:9 367:19

convince 138:18

cook 213:17

cooking 213:20

cooling 444:19

cooperation 66:11

cooperative 4:18

133:18 298:10,12

coordinator 4:8 357:15

copies 212:20

copper 290:3,16,22

291:4 292:2 336:17

397:11

Copper's 290:18

coppers 290:3,3,5

291:7,17,22 292:5

copy 121:7

core 30:1 35:19 55:2

352:20 440:16

corn 51:5,9 259:21

260:6 261:8 405:7

447:5 448:7

Cornucopia 4:3 130:14

136:11

Cornucopia's 130:21

corporate 130:6 132:7

corporation 135:22

406:6

correct 103:14 104:7

116:21 143:4 144:8

179:11 306:3 430:9

446:7 461:13

corrections 17:21

corrective 34:10 42:19

52:14

correctly 235:20 269:7

283:22

correlation 400:6

cost 226:9 368:3 405:4

cost-share 24:13,14

Costco 120:13 299:6

costing 448:1,14

cotton 26:4,17

Council 3:16 13:18 16:8

277:14 369:19 398:1

Counsel 23:21 39:21

counter 334:20

counterintuitive 426:21

counterparts 388:14

437:7 440:15

counties 20:1

counting 216:14 396:22

countless 86:11 87:4

countries 31:2 33:4

43:11 50:11,17 51:2

65:12,21 114:10,17

159:6 160:1 379:11

380:2

country 13:11 15:9

19:22 45:21 134:1

148:11 187:1,13

189:1 218:9,13 219:8

322:12 344:22

counts 21:20

County 416:6

couple 8:2,3 20:21 33:2

35:1 49:10 80:15

116:1 126:6 186:5

188:3 224:6 238:21

262:20 307:15 308:8

428:7 445:9

coupled 266:18

course 10:22 24:7 26:5

146:10 224:7 227:18

260:6 269:20 287:10

courses 252:16

court 1:19 132:15

207:12 208:19 209:8

210:11,13,15,16

464:13

courteous 93:16

Courtney 3:10 29:14

174:2 181:1,2,5

courts 133:9 211:17

cover 18:9,14 20:6

104:4 148:2 168:22

169:10 209:20 321:22

332:12

covering 103:22

covers 103:22 104:2

coveted 326:12

cow 295:5

cow's 294:13

cows 110:15 131:4

418:7 448:2

CP 3:20 4:2,5 230:19

234:3 238:3 382:1

crafted 207:14

cream 415:21

creamery 4:17 415:18

415:19 416:2

creamy 374:10

create 90:22 110:5,17

111:8 132:3 171:8

183:4 196:20 200:18

201:4 269:16 353:1

417:21 431:15,20

432:15 433:13 435:14

created 59:18 107:22

123:19 124:12 164:2

202:3 353:11 406:3,7

410:17

creates 101:5 103:7,7

111:8 129:1 218:5

creating 116:7 204:3

268:17 277:8

creation 197:3

credit 33:11

Crisantes 3:3 99:14,15

99:18 102:16 103:14

103:17 104:1,7,12

105:18,21 106:10

107:4,6,8,16 109:7,13

111:16

crisis 363:20 458:22

463:15,18 464:7

criteria 71:10,14,18

72:2,5,9 123:20

272:14 300:15 303:4

424:14,15

critical 42:10 51:19

56:22 88:5 109:6

112:16 140:14,15

142:3 158:9 159:4

160:14 267:14 269:19

281:5 283:6 338:4

364:11 393:2 395:14

396:1,12,17 397:7

438:6

critically 87:22

crop 17:4,6 72:7,15

73:4 74:9 79:7 100:1

109:5,15 117:11

124:18 133:17 168:16

168:19,22 169:10

173:3 175:16 176:22

178:19 208:20 209:2

212:7,9 218:7 259:22

267:19 271:5 272:17

273:17 303:21,22

306:8,10 309:13

310:19 321:22 329:5

332:6 333:8 335:5,21

341:5 343:6 397:3

401:22 402:5 405:7

408:21 409:16 410:2

422:8 424:1 450:6

452:22 453:2 458:5

crop- 453:3

CROPP 4:18 298:10

cropped 366:10

cropping 332:12

crops 9:7 26:4 72:13,16

72:19 78:7 80:3,21

93:10 102:4 112:11

116:21 117:1 147:19

148:6 149:2 153:5,8,9

154:17,20 155:6

188:10 198:19 218:22

248:7 260:7 261:12

265:19 266:16 269:6

277:21 279:19 291:11

302:12 303:10,18

304:19,21 310:22

316:18 321:22 324:19

329:6 330:6,7 331:3

331:16 335:2 337:8

341:1 343:9 346:7
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

478

352:19 396:15 404:13

405:14 423:21 448:3

448:4 457:4

crowd 183:7

CRP 364:14,15,19

367:3

Cruciferous 183:17

Cruse 3:4 259:7 261:21

262:3,3

crust 113:15 114:2,11

114:21 115:21

crux 225:11 228:16

CSAs 16:19

CSF 276:18

Cuatro 2:16 403:16

405:1

cucumber 165:21

cucumbers 106:6 119:6

120:15

cue 18:7

culinary 16:4

culminating 87:2

cultivated 458:8

cultivating 321:20

cultivation 334:20

337:5 409:3,11

culture 443:14

cumulative 201:19

371:9

CUNNIGHAM 429:21

Cunningham 3:5

422:20 426:5,6,7

428:4,21 429:6,9,18

430:9,14,19

curb 253:4

curious 144:18 145:16

150:19 193:22 241:19

331:4 333:9 339:7

354:14 356:6 367:12

391:11 439:8,16

446:2

current 67:12 76:11

81:15 118:20 124:9

124:17 128:15 134:22

135:7 158:10 162:22

242:19 265:14 270:2

308:14 309:14 344:20

368:16 377:22 389:12

407:4 453:17

currently 10:5 11:21

14:5 17:12 22:19

31:15,22 40:10 41:17

48:6 60:4 64:16 73:6

74:17 76:4,17 77:22

78:6,17 101:22

116:15 162:18 216:7

216:12 217:21 219:7

245:17 258:18 304:17

309:6 310:4 314:19

388:9,12 421:9 428:3

428:19 455:6

curve 286:3 342:4

custody 228:6

custom 64:21

customer 419:7 423:9

customers 171:9

185:21 222:10 260:17

346:22 419:6

cut 114:15 131:5

142:18 339:19 342:14

365:18 401:19 410:12

410:19 417:16 431:14

431:16

cuticle 311:22

cuts 158:11

cuttable 234:14

cutting 141:6

cycle 42:15 109:21

110:4 158:13 395:6

463:3

cycling 110:21 111:5

385:18 391:1

D

D 74:1,1

D.C 185:18

Da 3:6 449:17

daily 149:11 284:2

376:16,19 412:9

dairies 416:5,6,17

418:4

dairy 4:10 17:6 26:3

247:6 294:11 357:22

369:17 370:1,4 372:8

375:11,15,21 376:2

376:22 377:10 378:7

394:16 398:16 415:19

416:1,9,15 419:9

463:14,14 464:3,7

465:9

damage 183:21 211:15

212:2 255:5 448:2,4

damages 210:5,10

211:21

Damewood 3:5 430:21

436:6,7 438:16 439:4

440:2 441:16

Dan 2:8,22 13:15 81:20

125:13 134:14 136:4

150:18 166:20 173:10

173:14 189:18 192:21

193:15 241:3 255:18

269:1 278:17 283:14

300:20 301:4 302:1

307:3,3,6 327:13

330:1 366:6 367:5

401:18 417:15,17

dangerous 148:2

385:22

DARK 195:4

Darlene 3:13 307:3

313:20,22 314:3

data 106:11,20 112:20

116:7 118:18,19

119:7 120:3,12,14

198:18 295:2 299:4,5

315:13,19 402:10

430:1

database 21:17 22:2

31:13 45:4,7,12,14,15

45:16 46:9,15,17

47:15,19 48:1

databases 64:15

273:22

date 19:9 45:7 48:5

80:7,21 81:12 82:4,20

83:1,6 162:1 217:6

dated 244:14

dates 81:7,8,15 82:7

83:3

daughter 252:5,9 324:4

Dave 2:5 3:2 12:9 129:3

133:13,14,16 134:4,9

157:11 162:7,8,11

165:1,5 166:15

173:19 177:13 178:7

317:8 318:8 339:18

339:19 421:16

David 4:12 280:15

289:16,17,20 417:16

Davis 3:7 449:15,16

450:4,4 452:6,11,18

454:4 455:8,16

day 6:6 9:8 140:1

180:14 217:17 252:14

252:17 255:14 281:14

358:8 422:1 435:4

days 8:3,14 38:13 41:1

62:21,21 145:5 221:9

224:6 384:8 391:18

Dayton 341:20

DDT 244:19

de 2:4 10:8,8 373:11,13

de- 224:20

de-cert 225:1

de-certify 209:14

DEA 409:2,9

DEA's 409:13

deal 28:10 67:3 68:15

85:1,1 149:11 162:16

178:13 228:17 263:8

281:5 284:3 312:20

435:3

dealer 261:1

dealers 125:3,8 128:18

dealing 185:13 212:14

293:1,7 351:12

357:22

dealt 194:10

Dean 3:8 446:14,14,15

446:19,19

dearly 406:21

death 181:14 207:11

debate 163:1,11 198:16

decades 10:17 220:10

371:11 375:12

December 19:2

decide 133:9 135:4

163:11,13 181:18

432:20 433:15 438:6

decided 105:8 210:4

253:8 285:8

decision 115:2 283:2

408:12

decision-making

402:12

decisions 37:9 38:22

139:5 265:9 427:19

decisis 132:14

decisive 449:8

deck 99:11 111:18

129:14,15,16,21,22

139:10 147:9 157:11

162:8 174:3 185:9

196:11 199:20 215:21

219:22 220:1 223:18

230:13 237:18 243:5

248:14 251:8 259:8

274:16 280:15 289:17

292:13 298:6 313:21

350:13 357:12 369:7

375:2 378:16 383:8

394:7 397:17 403:11

406:14 422:20 446:16

449:19,20 450:1

456:13

declared 208:19

declares 206:15

decline 115:7

declining 416:15

decompose 319:22

decomposed 304:1

decomposes 304:6

decrease 175:18 218:7

decreasing 363:18

424:5

dedicated 66:1 351:4

deep 114:19

deeply 83:19 84:12

defective 411:15

defend 150:1

defenders 222:9
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

479

defense 221:15 440:19

defer 381:9

deferred 76:21

deficiency 290:21

382:8

deficient 293:20 297:19

define 142:4,9,19

163:19 169:15 179:10

273:19 318:5 388:2

451:18

defined 100:7 142:11

179:7 274:7 322:18

384:15 408:1 452:19

455:6,13

defines 284:8

definitely 152:10

179:14 190:2 195:18

361:2 362:13

definition 101:2,3,9

112:13 160:8 249:17

253:19,22 254:11

258:19 275:14 278:19

352:11,16 353:2

364:8 366:9,12

387:14 390:7,10

408:2 444:6

definitions 101:6 275:1

388:19 452:3

degradation 289:7

356:2

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face 260:16 261:6 281:5

281:8 357:19 358:17

359:11 458:21

faced 322:13 360:6

faces 113:20 320:10

facilitates 346:5

facilities 11:16 108:11

110:12 299:21 346:5

397:6

facility 169:18 451:5

456:19

facing 184:1

fact 126:19,20 142:1

151:4 152:8,13,18

158:7 232:14 244:9

264:2 306:8 309:15

309:17 312:3 313:12

324:9 325:17 331:1,5

331:9 360:6

factor 184:4 201:17

factory 226:3 301:1

457:5

facts 376:9 380:5

404:15

failed 206:4 207:7

208:2 252:15 463:22

failing 184:12 218:17

fails 443:21

failure 463:19 464:5

failures 464:2

fair 176:1 187:18

200:18 300:21 388:5

fairly 32:16 78:11 85:1

166:3 247:9 273:7

307:22 331:6

fall 34:9 40:19 71:9

74:16 80:10,19 81:3

82:11 115:3 119:21

159:3,7 161:3 170:21

235:3 242:19 267:10

281:20 303:22 388:9

399:11 402:17,20

403:2,4 405:18

falling 463:15

falls 41:8 303:22 304:6

familiar 113:5 345:11

349:6 361:12

families 131:6,11

155:14 242:14 294:15

family 3:3 4:17 12:1

86:13 131:4 220:9

248:18 259:17 343:1

410:1 415:18

fan 205:4

FAO 142:13 145:22

146:16,18

far 55:7 83:16 106:10

178:20 187:5 250:15

290:21 342:4 389:20

429:1 440:17

fare 131:18

farm 2:17 3:2,8 4:8

11:18 12:18 13:9

15:14 16:4,13,15

24:11,12 27:14,17

45:5 86:11 130:18

156:16 158:12,20

162:13 206:5 207:15

207:19 228:7,8

248:18 253:20 256:20

259:11 268:9 301:1

324:15 325:16 331:10

331:10,13 343:1

357:16,19 363:4

368:2 409:8 414:20

415:10 432:11 446:21

451:3 457:1 463:15

farmed 162:12

farmer 12:12 17:6

110:14 162:12 176:1

208:22 209:7,13

229:15 248:18 259:16

310:7 326:6 357:18

357:22 379:12 405:10

405:15,19 427:5

431:8 434:11

farmer's 13:8 16:19

27:7

farmer-owned 298:11

farmers 3:6 6:20 10:7

15:8 19:17 21:5 30:17

49:21 51:17 85:9 87:8

90:2 120:10 131:4

133:17 148:5,8

149:22 150:20 151:3

151:6 152:11 154:12

159:17,22 174:9

182:2 187:8 188:14

190:3 205:20 206:3

208:5 209:1 217:12

222:1 224:13 228:4

230:2 249:19 250:10

260:5 261:6 265:4

266:12 268:8 269:11

271:6 276:9 291:14

304:20 308:2,10

309:5 323:12 359:6

359:18 360:6 366:22

392:3 403:19 404:19

405:3 408:20 409:21

413:19 424:10 431:7

432:5,9 436:8 438:21

449:6 459:10 463:16

farming 4:12 16:21 17:7

133:22 163:3 174:7

176:12 224:2 230:2

249:6 250:21 259:17

266:13 320:17 321:12

322:5 326:2 327:2,3,4

327:5 329:21 331:12

335:8,11,12 341:18

343:10 344:16 407:4

416:12 421:20 423:17

424:1 425:12,12,16

425:20 427:10 447:2

454:18 457:5,11

farms 2:18,19 3:3,7,11

12:2 88:3 89:4 131:7

148:10 150:3 156:9

156:14 160:3,6

202:19 207:21 214:14

218:3,12 219:3 260:2

260:3 269:12 320:9

320:15 324:3 331:8

350:21 354:8 358:21

361:11 394:17 410:1

415:21 416:2,9,9,10

432:7 442:7 450:5

451:1 457:9,13,20

farmstead 304:19

fashioned 325:19

fast 161:1 443:1 445:5

faster 161:4,12

fat 370:10

fate 304:10 306:6

315:16 316:21

fatty 73:22 311:18

312:4,8 313:4,12

314:9,11 315:14

favor 401:2 431:18

favorable 314:7

favored 163:22

favorite 56:7,9 57:13

FDA 35:15 376:2,10,11

376:16 382:11 393:5

420:13

fear 405:3

feasible 286:22 346:2

feature 45:18,19 46:18

features 47:17,22 232:4

fed 169:21 294:15,19

294:22 295:3,4,19

301:9 337:17 349:10

349:14 418:5,6,7

419:18

federal 15:18 22:14

32:9 46:19,20 89:18

133:8 135:13 147:20

158:5 191:14 192:4

195:7,9,21 211:8

251:4 253:20 256:16

256:20 264:11 284:7

364:18 386:12,17

393:5,11 409:2,9,10

414:20 415:3,9

464:12

federally 256:21

feed 110:15 113:1

132:1 146:1 155:13

168:7 227:15 301:9

329:15 333:16,17

338:10 342:8 416:3

453:8 460:10,13

feedback 308:14

309:10,11 396:1

437:5

feeding 127:16 132:8

166:12 169:16 172:6

172:13,16 173:2

180:18 294:21 327:6

329:2 333:18

feedings 293:21

feeds 146:21 418:15,15

feel 29:20 42:18 47:7

125:1 175:22 187:20

229:20 234:17 236:10

239:9 249:22 252:6

254:17,22 269:13

270:15 286:11,11

382:10 419:6 441:8

feelings 88:19

feels 408:15 430:12

441:19

feet 206:11 220:19

Feldman 3:12 274:16

280:10,13,18,19

283:20 284:4 287:5

288:10,16 289:15

fellow 3:21 86:6 334:14

felt 134:10 320:18

424:12

fence 358:11

fermentation 314:17

339:14

fertigation 173:7

fertile 163:7 171:4

331:17

fertility 101:18 109:14

135:9 144:14,21
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

484

145:10 172:14 177:6

199:11,12 243:20

244:4 324:14 329:2

333:15 457:16

fertilization 177:12

fertilizer 132:9 385:19

454:5

fertilizers 163:3 169:18

172:8 177:7 324:20

329:10 332:2,12

451:9 454:2 458:3

fiber 408:7 414:14

457:1

fiberglass 166:2

field 42:22 53:6 99:20

103:22 104:20 106:12

119:5 141:14 173:4,7

262:10,15,17 263:4

264:1 277:21 279:16

289:12 308:1 336:17

343:3 358:8 365:9

439:1 448:19

field- 336:19

field-based 451:14

fields 110:1 214:14

358:2 423:19 427:4

431:17 447:20

fifth 259:16

fight 189:9 196:5

216:10 217:22

fighting 216:18

figure 161:15 194:4

360:19

figured 448:14

fill 23:12 382:4

filled 132:11 193:18

344:4

fillings 235:6 398:9

film 80:22 281:18

films 384:6

filter 413:4 455:21

457:19

filtration 140:21

final 18:18 19:11 35:6

56:8 81:8,9 82:19,19

89:6 159:3 167:16

275:13 278:5

finalization 19:6

finalize 19:3

finalized 18:18 19:4

34:17 78:12 86:16

finally 25:1 31:10 34:18

176:4 202:11 218:4

274:5 283:6 308:21

362:12 397:3 437:18

450:13

find 63:12 84:15 104:12

105:1 121:19 149:6

194:14 204:14 206:20

208:6 222:4 224:14

247:4 253:9 261:3

329:20 353:19 361:3

417:19 430:3 441:11

463:5

finding 45:20 198:19

217:12

findings 34:1

finds 303:3

fine 151:10,16 153:22

222:15

fine-tuning 248:4

fined 207:16

finish 9:8 97:8 128:4

141:20 144:8 159:2

178:1

finished 109:21 164:21

finishes 98:7

fire 291:12

firing 162:19

firm 234:13 237:13

first 10:5,22 12:21

14:20 16:21 18:13,14

18:17 36:7 37:10

53:16 63:6 71:5 79:4

83:17 89:12 99:10

111:22 112:9 121:13

133:19 140:2 157:21

165:19 168:15 170:14

177:15 200:10 215:10

215:19 251:16 262:21

265:7 281:17 292:2

302:17 307:11 308:9

310:6 328:15,15

347:8 351:19 361:4

364:21 386:10,21

392:22 413:21 415:19

417:15 431:9 447:18

firstly 407:3

fiscal 36:4

fish 275:16 385:19

457:19,21 460:2,5,10

460:13 462:6,9,12

fissures 83:22

fit 28:22 137:12 250:6

fits 424:13,15

five 30:1 38:15 42:14,15

42:16 44:10 117:15

175:5 205:14 216:16

244:16 246:20 259:19

280:21 285:20 318:18

364:13 401:13

fix 280:6 331:19 360:9

fixed 290:3,5 291:7,17

397:11

fixes 363:10

flaming 315:6

flat 423:12

flattening 416:14,15

flavor 235:8 236:8

240:21 375:19

flavorful 132:5

flee 222:1

flexibility 56:19 83:2

flexible 262:9

float 348:22

flooding 427:3

Florence 3:13 307:3

313:1,20 314:2,3

317:16 318:7,13,16

319:4,12 320:3

Florida 320:15 331:8

332:8 344:11,22

flour 398:6 401:2,22

402:2

flourish 164:14

flourished 343:22

flower 408:1

flowers 408:7

flowing 344:20

focus 30:2,11,11,14

33:19,21 49:13 59:10

59:12 124:10 128:15

130:21 132:1 166:16

281:12 335:4 346:17

436:15,17,17

focused 298:21 321:14

322:7

focusing 61:5 321:19

436:19

fogger 206:8,9

FOIA 28:3 29:17 40:18

40:21 41:9,14,15,17

41:21 42:1,2,3,8 66:1

folks 23:9,10 53:12

83:15 93:16 95:5,11

96:8,21 97:9 98:11

129:18 130:7 138:19

166:16 185:19 189:14

238:19 242:12 280:3

355:8,9 386:19

follow 105:11 119:8

120:2 166:21,22

167:18 171:18 278:14

324:3 405:20 439:5

442:8 447:13

follow- 347:21

follow-up 78:15 296:8

306:12,15

followed 9:7 181:2

223:17 248:14 259:6

261:22 264:19 271:8

302:1 307:3 313:20

320:5 323:21 334:4

342:16 381:15 383:8

413:13 415:14 422:20

426:5 429:8 436:3

442:2 446:11

followers 164:13

following 72:20 101:10

122:3 172:22 174:1

205:10 233:20 291:16

332:16 338:16,21

357:11 362:20 369:6

395:9 397:4,16 419:5

448:20 457:17

food 2:21,21 3:8,16,19

4:4,8,9,18 11:19,20

13:21 16:2 24:19,21

24:21 27:20 69:9 72:2

89:22 132:4,5,5

147:15 148:12,19

149:12 155:12 181:15

181:20 182:4,6,11

183:14 184:20 185:7

185:17 186:1,10,15

187:6,16 188:10,22

189:12 194:22 201:4

201:6,16,18 203:21

204:2 213:10,16

214:17 215:3,11

216:4,6,8,21 217:7

219:8 220:17 222:16

238:6 243:10,19

246:7 256:1 274:21

279:2,10 290:22

302:12,16 303:9,18

304:21 313:13 320:19

320:19 321:6 325:3,8

335:3 336:10 337:2,4

339:16 343:22 344:4

350:19 357:16 360:17

369:13,14,19 372:15

372:17 375:14,17

376:20,21 396:1,12

396:19,22 397:1,22

398:2,22 405:7 407:6

407:13,17 413:9

424:7,9 427:14 433:3

433:10 437:19 438:9

445:21 446:21 457:1

458:21 459:1,6

460:14

foods 71:14 95:9

105:15 148:22 149:9

149:14 150:4,13

181:13 183:9,17

184:2,19,19 202:10

202:16,19 204:1,2,8

220:11 251:4 284:5

297:9 299:6 309:19

314:12 325:5,6

334:21 336:10 369:17
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

485

370:1,2,4 372:3,8,10

372:12,14,19 375:7

375:11,16 376:2

377:9,19 378:5,7

382:10 398:4 399:5

412:3

footprint 314:8

force 112:20 116:4

162:15 165:14,15

167:15 177:11 263:5

269:11 287:11,13

391:16 450:15

forced 344:21

forces 326:15 459:6

forcing 270:6

forefront 344:1

foreign 4:7 24:11,15

28:16 31:3 34:13,14

43:6,11 44:4 50:6

51:2 66:11 383:12

foremost 112:9

forest 24:5 277:14

364:5 365:13,14,18

forests 364:4

forgive 270:17

form 138:18 205:19

231:14 297:11 300:17

341:3 370:21 376:7

408:22 411:14 413:1

428:13 460:19

formation 232:4

formed 115:15 116:5

379:13

former 277:7 450:5

forming 133:21

forms 47:4 231:1 242:6

375:9 401:3

formula 293:10,11,15

293:21 294:9 295:3,4

295:8 296:13,22

formulas 292:21 293:14

293:15,17,18,22

294:16 295:11 297:15

297:17 429:3

formulating 305:17

formulation 284:18

285:3

formulators 401:9

Fort 218:11

forth 181:10 229:15

297:21 299:17,20

328:21 441:17 453:11

forum 426:8

forward 7:21 32:5 41:10

49:2 69:20 74:15

81:22 82:5 85:6,11

87:8 88:13 101:7

151:18 176:14 197:5

209:6,8 272:6 352:8

365:21 437:11 441:13

450:11

fostering 266:7

fought 321:6 323:12

found 114:5 174:18

194:7 206:14 207:12

214:8 260:8,9,11,13

263:11 283:3 336:16

371:11 398:10 400:13

foundation 3:21 4:15

157:15 163:2,5

243:21 250:21 263:16

321:15 334:15 393:3

foundational 197:20

founded 323:6

founder 3:17,17 243:9

243:10

founding 133:17

four 27:22 150:2 169:2

198:11 227:4 281:16

318:18 462:21

four- 364:7

fourth 12:4 357:21

frack 217:9

fracked 154:13

frackers 217:13

fracking 148:3 149:16

149:20 150:1,3,22

152:16 153:1 154:13

155:3 156:12,15,17

156:20 157:2 186:18

186:22 188:20 189:3

189:6 190:20 193:18

195:9 196:3 211:6

214:20 215:2 216:10

216:13,16 217:22

218:5 219:2 361:7

386:7,11 389:2

392:13 393:1

fraction 285:2

fracturing 359:16

fragile 175:8 255:5

273:17

framework 158:6 190:9

277:10

Francis 2:9 17:3,8

102:10 115:11,12

120:20,21 165:2,3

169:15 286:14 288:2

288:5,19 310:11

337:11,11 339:6

347:6 348:10 387:1

433:17 451:22 452:13

Francis' 338:22

Francis's 62:18 166:22

166:22

Frankel 3:14 99:11

111:17,21 112:1

115:17 116:22 117:8

118:17 119:11,19

120:1,11 121:7,10,20

138:17

Frankly 127:17

fraud 380:5

fraudulent 50:20,22

224:5

free 68:20 154:18

184:19 241:7 250:17

278:10 365:9,13

404:12

free-radicals 183:20

Freedom 40:14

freely 203:6

freeze 32:1

frequently 303:12

fresh 3:7 217:11,13

336:19 407:7 424:5

456:18 460:5

freshwater 317:10,13

Friday 9:6

friend 154:8

friend's 149:2

friendly 424:9 425:5

friends 153:22 325:22

407:12 432:4,8,9

433:19

Froning 3:15 369:7

375:2,4,5 378:14

front 39:17 320:10

448:7 449:17

fronts 447:18

fruit 12:4 231:17 235:7

235:9 236:2,6 237:1,1

237:7 240:19 329:6

382:9,16,17,18 398:9

412:17

fruit-filled 412:14,17

fruits 26:16 132:21

231:12 291:13 383:1

390:4

frustrating 161:7 287:4

FSA 24:12

FSIS 35:14 420:15

fuel 182:4 455:8

full 41:13,14 70:21

75:16 121:1,8 175:21

206:22 236:7 270:6

271:3 276:8 384:21

fully 54:12 57:1 158:13

176:22 179:1 198:14

227:21 269:17 270:16

270:19 286:16 287:3

289:10 293:6 347:18

371:9 403:3 460:17

fumigated 64:9

fun 60:14

function 232:2 340:3

343:8 371:14

functional 123:8 398:22

functionalities 238:18

functionality 370:3

functionally 458:16

fundamental 130:22

131:16

fundamentally 137:19

funded 32:17 339:11

funding 32:19 45:13,14

funds 409:9

fungal 108:4 451:10

fungi 108:2 340:7

Fungicide 284:8

fungicides 397:11

further 45:16 98:5

122:12 124:13,15

143:19 152:19 170:20

186:20 197:5 278:13

300:6 385:9 386:19

397:9 427:18

furthermore 101:1

399:22 409:8

future 76:15,21 146:1

146:20 158:15 159:12

176:7 198:20 222:17

232:22 244:7,10

263:9 264:12 300:7

302:11 379:18 407:4

407:19 426:12 427:15

427:19 438:7

G

G&G 4:13 423:2

Gail 4:13 415:15 422:19

422:21 423:1

gain 120:17

gained 131:18

gaining 135:10

galactose 294:12

galactosemia 294:10

gallons 217:9

game 168:4 222:3

454:15

garden 149:4

Gardner 3:15 383:9

394:7 397:16,20,21

401:5 402:4,13,19

403:9

garlic 11:15

garnered 131:1

gas 77:8 147:18 152:16

153:1 155:3 186:8,19

186:21 190:20 191:11

211:6 214:2 217:3,14

218:11 219:3,5
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

486

359:13,17

gastric 296:11

gastrostomy 296:18

gate 463:16

gatekeeper 123:12

gather 119:16 198:17

gathering 275:12

Gays 15:2

GE 401:22 402:5,7

404:13,19 405:16

406:4

geek 442:9 444:7

gel 232:4 234:12 238:5

239:2 240:14 398:8

gel-like 235:21

gelatin 237:10

gelatin-free 235:9

gelling 231:16

general 23:20,21 28:21

34:20 39:20 92:15

175:2 309:10 376:15

399:22 400:16 452:15

generally 96:6 175:5

178:16 266:17 267:16

generate 102:3

generated 76:13

generating 429:22

generation 12:4 77:7

112:15 259:16 320:8

357:21 437:22

generations 261:4

427:15

generic 294:10

genes 182:8

genesis 198:12

genetic 158:22 161:10

250:2,17 252:10

270:1 360:3 361:10

405:2

genetically 221:12

249:22 259:22 260:4

260:9,18 402:3

genetics 266:13

genotoxic 126:10,18

274:7

geology 12:7

Georgia 320:15 331:8

344:12

Gerald 3:7 449:15,15

449:16,21,22,22

450:4

germane 290:8

Germany 43:10

Germplasm 406:3

Gerritsen 3:16 243:5

248:14,17,17

getting 17:15 36:8,12

36:19 57:9 63:1 73:17

86:19 129:15 150:13

151:11 153:8,9

159:16 167:3 168:8

180:15,16 183:13

253:16 280:3 348:18

368:9 373:21 386:4

391:17 402:21,22

GI 294:7

ginger 13:4

give 8:22 10:2 15:20

20:14 63:15 72:3 95:2

97:18 98:11 99:7

165:6,19 210:8 310:7

316:22 329:6 381:17

392:18 393:13 394:3

429:3 432:17 464:22

given 85:1 92:10

121:14 126:19,19

128:14 144:18 163:21

212:19 252:15 265:12

270:7 332:21 361:9

395:4 401:2

gives 197:17 288:18

giving 70:13 139:3

261:11 414:1

glad 146:17 328:9

361:2 373:19

glass 104:2 136:3

glazes 235:7

global 2:22 3:20 20:11

30:13 50:4 230:18

231:4 307:7 365:13

382:1 398:1

globally 232:11 380:7

globe 336:9

glycolic 74:17

glyphosate 244:13,20

244:22 245:14 246:2

246:9 247:7,13,14

248:9 284:22

GM 241:16

GMO 198:18 218:22

241:7 260:7 261:12

422:8 427:3 447:18

448:4

GMO-free 184:19

GMOs 247:5 301:9

416:3 426:20

go 8:15 9:20 18:12 25:6

25:20 32:9 35:20 42:3

43:1,14 47:15 50:3

53:13 63:1 82:17

84:11 88:4 96:2,14,19

104:5 120:19 129:16

129:21 130:1 141:19

146:7 150:4 158:20

165:4 166:4 170:20

171:15 172:1,4 174:2

187:22 189:21 191:5

191:7 203:5 204:14

209:6 214:16 220:1

223:18 226:7 227:4

230:1,12 235:11

237:11 239:6 259:7

261:1,2,22 269:16

274:16 282:15 285:8

310:21 329:7 339:18

342:17 350:10 357:12

361:20 362:7 365:19

366:7 382:13 414:6

415:6 417:17 434:12

441:13 444:12 460:14

461:8 465:14

goal 38:12,14 268:16

377:18,21

goals 20:10

God 433:11

goes 40:1 55:12 82:5

97:6,7 106:12 140:20

161:4 214:13 233:14

237:13 347:16 355:1

396:15 410:17 461:12

461:21

going 6:3 8:1,2,14 9:9

9:16 18:9,14 19:13

20:6 25:9 33:9 45:1

59:15 60:8 61:3 69:18

71:1 89:2,3,4,9,15

96:1 108:22 111:3

118:4 120:6 129:20

129:20 131:16,19

132:8 145:1 150:7

151:14 171:15,15

178:4,5 181:18

183:14 185:5,6 186:3

187:8 192:3 200:1

211:3 212:13 215:16

217:2 219:6,19

224:11,13 226:16,19

226:21 237:20 243:4

243:4 245:20 265:5

271:16 280:6 281:12

281:15 283:9 288:4

288:19,20 289:3,12

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381:3 385:8,10 387:5

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446:12 448:11 449:13

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454:14,21

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121:5,17 124:19

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189:14 196:17 215:6

225:19 228:3 249:4

264:22 286:11 289:20

311:15 312:9,22

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342:20 369:12 374:7

374:13 375:4 378:20

386:10 392:5 397:20

398:10 411:2 416:20

419:2 422:6 432:5

434:7 438:3 441:6

443:20 454:17

good-for-you 320:19

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413:12,16,17

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464:10

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34:14,15 44:4 50:6,12

50:14,15 52:20 66:11

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194:22

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224:20 225:18 226:7

228:12 446:20 447:20

447:21

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Neal R. Gross and Co., Inc.

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419:17

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221:1,2,3

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388:10

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290:21

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118:21,22 119:3

138:4 139:16 142:14

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118:21,22 167:19

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455:9

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127:19 132:19 135:3

148:20 154:2 159:2

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294:21 321:4 379:14

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442:18

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110:10,19 114:20

132:4 141:14 142:14

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222:16,18 254:5

256:21 257:3,18

260:20 329:5 333:19

352:19 444:4,16,18

456:5

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113:20 117:19 138:4

320:14 322:3 340:17

341:1 437:15

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115:22 116:9,14

117:2 139:14 143:3

166:3 217:20 249:9

259:13 266:9 316:20

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367:19 396:2 428:3

428:20 429:1 432:1,8

434:16 435:18 440:5

446:20

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101:9 102:4 103:12

104:6,22 113:14

114:1 117:14,20,20

118:3 121:4 143:3,22

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229:19 244:2,3 299:2

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329:3,21 331:3,16

336:5 352:6 355:9

390:9 394:15 414:13

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424:18 425:4,18,22

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450:12 451:14 452:16

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455:12

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105:15,16 106:8

118:15 119:3,18

120:16 143:17 146:4

146:6 167:19,21

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214:2 241:13,16

253:19 256:19 320:19

324:19 330:7 335:5

335:22 336:17,20

345:14,16 351:2

354:17 355:6 357:3

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424:3 425:1 434:9,10

435:10 437:13 444:9

444:14,21 448:19

451:2

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427:8

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119:4 141:20 143:19

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322:14 404:5 407:10

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116:5,9,22 117:8

118:2 119:1 120:11

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48:4,19 68:14 82:10

99:6 128:8 159:9

174:17 175:3 212:12

264:7 265:20 266:19

267:12 268:18 269:13

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370:20

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456:9

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108:11,18,19 116:7

181:7 199:22 215:11

258:19 280:7 320:11

334:1 369:8 382:21

413:22 430:2,3,5,16

464:18

H

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350:5

half 200:2 206:13

267:20 363:15 364:18

431:10

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131:20 437:14 459:17

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51:17 55:9 57:21

60:20 85:9 90:2 124:4

124:12,17 125:3,8

128:17 174:10 220:16

228:15 396:2 448:12

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56:1,13 66:15 72:8

75:8,17,21 76:17 77:5

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93:9 122:14 123:8

370:6 394:15 395:9

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300:13

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450:22

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147:7

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424:17

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68:9 88:14 103:10,19

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160:12,16 165:2,4

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417:15 419:3 461:18

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274:19,19 278:21

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135:21 138:10 321:19

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276:20

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315:9

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318:21

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317:5 336:11,13

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440:6

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204:5

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88:3 98:20 107:12

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368:2,8 380:21

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366:11,16 367:15

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459:1

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321:12 400:20 416:17

425:12

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462:12

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historic 291:19 410:1

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384:13

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245:21

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Hixton 456:19

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252:17

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84:5 130:4 173:6

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140:12

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259:19 435:2

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111:22

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104:21 149:2

Howdy 223:21

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270:15

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386:18

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435:20

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340:5

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412:15

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177:21 178:4 183:9

199:12 223:3,6 251:1

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343:4,12,14,16,20

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390:12 392:11 423:4

428:3,5,7,20,22

433:13,20 434:4,10

434:14,14 435:16

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118:16 119:20 325:10

390:9 425:1 437:13

439:21

hydroponically-grown

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hydroponically-prod...

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165:6 174:15 177:11

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222:6,15 243:16,18

244:1,3,8 275:2 283:1

323:1,4 324:18 327:7

330:22 336:18 339:16

339:22 340:9 341:4

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384:13,16,16 385:6

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391:13 426:8,9,10,13

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439:15 450:8,15,18

451:18 452:5 453:13

453:18,21 454:16

hypochlorous 74:18,20

74:22

I

I-70 259:18,20

IARC 126:14,16

ICL 4:4 369:13

idea 117:12,17 128:1

158:7 250:20 385:18

442:21

ideal 427:10

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193:13 248:4 361:17

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67:15 156:13 283:22

399:11

identifies 122:22

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277:13 386:10

identifying 41:2 190:6

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identity-preserved

405:14,16

IFAC 369:21 398:1,1,5

399:7,19 400:9

IFAOM 159:6

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379:7,9,13,18 380:10

380:16

ignorance 61:20

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illegally 135:17

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329:5 340:7 460:14

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449:9

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203:22 216:21 217:2

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316:2 352:12 356:1

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362:6,8 371:19

398:13 464:3

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207:19

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186:12 201:14 204:3

204:11 214:19 215:2

216:10 218:21 219:2

276:20 314:21 358:21

359:21 371:9 400:12

400:16

impair 90:21

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382:22

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225:14 227:1 406:2

436:22

implementation 68:22

264:6 365:22

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54:12 211:10 405:13

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44:16 60:21 87:9

124:16 226:20 271:19

273:9 426:16

implicated 201:16

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63:18 65:9,11,16 68:4

257:2,3,15

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52:10 57:21,22 59:6

88:1,9 108:3 110:22

112:16 122:11 141:10

141:15 145:13 159:8
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276:9 298:22 306:18

319:20 320:11 322:20

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382:5 384:10 417:2

417:11 454:19 458:14

463:2

importantly 9:11

409:20 413:7 457:2

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importers 49:6 228:15

importing 224:18

imports 25:17 34:21

35:3 60:21 61:2 64:7

64:8,15 65:3,11,12

227:11,12,14 228:22

229:6 261:10,10

310:5 448:7 449:2

impressed 86:3

impressive 86:21

improve 30:8 35:2

50:15 66:16 88:7 89:3

89:3,4 156:4 343:8

404:1 457:16

improved 201:9

improvement 33:14,20

33:22 38:15,18

175:11 268:20 331:12

331:21 333:15

improvements 30:9

31:7 34:3 45:12,13,16

267:12 270:4

improving 57:10 67:14

135:9 183:12 243:20

278:2 331:13,17

343:9 344:5 423:8

impugn 98:18

impurities 413:4

in- 262:16 263:3

in-demand 409:16

in-field 264:4 440:5

in-ground 104:10

176:12,18

in-soil 176:17

inability 308:17

inactive 272:22

inadequate 295:12

309:21

inadvertent 427:1

inadvertently 160:2

inappropriate 276:5

inappropriately 352:12

incentive 174:14 363:8

368:16

incentivizing 369:2

incidents 295:5

include 76:1 101:3

177:7 236:6 247:13

256:7 263:1 268:3

293:13 324:18 344:10

387:15

included 41:3 43:13

116:16 183:10

includes 24:5 63:21

90:1 110:18,19

122:17 164:18 192:8

284:18 360:2 370:9

412:19 414:10,17

including 26:19 29:8

73:11 130:16 141:4

174:13 198:11 201:3

201:22 235:13 252:4

252:16 265:8 275:20

277:17 291:10 351:1

352:15 375:7 398:3

399:1 414:11 427:10

444:4 455:5

inclusion 115:5 175:21

410:3

inclusive 438:8

incoming 36:7,8,22

57:16,18

incompatible 303:12

inconsistencies 302:15

inconsistency 303:14

303:15,16 401:11

inconsistent 199:13

275:6,11

incorporate 110:9

incorporated 180:5

incorporates 273:10

451:13

increase 19:14 20:18

20:21 21:3,5 22:1

51:5,8 62:5 136:20

140:9 175:15 261:10

347:2 379:22 399:16

404:20 459:6 461:6

increased 218:10

363:18 424:11 427:2

448:8 462:14

increases 45:8 462:13

increasing 160:5

323:11 422:9

increasingly 186:14

359:9 407:8

incredibly 154:9 240:10

458:19

independent 90:7,8

197:15 200:16

India 44:5,6 159:7

380:17

Indiana 228:9

indicate 345:4 346:3

398:20 438:21

indicated 282:3

indicates 288:17

289:10

indication 127:4 294:14

indications 294:8

indigenous 10:7

indiscriminate 458:2

individual 91:21 94:8

98:19 117:19 207:3,7

276:14 382:15 426:15

individually 276:10

individuals 193:8

250:12 252:4

indoors 444:18

industrial 231:20

232:17 251:18 253:21

254:3 257:11,12

258:20 278:9 406:22

407:5 409:3 414:6,9

414:14 457:7

industrial-sized 206:8

Industries 3:18 4:16

406:20 409:18 413:18

industry 87:6 88:2

106:8 119:15 130:7

130:20 131:3 132:19

132:19 136:13 171:6

186:13,14 187:4

216:10 217:3,15

221:1 251:22 255:1

257:16 321:3 322:13

339:16 379:2 395:18

397:2 408:9 411:17

417:12 420:21 447:8

447:17

industry's 415:2

ineligible 364:12

inert 101:13 132:11

199:6 271:21 272:4

272:10,12,15,20

273:3 275:9 283:18

283:19 284:10,19

285:12 354:18

inerts 272:7 273:1,5,9

282:17 283:17 284:12

285:4,18 381:6,7,8

infant 293:11,14,21

inference 335:15

influence 191:15

influencing 408:12

info 15:12

informal 363:21 374:2

information 19:19 22:1

22:3 30:20,21 35:2

36:2 40:14,18 41:7

45:7,20 46:7,11 47:6

65:8 70:1 73:11 76:14

92:13 106:19 121:21

128:22 138:8 139:4

182:5 212:17 238:12

268:13 273:6 275:13

282:3 283:5 292:3

298:19 355:22 367:18

368:5,11 371:4

441:10,15 459:12

informed 355:7 362:14

infrastructure 186:18

358:18 359:13

ingredient 234:18

284:9,10,11,21 327:2

369:14 376:3 382:9

ingredients 11:12

48:15 53:22 57:18

126:15 132:11 213:21

214:1 232:1 235:1

238:5,13,16,19 239:1

239:4,10,21 240:10

256:11 271:22 272:1

272:4,10,16,20,22

273:2,11 285:1,12

370:9 375:7 377:20

395:15 398:2 399:1

453:5

inhibit 409:10

inhibited 338:17

initial 73:16 135:7

initiates 28:20

initiating 265:9

initiatives 21:10 31:14

injections 252:17

injunction 207:13

innocuous 283:19

Innophos 3:15 375:5,6

innovation 325:21,22

326:4

innovations 325:2

425:11

inoculants 451:10

inorganic 101:14

310:15 440:10

input 15:20 35:15 87:5

103:1,3 133:1 156:1,6

193:2 286:9 380:19

427:6

input-based 322:6

inputs 53:18,19,21,22

103:7 104:9,14,16

107:21 111:6 144:14

188:15 199:3,11

214:21 275:10 282:8

282:9 322:4 324:22

325:11 327:6 337:5
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424:16 425:2 431:21

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303:21 304:12,13

305:18,22 306:5

310:20 311:2 318:11

insecticides 303:17,19

311:6 318:17

insects 312:6,16 317:4

inserting 454:16

inside 111:4

Insider 3:17 243:9

insight 277:15 308:4

insights 427:17

insignificant 448:17

inspected 58:8 108:15

358:11

inspecting 88:2

inspection 24:22 25:15

25:18 43:2 53:8 54:8

59:6,20 225:5,9

inspections 13:10,11

42:21 47:1 52:2 54:7

54:9,10 125:7 383:17

448:18

inspector 23:20 34:19

42:22 57:5 59:22 60:1

60:15 108:16 125:6

134:6 262:10,22

263:2,15 358:5

inspectors 14:13 59:19

60:2 264:2 267:18

363:22

inspects 171:9

instance 35:5 256:8

279:5 421:1

Institute 4:4 10:6

130:15 136:11 287:7

376:17 378:22

instituting 64:7

instruction 49:17 68:4

159:9 212:12 254:1

278:14

instructions 28:9 49:5

49:5,8,19 68:1 288:18

instrumental 133:21

insufficient 309:15

insulation 166:2

intact 234:16 236:1

370:21

intake 67:15,16 201:13

203:22 376:19 412:4

412:9

intakes 400:2

integral 456:22

integrate 83:22

integrated 141:2,3

443:12 457:22

integrity 6:17,20 11:18

20:13 21:13,14,17

27:13,14,16 30:10,12

31:11,13 35:20 45:4,9

47:15 48:1 49:10,15

59:13 60:19 61:11

64:13 112:7 115:6

122:13 123:10 124:2

124:10 134:20 163:13

171:11 197:6,20

201:7 229:7 281:13

322:11,21 327:8

357:19 366:3 404:2

404:18 430:10 447:16

448:1 449:4,6

intend 403:3

intended 306:9 317:17

450:9

intensification 457:6

intensive 458:3

intent 42:7 61:19 82:12

160:7,8 351:6 441:3

intention 269:10

intentionally 70:9

interact 113:12

interaction 94:8 339:3

interacts 28:7

interchangeably 166:3

interest 14:15 40:20

60:10 89:13,21 90:1,4

90:9,13,13,17,18 91:6

91:22 92:3 93:13

130:6 263:8 327:10

interested 81:4 93:3

160:13 172:20 248:3

367:19 386:20 392:16

interesting 155:21

168:21 250:4 327:18

327:21

interests 89:20 90:10

90:12,12 91:11,19

92:13 93:15

interfere 370:16

interim-type 450:10

intermediate 338:1

462:8

intern 2:21 213:10

internal 33:16

international 2:20 3:16

4:11,15,20 24:16

28:13 29:13 31:1 32:8

108:17 134:3 157:16

230:17,21 231:3

293:10 350:21 369:19

372:6 379:8,15,16

380:10 394:12 397:22

interpretation 254:16

interpreted 254:12

interrupt 97:10 98:21

172:2

interrupting 97:9

393:22

intersecting 284:7

intersects 284:5

intervening 461:19,22

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interview 53:6

intestinal 294:6

intestines 300:2 301:1

intolerance 294:13

297:13

intra-genesis 198:13

introduce 110:2

introduced 238:17

introduces 314:22

319:17

introduction 10:2 358:9

introductions 5:5 8:16

9:15,22 99:9

intuitively 125:21

invaluable 86:10

inventory 58:2

invertebrates 316:9

317:11

investigate 380:8

investigated 335:20

investigating 51:12

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investigations 28:20

36:10

investigative 37:4

investment 33:9 321:18

347:16 348:9

invite 351:7 380:15,18

inviting 108:10

invoices 57:18

involve 41:10

involved 14:11 19:17

21:6 43:20 54:21

55:10 126:1 216:9

258:4 349:7 447:8

involvement 271:14

283:10 285:14 360:5

involving 61:2

IOIA 263:6

IOIA's 263:14

Iowa 17:6

IPPA 230:21 231:5

232:8,13

IPPA's 232:10,19

Ironically 404:9

irrigate 187:16 188:9

irrigated 148:13

irrigating 148:6

irrigation 152:9 184:4

214:9

irritation 315:10

Isaura 2:16 394:7

397:16 403:11,13,15

ISO 254:7

ISO-17011 50:18

isolated 201:17 260:2

isomer 414:18

isomers 414:18

isothiocyanate 73:8

183:20

Israel 44:4,6

issuance 175:3

issue 54:19 124:3,7

134:17 148:18 153:7

159:10,13 160:17

161:8 162:22 174:19

175:4 179:7 187:7

191:22 197:9 203:2

209:19 214:16 218:5

218:16 224:6 227:12

245:22 249:15 250:14

265:8 272:4 281:9

282:18 284:17 291:5

302:10,16 311:9

313:15 319:8 324:17

351:18 360:10,12

361:5,13,17 380:14

384:1 385:1,6 389:16

392:11 436:13 437:2

437:11 464:9

issued 414:5

issues 10:18 11:7 25:17

75:16,21 83:20 93:2

94:6 123:5 124:12

125:7 128:19 132:16

133:9 157:18 171:1

181:9 187:14 190:2,3

190:7 191:13 213:8

218:6 254:17 255:9

271:15 281:3,9,10,15

281:16 282:10 284:2

286:18 287:17 297:16

347:14 352:10 355:15

356:4 360:2,19,22

361:8,9 379:15,16

381:5,7 392:22 401:6

401:11 402:10

issuing 52:13 55:1

281:7

item 9:10 72:19,22

items 11:14 64:19

89:10 91:15,20 92:7

93:8,10 223:3 397:4

427:16

IUCN's 365:12
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J

Jackson 136:6

Jacob 122:4 129:14,19

129:19,20

jail 207:16

James 357:21 358:15

358:18 359:4,6

jams 235:6,13 240:17

382:19 398:9 412:16

Janel 4:13 248:14 251:8

251:10,12

January 18:19 86:16

Japan 201:22

Japones 77:19

Jay 3:12 274:16,16

280:12,15,15,19

283:13,14 286:13

289:14

Jaydee 279:15

Jean 299:12

Jeff 287:6 446:14,14,15

446:17 449:11,11

Jefferson 3:8 446:19

jellies 235:6,13 240:17

382:17 398:9 412:16

Jennifer 29:7

Jennings 259:11

Jenny 3:4 29:9 259:7,7

261:21 262:1,3

264:18

jeopardy 244:11

Jesse 2:4 5:6 13:1

17:17 136:6

Jessica 2:14 4:5 7:9

219:15 230:12 233:20

233:21,21 234:2

237:21 238:17 241:1

Jester 219:17,18

237:19,19 243:3

Jim 3:16 243:5 248:14

248:15,17 251:6,7

Jo 2:17 357:11,11

362:20,22 363:3

366:6 369:6

job 52:1 60:3 158:2

197:3 208:2 228:20

422:14 438:4 440:9

442:22 447:13,14

jobs 31:19 60:16

Jody 446:16 449:12,12

Joe's 150:5

Joelle 2:6 11:10 165:3

166:20 170:5 179:18

297:4 346:11 347:5

387:2 391:10 451:22

455:2,2

Johanna 379:3 381:10

join 188:18 189:8,9,13

459:5

joke 98:14

jokes 94:15 96:22 97:1

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joking 384:7

Jonah 442:2,2 446:11

446:11,12,12

Josh 182:21

journalism 200:22

judge 39:17 40:3

juice 231:20 233:12

juices 233:13 394:16

July 35:8 244:14

Jurlina 4:2 219:16

233:21 238:1,2 241:4

241:9 242:3,8,20

243:2

justice 208:6 258:16

justifications 222:12

261:11

justify 132:21

K

K2 183:5

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229:16,17 259:18

260:3

Karlin 4:3,3 350:6,11,16

350:17,18 354:21

356:8 357:1,5,9

Kastel 4:3 129:14 130:3

130:8,12,14 134:11

134:22 137:14 139:8

KDA's 256:21

keenly 345:12

keep 56:15 97:4 154:17

189:20 195:16 210:19

212:14 219:18 237:2

267:18 288:4 298:15

311:5 332:19 358:17

365:21 378:8,10

385:18 390:3 412:21

426:12 443:14,22

445:2,20 446:2 453:8

keeping 23:7,7 34:2

54:4 56:6,20 163:20

217:4 334:6 344:3

384:8 397:4

keeps 58:13 144:10

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234:3 238:3 382:2

Kelly 3:5 430:21 436:3

436:3,7

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kept 153:17 224:13

key 291:11 334:7 338:1

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kidney 201:15

kids 296:3 434:8

Kiki 4:1 261:22,22

264:19,20 265:1

268:22

kill 183:7 319:20

kimchi 339:17

kind 20:7 33:12 47:17

47:19 49:1 53:18

116:6,11 117:18,19

117:21,22 125:14,19

136:12 151:7 153:5,6

153:17 160:13 161:3

170:3,10 172:9 186:5

193:22 194:19 211:5

218:1 219:6 225:21

226:22 249:4 273:5

296:15,16 310:15

313:10 338:21 341:20

347:9 355:20 386:7

389:13,21 392:8

417:6 418:21 421:14

446:4 453:12 465:13

kinds 37:1 137:13

204:19 312:18 368:2

378:9 421:22

Klopf 4:4 362:21 369:11

369:12 373:3,12,19

Knee-deep 358:22

knew 357:5 439:12

know 9:18 19:8 32:20

50:7 59:10 61:22 63:8

63:11 68:10 69:19

83:15 94:19 102:19

103:5 104:13 105:1,3

105:4,5,19 106:5,10

106:16,17,18 107:14

107:18 108:12,13,18

111:1,8,10 115:17,19

115:21 116:3,5

117:11,15 118:3,5,7

118:14,19,20 119:1

119:17,21 127:13

133:13 135:17 136:6

136:15,16 138:9

143:10 148:1,8,9

149:13 150:11,20

151:7,13 152:14

153:4,11,14,18 154:9

161:1,8 165:13 167:6

170:14 172:17 176:4

178:6 180:3 181:7

183:3,13 184:6

188:19 190:2,19,21

191:2,3,8,19,20 193:4

199:22 203:18 205:3

216:22 222:14 224:11

224:18,21 225:6,15

226:1,10 230:4

241:21 243:22 244:21

245:4,14,21 246:1

248:3 252:21 253:16

257:10,11 258:18

279:13 284:4 286:2

287:1,4,14 299:4,12

303:16 305:21 319:8

329:4 330:8 333:15

339:6 341:19 347:15

347:17 348:5 351:13

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373:16 374:8,14

380:10 382:5 390:3

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439:22 442:10 443:21

445:20 447:22 452:21

454:20,21

know-how 341:19

knowing 148:12

knowledge 232:10,19

270:17 402:5

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272:16 273:4 411:17

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401:22 402:2,7

Kymene 126:9,14,18

202:7

L

L 414:10

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L-methionine 75:11

205:2 293:4,11,17

295:13

lab 248:1,2,11 254:8

393:2

label 27:15 62:1 85:14

88:22 89:5 122:12

123:10 137:7,13,16

138:6,21 148:19

150:12 153:12,15

155:10,11 170:16

171:8 177:16 178:4,6
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435:15,21 441:2

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label's 322:21

labeled 56:14 137:11

137:21 149:13 155:1

155:4,9 176:19

202:16 203:1,4

204:15 335:3 377:9

377:19 378:5

labeling 137:16 170:15

217:5 376:3 391:13

418:4,9 419:11

420:14 421:15 422:12

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labels 55:19 305:21

322:11,17 417:18

418:18 420:13,14,16

420:17,18 438:2

labile 337:16 338:8

labor 308:18 435:4

laboratories 245:17

labs 375:13

lack 360:2 385:12 395:5

404:10

lactose 294:12

lading 57:19

Lady 2:18,19 320:9,13

324:2

land 4:17 16:16,22

174:22 175:6,7 191:6

191:8,18 192:11

208:20 209:15 231:11

259:12 260:22 273:17

273:19 277:9,12

316:11 359:5,8,18

363:12 364:14 365:4

365:6 366:9,13,18

367:3,9,15 368:16,20

407:6 424:4,4 425:6

427:8,11

lands 277:17 364:15,19

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364:10

landscapes 356:1,3

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249:19 263:20 264:11

267:1 277:20 452:11

454:11

large 11:15 21:3 172:15

300:22 346:19 359:15

364:10 396:19 415:1

424:4 451:3

largely 264:5 340:2

390:7

larger 123:5 159:15,18

281:9 321:3

largest 50:9 133:22

272:10 298:11 320:13

411:4

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429:8 430:21 431:2,4

431:5 434:5 435:17

436:1

lastly 95:7 177:14 413:7

late 84:20 96:13

Latin 49:21 50:17

laugh 94:15 98:15

laughing 14:17

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Lauren 4:16 403:12

406:14,15,19

law 14:12 39:17 40:3,21

130:18 134:17 191:3

191:4 197:14 324:22

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laws 209:20 290:9

lawyer 209:7

lay 202:22 249:19

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leach 317:22 318:1

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lead 14:5 19:22 287:1,8

287:9

leader 163:16 287:9

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leadership 23:3 29:2

69:16 164:20 463:22

leads 40:4 224:9 268:7

leaf 311:21 317:18

397:12

leafy 335:6 336:13

349:5

learn 163:10 351:8

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leave 67:10 94:12

125:20 127:10 179:7

289:6

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276:13 408:8 464:8

leaving 127:7 271:6

led 38:21 224:18

Lee 3:14 111:17,19

112:1 115:10,11,13

122:2

left 32:9 96:18 110:8

236:18 303:18 382:4

405:21 423:18

legal 132:14 137:15,17

163:19 211:12,14

212:1 256:22 421:10

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legislators 62:4

legume 169:1

lemon 231:17

lengths 315:14

Les 99:11

lessening 136:18

let's 27:11 81:21 116:11

221:12 222:2 224:14

224:15 341:17 342:7

365:21

letter 108:9 177:4

291:18 351:6

letters 212:20

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lettuce 345:5 452:22

Leukemia 205:19

level 15:18 32:18

117:18 136:20 169:7

170:3 193:2 195:7,9

195:13,21,22 196:6

218:5 250:2 268:5

288:21 336:1 362:9

364:10 373:8 405:14

424:21

leveled 22:9

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194:8 204:9 245:16

289:4 336:20 372:2,3

427:2

leverage 58:18

Lewis 2:13 4:6,7 7:13

8:4 29:11 219:19,19

220:6,7 223:8,10

378:17 381:15 383:8

383:11,12 387:9,12

388:5 389:4,6,10

390:6,19 391:15

392:18,21 393:18

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license 207:3,4,5,17

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183:2 234:22 253:6

335:19 336:1 422:6

431:11

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178:13,17,18 274:3

384:9 444:17,19

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Lima 2:4 10:8,8 373:11

373:13

lime 231:17

limit 173:2 207:14

376:18 456:5 458:7

limitation 168:6 318:4

limited 29:19,21 45:17

315:15 329:1 370:1

459:7

limiting 348:7

limits 196:3 336:21

393:6

line 15:12 68:3,5,12

85:8 89:3 179:8 250:4

251:14 252:1 255:14

351:20 352:3 354:20

390:18,21 453:20

lineage 434:7

lined 384:5

lines 354:15

lingered 83:21

link 47:19 159:18 190:6

458:4

Lipstreu 4:8 350:13

357:14,15 361:1

liquid 101:17 132:9

144:14 145:10 166:13

168:7 169:16,18,21

172:6,8,12,16 173:2

177:6,12 180:18

199:10 275:9,10

284:15 323:3 329:1

332:2 340:20 348:13

348:14 385:19 450:18

451:17 453:7 454:2,5

liquidly 341:5

liquids 428:7,9

Lisa 2:4,12 4:18 5:10

7:18,19 10:8 215:10

215:19,19,20,22

216:3,5 372:22

373:10 459:16

lissencephaly 252:11

list 2:12 7:19 8:20 28:9

48:13 68:12 72:17

76:2,5,8 79:12,14,15

79:16,18 81:5,6 82:2

82:13,15,16 93:10

122:16,20 123:13,18

161:9 198:12 201:13

214:12 219:19 234:18

238:14 239:15 240:2

240:6 241:6,22

244:21 245:4,5,9

246:14 247:8 248:5
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Neal R. Gross and Co., Inc.

494

270:22 271:21,21,22

273:11 281:6,20

282:7 285:6,6,7,17

289:2 290:4 291:21

292:6 303:1,5 314:7

316:20 365:12 369:16

370:1 372:13 377:5

378:11 382:6 383:18

387:5,6 389:14,15

394:19,22 395:4,17

396:15 397:3,5

401:12 411:8,21

412:22 443:7,8,13,18

445:21

listed 79:11 95:15

121:3 239:22 241:20

244:22 247:8 265:10

270:22 276:10,12

308:17 376:8 382:12

382:15

listening 61:8 94:5 99:6

Listeria 338:19 396:9

listing 78:20 79:21 80:1

96:9 224:4 231:1

242:19 275:3 276:4

277:2 300:15 316:17

369:15 370:8 411:7

listings 72:17 76:3 80:2

271:22

lists 91:15 93:9 244:18

365:13 428:18

literally 15:8

literature 100:12,20,22

102:20 338:15 399:15

400:9 463:5

litigation 41:19

little 6:9,10 18:7 20:6

21:18 31:11 35:21

46:9 47:5 55:6 59:9

59:16 63:14,16 67:3

67:18 70:16 79:22

80:5 83:13 89:15

95:10,15 109:17

111:3 115:14 121:18

125:16 126:3 127:3

169:22 187:12 217:2

217:16 226:14 228:15

229:20 230:3 242:13

251:21 280:4,8,8

285:15 296:10 313:2

318:22 335:16 351:15

366:12 384:11 386:19

388:20 389:13 406:18

433:5 452:9

live 15:2 145:12 183:2

205:14 208:16 344:16

462:17,17

livelihoods 216:19

291:14

liver 183:4

lives 88:8 390:22

458:20

livestock 9:5 13:12

14:21 18:17 19:6 26:5

26:17 35:6 43:21 48:4

68:13 69:10 72:7

74:12 75:4 79:8 80:4

86:17 87:7 227:16

272:17 278:6 396:16

416:9 464:5,9

living 3:17 131:11

139:17 141:18 144:2

144:19 163:7 164:18

167:7 243:10 253:5

290:19 324:10 326:4

391:4,5

load 136:18 226:6

400:20 416:3,4

loaded 121:18

loads 226:11

lobby 132:19

lobbyist 138:17

lobbyists 130:7 132:7

local 16:1 30:22 110:14

110:14 146:11 216:14

locally 138:3 424:3

located 456:19

locust 239:15

log 226:2

long 3:2 49:15 55:5

61:1 62:20 78:13

97:11 108:14 117:20

132:3 136:13 144:22

145:11 150:6 160:21

161:9 162:13 164:13

175:12 183:2 271:13

315:20 324:21 332:18

333:2 420:18 423:10

435:18 453:2

long-lived 374:15

long-term 343:10 371:8

longer 114:16 145:10

164:15 270:11 372:14

404:14 452:22

look 7:21 30:8 46:1,1

47:5,7 49:12 53:16

60:12 64:6 65:8 67:12

74:15 81:15 85:6,11

87:8 113:5 125:22

127:3 137:15 138:9

159:17 161:14 191:7

194:3 197:5,21

222:14 255:8 279:7

281:15 284:17 295:4

299:20 309:18 310:5

311:9 319:12 334:5

336:12 338:5 339:11

339:15 340:16 342:7

361:5,14 377:8 385:4

385:6 402:6 437:19

439:5 456:8

looked 156:13 212:11

272:15 277:15 297:15

302:9 312:3 336:14

337:22 362:7 369:1

400:11 436:12 445:12

looking 11:7 25:16 30:6

33:17,18 36:17 45:20

45:22 46:4 51:12 53:7

54:4,5 64:14 65:1

66:16 67:2,14 70:7

71:11,19 107:1

116:19 117:10 121:1

136:14 146:20 147:4

156:11 189:12 212:10

239:17 286:8 309:7

326:6 347:1 348:17

359:9 361:2

looks 22:6 60:7 70:7

116:20 129:21 206:12

229:22 387:11 442:18

loophole 125:10 128:5

128:8,13 129:1 160:9

404:9

loosen 15:18

Lori 4:4 362:21 369:6,6

369:8,12

lose 120:17 163:15

164:12 172:15 208:22

433:21 449:5,6

loses 164:12

losing 62:11 131:6

loss 91:3 134:10 315:11

360:7

lost 69:13 91:17 131:13

323:14 363:15

lot 12:18,19 13:10 16:6

18:15,20 19:5,15,15

20:2 21:8,9,21 24:7

25:5 26:14,18,19

29:20,21 30:11 33:14

35:9 38:18 39:4,18

40:8,15 43:8,17,19

44:17,18,20 45:15

46:16 48:19,21 49:13

51:7,11 55:7 58:15

59:10,11 61:4,4,6

64:2 65:17 66:6,6,6,8

69:7,10 87:20 110:6,7

110:8 111:5 120:9

127:21 136:21 146:19

149:5 151:1,5,8

153:21 156:11 189:14

192:4 194:3,9,18

213:19 224:17 247:10

257:15 258:3,9,16

259:20,22 274:13

284:20 285:14 287:5

297:16 298:19 299:5

313:8,9 321:17

330:10 337:16 338:9

367:1,17 368:5 380:4

390:19 416:18 418:3

419:17,21 422:5

428:8,10 432:4,17

438:2 440:19 444:3

444:14 450:20 454:4

lots 43:11 44:1 117:11

195:15 283:16 422:13

loud 188:19 193:6

louder 452:9

loudly 150:3 186:8

Louis 198:8 293:5

love 67:5 119:22 193:2

205:21 351:7 421:17

431:14,15

Lovera 4:9 185:12,16

190:13 192:1 193:12

194:2 195:11

low 172:14 236:8 239:6

240:13 241:20,21

242:5,7,16 245:16

372:3

low- 242:10

low-methoxyl 242:9,15

lower 306:1

lowercase 9:12

loyal 419:5

lucrative 325:10 408:22

409:16

Luddites 169:6

lunch 27:2 213:6 215:6

222:22

lungs 315:10

lurch 271:6

M

M 5:10

ma 222:14

ma'am 103:17 104:7

105:18

Maarten 134:4

mac 204:13,14 374:1

macaroni 372:17

machine 226:17

machinery 457:1

macro 159:15

Madison 4:11 162:8

174:1,2,3,5 178:10

magnesium 395:11

413:6

magnitude 340:14
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Neal R. Gross and Co., Inc.

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341:11

mail 168:18

main 7:10 15:11 262:14

326:16 345:20 348:4

348:6

Maine 130:16 248:19

mainstay 352:21

maintain 45:14 56:11

59:3 112:7 156:4

197:6 322:21 325:4

344:19 345:15 357:18

377:22 413:9 424:20

maintained 325:14

maintaining 85:13

135:8 236:11 243:20

maintenance 163:6

304:19

Majestic 1:18 95:1

major 85:4 86:15 87:6

132:18 241:6 244:4,4

299:5 396:10 457:2

majority 6:14 79:17

110:13 180:8,17

284:21 300:22 324:19

345:18 349:12 399:15

433:7 436:10

makeup 348:14

making 30:2 31:7 49:3

49:7 60:5 69:5,18

82:16,17 98:17

124:13 140:14 150:14

154:20 235:2 238:10

249:4 331:17 391:2

396:7 420:18

malicious 61:19

malnourished 182:19

mammalian 319:13

man 207:16

manage 91:6

manageable 253:6

managed 383:18

management 12:17

32:3 33:15,17 34:5

141:1,2,3 421:11

443:12 464:1,12

manager 2:12 3:6,13,15

3:19,20 4:2 7:19

238:2 274:20 314:3

382:1 397:21

managing 2:20 66:2

mandating 240:18

mandatory 255:3

manipulation 250:1,5

Mann 32:8

manner 82:14 113:1

206:17 306:9

mantra 312:17

mantras 131:22

manual 89:15 96:4

268:15

manufacture 11:14,15

231:5

manufacturer 237:4

292:20

manufacturers 16:5

302:8 375:14 376:20

398:2

manufactures 375:6

manufacturing 292:21

409:4 439:16

manure 322:1 340:19

431:17 457:15 460:2

460:5,8

manuring 109:14 110:5

332:12

map 365:16

March 262:8

marijuana 408:2,5

Marin 416:6

marine 72:17 76:3

276:19

Mark 4:3 129:14,20

130:8,9,13 134:8,14

137:4,4 139:6 386:4

465:5

market 10:10 26:19

30:16,19,22 31:1

44:19 50:8 95:9

114:18 141:22 159:11

161:4,12 163:22

232:12 253:12 261:3

261:7 266:15 279:12

279:18 282:2 296:21

299:1,2 300:8 326:15

326:19 363:19 373:15

377:12,14,16 389:11

393:8,14 398:15

404:11,16 408:10

421:19 434:18 435:8

435:8,9,11

marketed 296:21

marketer 350:22

marketing 4:5 7:4 25:2

25:11,13 26:1,6 27:4

29:5 37:18 164:11

224:2,8 234:3 298:12

421:2 422:7,14

425:17

marketplace 27:18

85:13 131:1 177:22

321:10 323:11 325:7

424:13

markets 16:19 27:7

31:2,4 50:9,10 260:14

260:15 345:20 376:21

377:6 423:4

marmalade 236:2,4

Marni 4:3 350:6,6,7,9

350:13,17

Martin 3:10 114:3

219:22 220:1 223:17

223:19,21 227:6

230:9

Maryland 189:3,5

Mason 446:16 449:12

mass 54:15 235:7

236:21 340:13

massage 256:8

massive 84:21 379:21

matches 240:21

material 72:3 73:9,12

79:3,5,11,14,15,18

80:20,21 81:22 82:2

82:14 132:2 140:10

231:10,13 249:21

281:18 282:1,6

288:21,22 289:5

292:2 312:15 317:5

317:17 337:17 338:8

354:18 383:18 397:10

materials 2:14 5:9 9:7

15:3 53:20 70:3,18

71:2,3,7,12,13,13,19

72:6,15 75:14,16,20

76:4 78:2 79:8,9 80:6

80:14,17 81:2,6 82:12

100:5,13 101:5,13

122:19,20 123:16

140:6,9 142:7 143:12

198:18 199:6 202:9

231:19 232:6,15

233:11 274:3 276:14

276:16,21 281:7

284:14,20 285:20

286:7 290:7,11 291:9

304:20 305:7,12

306:16 312:19 319:3

352:20 363:13 368:21

378:22 380:20,20

394:18,22 395:3,9,21

396:14,17 399:9

413:8 428:18 443:6,7

445:16 457:15

maternity 67:10

math 225:20 448:16

MATHEWS 4:9

matrix 91:14,18 92:5

390:22 391:4,5

matter 95:17 118:5

140:8 181:13 215:13

225:12 275:19 315:3

319:18,22 340:12

408:2 437:2 465:20

matters 98:3

Matthews 456:14

463:10,12,12 465:2,5

465:8

mature 143:18 176:22

178:19

maturity 270:12

Max 3:17 237:20 243:4

243:6,8 245:7 246:11

247:20

Maxwell 3:17 243:10

McEvoy 2:14 5:2,8 6:3

7:3 8:19 18:5,6 62:7

62:14 63:11,18 66:4

67:6 68:5 69:1 124:6

155:20 157:2 211:3

212:22 246:13 256:2

258:2 259:2 367:17

420:11

meal 113:8 169:22

meals 213:20

mean 49:2 68:16 88:22

99:5 145:9,19 148:20

150:12 153:21 155:10

180:4,13 191:17

210:15 228:11 287:21

295:22 305:21 306:16

312:17 318:22 319:7

322:17 329:7,13,20

330:12 332:20,21

333:5,7,9,14 334:1

338:7,12 339:1,6

341:17 356:8 359:20

388:11 418:18,18,21

428:11 430:4 435:1

439:12 440:4

meaning 69:4 321:9

meaningful 177:19

193:10

means 142:10 153:15

171:4 323:7 326:9

361:6 387:16 418:19

422:8 430:14 457:2

meant 433:9

measure 160:4 245:15

268:20 270:5 337:20

measured 400:2

measures 225:14

358:19

meat 24:22 221:1

394:16 395:18 396:5

420:15

mechanics 389:13

mechanism 73:2

media 94:1 100:16

275:10,15 343:17

348:19,21,21 350:1

387:20 394:1,3

454:20
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medical 13:18 148:21

252:14 296:10

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Medicine's 376:18

medium 100:6 101:12

165:11 166:1 199:7

338:2 339:13 340:20

424:19 458:14

mediums 132:4

meet 52:17 54:3 123:20

142:1 147:22 177:3

251:3 266:10,14

270:8 276:21 404:17

424:11

meeting 1:9 6:9 7:22

8:12 10:22 12:22

17:15,19 38:14 52:4

70:18,22 71:1,5,8

72:14 74:15,16 75:9

76:13,15,20,21 77:1

78:20 79:1 80:10,19

81:3,3 83:17 85:19,21

91:13,16 92:11 94:1

94:12 95:1 115:3

116:2 119:21 124:6

131:14 159:3 171:10

201:11 239:14 271:3

271:16 282:5 285:14

288:11 293:5,12

310:4 335:2 354:4

357:17 399:8 401:16

402:17 450:16,21

464:22 465:16

meetings 8:4 87:21

133:16 229:15 250:9

meets 109:11 142:8

269:17 286:12

melons 13:4

member 8:16 9:14,22

10:4,8,13,20 11:10

12:1,3,9 13:1,7,14,15

14:1,8 15:1 16:12

17:2,18 18:3 61:15

62:10,11 67:1,22

68:10 81:21 87:14,17

88:15 90:15,19,20

91:9 92:19 94:4

102:11 103:11,15,18

103:20 104:5,8

105:11,13,20,22

106:4 107:1,5,7,10

109:3 115:13 116:19

117:3 118:13 119:8

119:13,20 120:5,22

121:9,12 125:15

127:2 128:3,7 129:5,9

134:15 137:5 143:2,8

143:14,21 144:4,6,9

144:12,18 145:8,16

146:14,22 150:19

151:16,21 152:6

154:7 160:13 165:5

166:21 167:6,12

168:14 169:13 170:6

170:10,13 171:18,21

172:2,5,19 173:11,15

174:9 178:11 179:4

179:19 180:5,8,11

186:2 189:22 190:18

192:22 193:16 195:2

203:14 208:15 210:21

227:10,14 228:21

229:2,4,6,9,12 232:8

233:5,8 241:5,19

242:4,18 245:12

247:22 255:19 256:13

257:10 269:2 270:10

278:18,22 283:15,21

286:15 288:6,13

295:17,21 296:3

297:5,22 300:21

301:7 305:2,5,10,16

305:20 306:12,15

310:13 311:12 312:14

317:9 318:5,9,14,21

319:5 327:15,17,20

328:2,6,12,16,17,18

329:19 330:2,21

332:1,16,21 333:6,9

333:12 337:12 338:7

338:21 339:20 341:6

341:10 346:12 347:7

347:21 348:2,11

354:14 355:13 356:21

357:2 360:16 366:8

367:6 368:14 369:18

373:1,11,13 381:3,8

387:3,7,10,13 388:22

389:5,8 390:2,17

391:11 392:8,20

395:2 401:1,21 402:9

417:18 419:4,14

420:6 421:17 422:4

428:1,17 429:14,20

430:6,13,17 433:18

435:13,22 438:13,17

439:8 441:6 445:9,15

446:1,9,20 450:5

452:2,9,14 453:16

455:4,11 456:11

459:20 460:1 461:10

461:15,19 462:2

member's 90:21

members 2:1 9:9 17:13

41:13 79:19 86:7

89:17 90:6,10 91:14

91:17 92:9,12 94:8

97:13 98:5 99:14

108:8 112:4 115:16

116:15 117:9 196:20

199:14 200:11 205:15

210:19 215:18 232:13

249:2 262:15 263:8

263:11 287:12,13

379:1,11,12 383:20

393:20 442:16 447:1

membership 15:7

249:7 250:14 391:19

memo 281:21

memorandum 64:4

273:13

memory 134:4,9

mention 19:13 92:21

93:3 146:15

mentioned 58:10 63:7

65:20 66:14 81:1

102:12 145:17 177:13

228:6 241:1 284:16

293:3 328:18 337:12

337:13 346:13 379:21

387:14 401:1 439:19

445:10 446:2

merit 243:17 258:9

message 184:18

messages 182:6

messing 329:12

met 1:18 44:13 293:9

310:4

metabolized 290:20

metals 254:8 335:6

336:14

meter 185:13 213:8

methane 416:11

methionine 293:2,20

method 101:17 314:18

372:2 425:10

methodology 21:22

methods 12:13 112:12

113:19 115:22 123:19

176:9 198:6,12,21

202:4 245:18 265:8

265:10,12 308:14

314:20 331:1 337:6

352:7 423:20 451:14

methoxyl 242:11

Mexican 44:16

Mexico 43:10 44:15,15

44:19,20 50:11 364:4

364:6 403:16,17

405:8

Miars 4:10 375:2

378:16,20,21 381:7,9

mic 234:8 280:5

Michael 147:9 157:10

157:11,14 160:11

162:4

MICHEAL 4:15

Michelle 2:11 7:6 96:14

96:20 147:2 152:1

Michigan 228:9 344:13

micro-biological

100:15

micro-nutrients 102:21

micro-organisms 183:1

microbes 164:19 304:1

396:4

microbial 458:20

microbials 254:9

396:21

microbiological 100:19

337:14

microbiologist 11:20

microbiology 111:7

microbiome 336:1,6,6

338:1 339:12

microflora 340:4

micronutrients 276:2,9

279:11

microorganisms 313:6

313:13 314:8 315:4

317:20 462:7,17,19

463:1,7

Mid- 14:9

Mid-Atlantic 10:11

midchain 315:22

middle 437:10

middles 304:5 306:10

midterm 42:17

Midwest 15:5,9 208:15

migrate 279:10

migration 317:12

Miles 2:14 5:2,8 7:3 8:9

8:19 18:5,5 61:14

62:12 69:22 88:11

97:2 124:9 152:5

154:5 155:19 210:22

246:12 255:20 257:9

258:1 367:7 379:21

420:8

milk 131:4,5 203:16

220:22 294:13 295:5

297:11,12

milks 419:17

millennial 437:22

milligrams 376:18

412:7

million 32:15,15 45:6

131:8 217:9 344:9,14

422:10

millions 88:8 340:6
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Mills 15:2

mimics 460:22

mind 14:18 101:5

138:22 217:5 227:11

257:15 283:17 426:12

445:3

mine 432:3,4

mineral 371:13

mineralization 340:2,12

386:3

mineralized 330:17

minerals 182:10,11

205:4 451:9 455:9

mingling 228:12

minimize 396:20

minimum 244:16 278:8

435:2

Minnesota 187:2

190:22 191:2,3

208:17,19

minor 412:3

minority 209:21

minus 223:10

minuscule 203:16,18

minute 96:18 136:1

222:21 381:13

minutes 17:18 95:14

96:17 99:2 147:10

186:5 189:19 210:20

288:3 334:8,10

381:18 446:13 449:14

465:12,16

Miracle-Gro 3:5

mircobiomes 335:10

Mirenda 379:3

mirroring 440:8

misleads 164:11

missed 166:14 170:9

173:18 429:12

missing 327:2 436:20

mission 24:1,3 27:12

463:21

Mississippi 13:3

320:14 415:20

mistake 432:12

misunderstanding

163:4

mitigated 359:22

mitigates 316:15

mitigation 188:13 191:4

358:4 361:15 362:6,8

mix 140:3,4 142:6 143:4

143:6,9 144:16 169:2

331:9 455:7

mixed 13:3,9 46:9

113:9 345:6 346:13

mixture 451:8 453:4

mixtures 352:19

mobile 317:21

model 167:19 172:11

270:18 322:5,7

335:21 423:14

modern 324:7

modest 32:14

modicum 408:3

modified 402:3

modifying 228:18

MOFGA 248:20,22

mold 253:13

molds 254:9

molybdenum 279:12

MOM's 10:9

moment 32:11 146:13

220:14 350:8 384:12

Monday 22:22 23:1

money 214:1 406:7,10

monitor 397:7

monitored 358:13

monitoring 358:6

Monsanto 250:3

Montana 260:12

month 44:17 62:19

67:10 345:17

months 23:11 34:19

35:1 37:3 225:4

252:12 265:17 329:8

332:7 344:18

Monty 4:11 162:8 174:5

174:6 178:3,16

179:12 180:3,7,10,13

180:22

Moon 2:18,19 320:9,13

324:3

Moore 4:12 122:4

129:14,19,19,20

280:15 289:17,20,21

moot 153:18

moratoriums 216:15

morning 9:3 10:4 11:10

12:9 13:1,14 14:1,8

16:12 17:2 18:6 50:21

70:6,12 130:13

139:18 190:15 274:14

340:22 379:21 380:7

Mortensen 2:5 12:9,10

128:3,7 129:5,9 318:9

318:14 339:20 341:6

341:10 421:17 422:4

MOSA 133:21

MOSES 133:22

Mosso 2:6 11:10,11

170:6 179:19 297:5

297:22 347:7,21

348:2 391:11 455:4

455:11 456:11

motion 79:4,5,10,10,15

79:16,21,21

motions 452:4

Mountain 95:9

Mountains 6:7

mounting 221:15

mouth 234:17 236:10

239:9

move 8:22 9:4 27:11

31:19 32:5 49:2 60:11

68:21 69:20 89:10

111:14 129:18 161:1

164:16 176:14 186:19

203:6 209:6,8 226:13

269:4 271:1 282:16

282:22 287:15,16

340:20 350:6 403:10

412:11 437:11 449:20

450:10 465:18

moved 70:9 81:22

287:16

movement 55:4 68:19

69:14 83:19 84:8,12

131:22 132:14 133:15

163:16,17 164:8

188:20 189:13 190:20

195:17 196:7 438:7,8

438:8,9 458:7

moving 22:13 35:19

42:9 45:3 67:18 68:11

93:14 97:17 129:13

272:6 288:4 338:2

365:21 439:13 449:21

Moyer 287:6

MSDS 126:17

muddied 199:4

mulch 80:22 281:18

288:13 384:6 389:9

multi 211:22

multi-billion 135:21

multi-ingredient 48:15

multi-residue 247:10

multiple 158:1 206:15

207:2,7,8 311:6 399:4

multitude 409:21

Munger 350:20 354:7

municipalities 216:15

mushroom 3:11 442:7

442:9,12 443:14

444:7,17

mushrooms 442:11

444:4,8,14,16,16,21

445:3

mutual 65:5 407:11

mutuality 84:15

mycologist 442:6

mycorrhiza 339:2,8

mycorrhizal 451:9

N

N 9:12

nagging 227:11

naled 244:20

name 10:13 13:14

16:12 17:2 98:1,9,12

99:13,15,18 111:19

112:1 122:6 126:15

130:8,10,13 138:14

139:11 147:12,12,14

157:12,14 162:9

174:3,5 181:3,5

185:11,16 196:14,17

199:21 200:6,7

205:12 213:9 216:1,5

220:4 223:20 230:14

230:15 233:22 237:22

238:1 243:6,8 248:15

251:11,12 259:9

262:2 264:20,22

271:9,11 274:18

280:16 289:18 292:14

298:7 302:3,5 307:4,6

313:22 314:2 320:6,7

321:9 323:22 334:12

342:18,21 350:14,17

357:13,14 362:21,22

369:9,12 375:4 376:8

378:19 381:20,22

383:10,11 394:9,11

397:19,20 403:13

406:16 410:22 411:2

413:14,16 415:16

422:22 423:1 430:22

431:4 436:4,7 442:4,5

446:18 450:2 456:15

456:17 463:11

names 97:18 302:2

NANCI 2:21

Nancy 139:10 147:8,11

147:14 150:17,18

153:20 154:4 155:17

157:7

nano 276:14,16 278:19

279:8,12,12

nanomaterial 278:21

278:22

nanomaterials 279:4,8

279:17

nanonutrients 279:18

nanoparticle 278:20

nanoscale 276:11

279:13

narrows 366:17

NASA's 335:18

natamycin 73:22 77:3

Nate 4:7 378:17 381:15

381:15 383:7,9,11
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Neal R. Gross and Co., Inc.

498

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393:17,21

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national 1:5 2:11,12,12

2:13,14,17 4:22 5:7,9

7:5,11,16,19 8:12,20

18:21 25:3,14 26:4,9

27:5,9,11 28:7,9,11

29:3 31:8 35:10 37:13

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51:22 56:7 61:9 63:22

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122:8 123:13,18

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196:16,19 197:11

198:17 199:1 201:13

212:4 214:15 218:15

218:20 222:9 241:22

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271:22 280:20 281:6

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316:20 324:22 359:7

369:16 370:1 372:13

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406:3 410:4 411:8,21

412:22

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Nations 10:6

nationwide 210:9

native 174:21 175:8

356:2 363:9,22 364:2

364:5

natural 4:6 11:22 24:4,5

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220:7,8 256:9 308:22

315:2 343:17 363:17

365:8 367:21 370:10

382:8 407:16 457:19

459:7

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naturally 231:10 255:6

314:10 319:2 399:17

nature 69:15 98:20

287:10 363:6,11

Nature's 4:21 134:3

292:19,19

NatureServe 365:2

Naturipe 350:20 354:7

naturopathic 13:18,19

naysayers 423:11

near 129:16 159:12

217:20 232:22 259:11

263:9 300:7 318:3

362:10 364:19 376:17

nearby 427:4

nearly 322:12

Nebraska 12:14

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120:8,13 212:8 296:5

355:8 417:22

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118:6 290:18 291:8

396:6 412:14,22

413:9 444:20

necessity 114:20 252:7

255:2

neck 296:16

need 18:7 25:4 30:5,20

36:14 57:7 95:11

117:11 123:22 148:17

148:18 149:13,15,19

150:2 153:4 169:9

177:5 181:18 182:11

183:1,12 187:8

194:20 195:9,11,13

196:7 210:14 219:4

222:3,4 230:1,4

237:14 254:18,20

261:14 265:4 271:4

274:3 277:1 281:10

282:13,20 283:7

289:8 293:17 294:16

331:21 332:13 333:14

334:10 353:13,18

355:2,16,22 356:5,6

378:10 385:5 386:3

387:4 388:19 392:22

397:8 404:15 412:21

415:4 417:6 424:7

425:9 427:9 444:18

445:20 449:7 458:14

462:14

needed 41:16 92:2

177:2 210:5 253:4

267:22 293:22 307:18

356:9 371:15 459:21

462:18

needs 101:18 111:5

116:12 120:16 158:19

163:17,22 164:19

167:3 182:10,15

198:2 199:12 214:16

251:1 266:15 269:18

282:6 324:10 325:8

325:20,21 326:19

337:6 339:10 349:18

355:7 362:10 386:2

396:19 425:19 428:13

449:8 452:18 453:10

454:13

negate 432:22

negates 153:10,13

155:8

negative 201:14 204:10

314:20 316:15 400:15

negatively 278:1 371:3

negligence 211:21

negligible 290:17

neighbor 206:6

neighbor's 448:3

neighbors 93:17

447:22 448:5

neither 232:15

Nelson 4:13 415:15

422:19 423:1,2

net 226:5

Neudorff 4:12 290:1

neuro-protectant 253:3

neutral 353:15

neutralize 183:20

never 163:20 194:10

269:10 405:8 461:5

nevertheless 19:11

new 5:9 9:9 10:20 12:3

20:9 23:5 31:22 32:2

33:2 44:4,7 45:18

46:18 47:22 48:22,22

63:2 67:8 69:2,16

70:4 73:10,11,15,19

75:12 78:14 85:1 86:7

87:9 129:22 146:8

158:2,3,4,12,18,20,22

160:18 161:10 183:5

196:22 200:11 203:2

258:6,12 274:3 282:3

283:5 292:3 309:8

320:10 322:15 325:2

344:11 363:20 364:4

365:20 366:1 378:22

380:16 383:18,20

403:16,17 405:8

423:20 442:16

newest 26:10

news 26:19

newspaper 78:16

nice 6:5 18:6 21:4 23:2

23:3 56:18 116:7

166:7

Nicholas 3:15 383:9

394:7 397:16,18

Nick 397:21

Nicole 178:21

NICU 295:22

NICUs 296:4

night 56:10

nine 26:3 29:11,16

40:19 41:8 329:8

391:18 415:21 416:1

Ninety 217:17 416:5

nitrate 386:2 454:9

nitrification 462:15,16

463:2

nitrifying 338:9

nitrogen 349:10,13,16

395:11 428:16 454:9

NOC 123:17 124:6,18

125:5 128:20 196:19

222:22

nod 324:9

NOFA 174:8

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non- 79:8 107:13

172:10

non-amidated 231:1

242:1 398:6,7

non-biased 121:21

non-bio- 289:4

non-certified 58:12,14

58:16 448:12

non-compliance 52:13

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non-food 238:6 371:22

non-GE 405:22

non-gelling 241:13

non-GM 241:14,17

non-GMO 221:13 416:2

418:13,16 419:18,21

421:4

non-natural 288:21

289:4

non-organic 113:7

159:20 261:2 297:10

non-profit 200:16

non-profits 87:7

non-psychoactive

253:1

non-renewable 315:8

non-synthetic 79:7

nonactive 272:1

nonanoate 73:14 302:8

303:8,20 304:4,11

307:16 315:18 316:1

nonprofit 265:3 379:9

nonselective 310:14

noodles 213:16

NOP 8:5,18 18:5 20:7

28:22 38:6 41:1,13

70:20 72:22 74:10

75:12 77:11 78:12,18

81:5,9 92:1 124:7,10

128:15 137:12 139:20

140:6,9 159:8 164:2

170:22 175:3 192:8

206:2 209:3,15,16

211:2 225:1 226:16

226:21 244:13,15
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Neal R. Gross and Co., Inc.

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337:3 351:7,22

356:13 366:2 380:8

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409:12,15 415:7

426:16 427:6 451:17

463:20,21

NOP's 20:10 197:15

265:20 267:12 276:13

464:5

NOP-2027 262:7,14

263:19,22 264:10

normal 101:11

normally 48:18 84:4

145:5 179:22

north 95:10 227:16

259:18 344:12 379:6

379:13,14,17,18

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70:11,22 71:21 76:20

81:13 86:7 87:1,20

89:13,17 90:6,10 91:5

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98:5 112:19 115:3,18

116:2,13 123:3,11,13

124:14 128:20 132:22

133:15 139:19 154:10

157:17 158:16 159:1

160:18,20 176:14

177:10 192:8 196:20

197:18 198:2,7,14,16

198:20 199:14 234:18

243:12,13 244:5

245:3,5,8 246:5,10

250:8 256:18 261:16

265:16 266:22 267:5

271:20 272:8 273:9

273:10,15,22 275:12

275:17 276:11,15

277:19 278:2,13,14

281:20 282:4 285:10

287:12 303:1,3

304:13,16 307:16

308:21 309:4 310:5

316:16 320:10 323:8

328:20 334:19 353:11

354:8 357:17 360:1,5

360:9,10 361:5,6

363:10 365:22 369:21

370:14 377:14 379:1

395:2 403:22 406:8

415:6 421:20 422:5

426:11 427:16,18

436:16 437:18 442:16

450:5 451:16 459:9

459:11

NOSB's 174:20 175:9

176:4 266:4 302:20

Nosb2017 9:12

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note 120:6 189:19

223:2 393:20 398:19

400:6

noted 125:9 128:14

356:15 437:8

notes 70:21 126:6

402:14

notice 62:20 206:18

317:11 328:10 334:6

353:5 373:22

noticed 225:16

notices 37:3 38:7 52:13

81:9

noticing 226:4

notified 285:10

notwithstanding 99:3

nourish 183:4

nourishing 457:4

novel 80:5

November 17:19

265:11 380:17

noxious 193:19

NRCS 16:8 35:14

number 18:9 19:3,14

20:3,18 21:2,5,20

22:8,11 31:18,21 34:6

35:11 36:9,12 37:14

39:1 40:10 63:19

66:15 106:13 115:21

136:1 140:5 141:9

142:17 146:8 151:17

193:7 196:8 210:8

216:22 244:11 245:16

279:3 311:9 368:10

390:14 398:3 438:1

438:18 439:20 442:17

454:6

numbers 39:1 85:22

106:14 119:16

numerous 88:19 214:5

nursery 112:15

nurture 409:15,21

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nutrient 101:14 105:14

140:7 143:15 144:13

184:2 275:17 290:18

340:1,19 341:15

348:17 385:18,20

386:1 458:16 460:8

460:19,21 461:4,7,20

nutrients 100:10,14

110:7 132:3 169:17

173:3 180:15,17

182:15 275:16 276:4

276:12 315:5 323:3

324:20 332:2 343:18

348:13,19 349:10,14

349:22 388:15 391:2

437:4 453:8 454:2

457:3 458:10,19

460:17 461:2,3,12

462:4

nutrition 4:21 24:20

102:13,15,18 103:8

107:18 111:4 140:11

166:13 168:8 181:6

276:1 292:19,21

293:17,22 294:2,3,7

295:11 333:2 339:3

354:17 376:9,13

461:6

nutritional 136:5,20

167:3 330:5

nutritionist 411:3

nutritious 132:5 222:16

330:13 331:4 424:8

425:5

nutshell 284:1

O

o'clock 334:7

O- 465:8

Oakley 2:6 15:1 16:12

16:13 18:3 61:15 67:1

68:10 88:15 103:11

103:15,18,20 116:19

117:3 120:5 143:2,8

143:14,21 144:4,6,9

144:12 145:8 152:6

160:13 166:21 167:6

167:12 178:11 189:22

190:18 203:14 208:15

210:21 227:10,14

228:21 229:2,4,6,9,12

233:5,8 257:10

286:15 288:6 317:9

318:5 327:15 328:16

328:18 346:12 360:16

366:8 388:22 389:5

420:6 428:1,17

438:13,17 441:6

452:2,9

oath 207:9

objection 17:22 465:18

objectionable 123:2

objectivity 90:21

objects 399:19

Observation 345:3

observational 400:1,5

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observe 8:11

observing 42:22 232:6

obsolete 271:20

obtain 175:17

obtained 231:8

obviously 127:11

281:18 287:2

occasionally 367:7

occur 314:12 362:16

364:18

occurred 86:15

occurring 94:20 314:10

319:2 399:17

OCIA 133:20

October 36:5

odd 229:20

OEFFA 358:15 446:21

OFA's 152:7

OFARM 3:10 219:22

224:1

off-annotation 439:3

off-book 272:14

offense 207:16

offer 46:19 251:19

offered 388:6

offering 47:11

offerings 377:22

offers 408:21

office 23:15,16 28:1

29:7,17 32:2 34:19

35:13 39:20 40:2 92:2

95:9 185:18 285:22

286:12

offices 23:14 25:22

officially 44:22 321:2

officials 207:6

OFPA 71:18 72:10

112:17 123:20 135:6

163:20 177:4,16

178:6 190:7 191:9

192:11 193:5 274:4

275:3 285:4 292:1,3

303:4 322:2,8 324:12

325:14 326:17 351:6

351:22 353:11 356:12

356:16 360:19 361:2

OFPA's 149:20 188:13

OGC 40:9

oh 18:7 20:14 50:3

133:11 143:21 155:12

227:7 229:1 328:6,8

328:17 350:8 373:12
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411:12 413:5

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20:15,16 22:13 25:20

35:19 42:9 45:3 47:22

50:1,4 59:9 60:9,10

60:17 62:7 63:13

70:12 71:1 72:13

74:12 75:8 78:21

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103:18 105:13,20,20

105:22 107:7,10

109:15 116:10 119:13

120:1 121:9 122:8

126:5 128:11 129:8

130:12,13 144:12

147:14 152:2 155:12

155:18 157:4,9

169:13 170:8 177:22

180:10 212:19 213:2

215:16 216:5 226:13

229:12 234:9,10

242:18 247:17 257:14

259:4 328:17 341:12

342:5 348:15 350:2

354:11 356:21 366:6

369:11 381:18 383:2

386:5 387:12 388:5

392:20 394:11 403:7

415:11 429:4 435:22

436:6 446:1,9,19

454:10 459:17,22

461:15 465:2

Oklahoma 16:14 190:1

Olam 11:11,12,17,22

old 142:16 213:12

220:13 252:12 260:20

324:6 325:19

older 431:12

Ole 13:2

Oleochemicals 3:1,3

3:13 302:6

olives 256:10

OMRI 4:10 378:21

379:4,5 380:18,19

OMRI-approved 322:4

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on-deck 262:1 274:17

342:17 378:18 410:21

442:3 449:20

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62:21 74:7 75:6 77:12

91:7 109:21 129:20

136:7 137:20 138:2

144:21 145:2 185:5

229:21 243:4 371:18

446:12 449:13 457:8

oncologist 205:18

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one-third 165:16

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58:20 81:11 86:7

104:3 182:9,9 308:16

319:1 383:21 442:16

ongoing 51:4 158:12

196:4 205:22 266:4

403:1,2

onion 11:15

online 365:13

onsite 225:5

op 465:6,6

open 41:17 48:13 61:11

62:13,17,18,20 99:20

104:20 106:12 276:13

283:6,8 311:22

353:10 387:20 389:1

426:12 435:8 464:21

opening 6:8 220:17

operated 134:2

operates 199:5

operating 6:16 53:8

135:17

operation 15:22 39:16

53:4 56:11,16 57:3

103:20 109:10 117:7

150:22 193:18 343:5

346:16 347:8 359:15

426:15 433:20 457:13

460:3

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19:14 20:19,20 21:2

21:21 22:8,12 33:4

43:2 52:8,17 55:17

57:9 58:11,13,17,19

65:22 145:18 156:3

156:15,17 244:17

246:21 268:16 269:19

322:10 323:9 343:10

347:13 351:8 352:18

352:18 360:8,12

384:4 385:13 388:11

404:22 426:17 440:21

457:7 458:8 463:17

464:4

opinion 171:3 183:10

324:5 374:7 391:12

450:10 455:12,15

opinions 355:8

opportune 128:16

opportunities 30:17

131:10,17 251:18

opportunity 8:21 98:11

99:22 102:6 122:9

124:15 134:7 142:19

174:11 268:10 307:12

308:3 310:8,18 353:5

354:9 361:20 394:19

406:21 408:21 436:20

438:6 440:22

oppose 274:5

opposed 118:21 137:19

256:1 329:2 366:11

368:17

opposite 327:7

option 204:6 234:21

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429:2 437:9

oral 85:18 399:12

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97:9 141:12 149:4

163:22 207:13 210:17

211:21 235:19 300:5

341:10 364:20 367:14

369:8 415:3 427:18

orders 27:4 37:2 49:1

57:19 69:3 340:13

Oregon 11:3 130:16

211:17 260:12 364:3

organic 1:5 2:11,12,13

2:15,17 3:5,8,10,17

3:19 4:1,7,10,11,22

5:7,9 6:11,17,19,22

7:5,7,12,16 8:12

10:10,10 11:13,14,18

12:3,13 13:2,11 14:3

14:10,11 15:5,8,12,14

16:1,7,10,20 17:6,7

18:16,17,20,21 19:6

19:14,18,20,21 20:2,4

20:11,12,18,20 21:2,3

21:6,13,15,17 22:4,11

24:14 25:3,14,16 26:5

26:9,19,21 27:6,9,12

27:13,14,15,19,20

28:7,11 29:3 30:10,12

30:19 31:3,4,6,9,11

31:13 33:3,5 34:15,20

35:5,10,20 37:13 39:5

39:15 40:13 44:16,20

45:4,9 47:2 48:4,15

49:4,9 50:4,7,8,13,19

51:5,9,13,14,17,18,22

53:2,9,16,17,22 54:1

54:3,11 55:20 56:8,14

56:16 57:16,17,20

58:7 59:12 60:15,19

61:9,10,11,17,21 62:1

62:1,3 63:22 64:8,9

64:18,18 65:2,3,6,9

66:21 68:3 71:14 72:2

72:4 83:19,22 84:7

85:9,13 86:9,17 88:8

88:22 89:5,22 92:22

101:20 103:16 107:5

107:9,13,14,17 112:8

112:17,21 113:3,10

113:16 114:1,15,16

115:2,6,8 116:15

118:15 119:3,9,12

120:9,15 122:8,12,13

122:18,20 123:10

124:1,10,16,17,21

125:6,11 126:1

127:14 131:4,7,22

132:2,12,14,18,20

133:4,10,18,22 135:2

137:2,20,21,22 138:6

139:1,16,17 141:2,4,9

141:22,22 142:2,20

147:18 148:6,9,11,19

148:22 149:2,9,14,17

149:22 150:3,9,11,11

150:20 151:10 152:11

153:8,11,11,13,14,15

153:22 154:12,17,18

154:18,20,21 155:1,4

155:9,21 156:3,3,9,14

158:1,5 159:9,13

160:6 162:12 163:1,2

163:5,13,14,20,21

164:4,8,10,13,17

167:13 169:22 171:4

172:10,11 174:7,8,10

174:14,15,17,22

175:12,16 176:2,7,15

176:19 177:3 181:12

181:15 183:11,17

184:6,16 185:21

186:2,7 187:16,21

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217:5,19 218:16,20

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221:10,10,11,20

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225:21 226:6 227:15

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254:2,6,15,20 255:1,6

255:10,15 256:3,6,10

257:12,20 258:11,21

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261:15 262:7 265:2,3

265:15,20 266:2,5,7

266:11,13 267:2,13

267:16,18,22 268:3

268:12,15,16,17,18

269:5,15,17,18

270:11,13,21 271:3

271:14 272:7,17,21

273:4,17 274:20

275:7,11 276:15,19

276:22 277:10,22

278:3,6,10 279:2,5,9

280:21 281:4,14

283:2,11 284:5

285:18 286:10 291:8

291:11,12,19,20

292:20 293:13 295:3

296:20 297:14 298:11

298:13,13,16 299:2,7

299:22 300:2,17

302:12,16,19 303:9

303:13,18,19 304:20

304:21 307:18 308:2

309:4,18,19,22 310:7

312:17 314:15,19

315:3 316:22 317:1

319:18,22 320:1,13

321:9 322:3,5,21

323:2,6,13 324:8,15

324:21 325:5,8,11,15

326:2,7,13 327:3,4,5

330:12 331:11 334:16

334:20,21 335:3,8,11

335:12,14 336:9,13

336:15,20 337:4,8,16

340:12,16 341:18

343:3,12 344:6,20

345:4,9,20,21 346:7

346:14,15,19 347:2,9

347:12,13,19 348:3

348:12 349:5,8

350:19 351:2,5,9,17

352:20,21 354:1,5

357:4,18 358:3,5,12

358:16 359:7,20

360:11 361:15 362:3

362:11 365:2 366:4

366:18 367:11,20

368:1,6,12 372:15,18

377:5,12,18,20 378:2

378:9,21 379:2,10,15

379:16,22 380:7,9,16

383:12,16,19 385:14

388:9,11 390:4 392:3

395:5,18,19 396:11

396:18 397:1,9 398:4

398:8,11,14,16,16,20

399:4 401:3,7,8

403:18,21 404:4,4,6

404:11,11,12,14,18

405:1,18,22 406:9,18

407:1,4,10,12,13,16

407:18,20 408:9,13

408:22 409:16,19,22

410:2,9,13 411:5,9,10

411:20 412:3,13,14

412:18,22 413:5,6

415:9,19 416:1,7,15

416:20 417:2,3,5,11

418:4,15,15,19,20

419:2,9,21 420:4,9

421:7,13,19 423:17

423:21 424:1,7,10,12

424:15,15,21 425:2

425:12,15,16,22

427:14 428:6,19,21

430:8 431:7,8,19,21

432:20 433:1,3,4,7,8

433:9,12,12 434:6,13

435:3,16,20,21 436:8

436:9 437:1,6,12,16

438:1,4 439:17

440:12 441:2,3

442:11 446:20 447:4

447:7,9,16,17 448:1

449:4 450:11,20

451:4,9,13,14 454:14

454:17 457:11,13,13

457:15 458:7 459:4

459:11 460:11,12

463:13,14,16,17

464:3,4

Organic's 148:16

organic-based 343:19

organic-growing

425:10

organically 106:9

149:13 162:12 206:5

232:15 233:6,9

257:22 320:17 321:12

331:18 335:5 377:9

377:19 378:5 447:3

451:2

organics 3:14 4:11 24:8

112:3,5 114:20

130:20 131:12 136:17

137:17,20 184:18

197:2 219:2 320:21

326:19 330:13 361:10

363:18 374:17 379:7

380:10 404:3,5 410:4

426:21 439:9

organism 324:10 396:7

organisms 182:13,16

183:2,3,6 221:12

290:19 306:17 312:16

319:15 337:19 338:17

338:18

organization 15:7 20:7

115:15 200:17 245:2

250:9 268:7 274:22

379:10

organizations 250:12

259:15

organize 80:11

organized 20:8 27:22

28:22

organizer 216:6

oriented 116:8

orienting 429:1

origin 11:16 68:13 69:9

464:5,9

original 83:5 116:6

159:20

originally 403:17

ornamental 304:19

Orville 341:22

OSB 9:13

OSGATA 205:15 249:8

403:18 405:1

OTA 383:13 395:2

OTA's 384:13

outcome 163:11 335:11

353:17

outcomes 158:14

outdated 254:11

outdoor 202:22 278:9

outdoors 88:10 161:8

outer 113:15 114:1,11

114:21 115:21

outline 273:13

outlined 364:8

outpaced 265:14

outreach 12:11 14:5

outside 67:11 93:19

110:1 140:20 144:14

178:6 199:10 203:6

260:12 333:2 389:22

408:16

outstanding 5:9 70:4

73:4

overall 28:2,22

overarching 211:9

overdue 188:20

overnight 368:22

overreach 408:19

overseas 66:10 257:2

oversee 265:14 420:12

436:14

oversight 28:14 35:3

42:11 52:21 60:21

63:14,19 66:12

393:11 420:15 464:10

oversupply 463:15,18

overturning 132:16,22

overuse 458:2

overview 5:3 28:21

65:15

overwhelmingly 115:4

owner 431:5

owners 192:11

oxides 276:3

oxygen 166:8 314:22

319:17

ozone 218:5

P

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

6:1

p.m 95:8 215:9,14,15

465:21

Pacific 43:8

packaged 56:1

packaging 56:2 76:10

279:6

Packers 25:18

packing 11:3 437:13

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palm 291:13

Palmetto 4:13 251:13

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panel 197:10 353:15

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Paonia 217:20,21

paper 78:16 159:15,18

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papers 249:11

par 137:2,22 138:19

paradigm 172:11

paragraph 121:6

parameters 114:12

452:17

parasiticides 464:19

parents 253:13 320:16

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park 423:15

parking 185:13 213:8

part 27:5 35:19 40:16

42:10 45:5,21 53:5

56:9,22 57:13,15 58:7

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participate 8:11 30:19

222:11 380:15

participating 380:11

particle 458:13

particles 458:11

particular 56:17 70:19

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90:11 105:10 156:4

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partly 388:6

partnering 197:5

parts 56:7 63:21 148:5

187:1,13 258:22

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party 38:2 40:2 74:6

pass 79:21 128:21

151:6 216:15 267:6

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passage 409:7

passed 133:14 134:5

226:13

passing 139:22

passionate 321:8

Passports 352:4,4

password 9:11,17

pasta 374:12

pasture 366:11 418:8

pathogen 427:2

pathogenic 11:20

338:18 396:7

pathogens 183:7

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patrol 64:21 195:15

pattern 160:18,19

161:17 162:3

Patty 4:9 185:7,8,9,16

189:16,17,22 196:10

216:22

Paul 2:13 7:13 8:4

29:11

pay 34:18 405:6,9 448:3

448:5

paying 31:16 435:4

PCO 442:14

PDS 9:7

peaked 419:7

peat 100:6 348:19,21

352:19 384:3

pectin 4:20 230:17,22

231:1,3,5,10,14,16,19

231:22 232:3,9,18,21

233:3,6,9,17 234:6,10

234:11 235:2,5,14,19

235:21 236:2,9,14,18

238:9,18 239:13,18

240:13 241:7,12,13

242:19 382:3,6,8,10

395:12 398:6,7,11,13

411:8 412:11,11,14

412:18,19,21

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242:1,9,10,11,13,15

pediatric 292:20 293:22

pediatric/infant 293:13

peel 231:17 233:14

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peer-reviewed 136:21

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Peggy 4:10 369:8 375:2

375:2 378:15,18,20

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penalties 37:10

pending 74:17 75:16

76:17 158:11

Penn 12:14 19:19

Pennsylvania 12:10,15

320:15 329:12 331:8

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people 15:19 23:5,12

25:5 29:9,22 30:2,3

31:19 35:9,11,12 52:7

60:8,12 61:21 63:21

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118:10 121:14 129:16

147:10 150:14 154:2

161:19 166:5,5

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210:13 216:18 221:22

228:2 238:9 253:14

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296:12 297:18 308:19

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367:11,13 368:8,16

374:4,8 375:19

379:20 396:8 402:2

417:1 419:11,19

423:2,12 432:14

433:6,13 435:9

438:22 441:17 442:19

454:15

pepper 77:18,19 165:21

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120:16

perceiving 430:8

percent 20:21 85:20

102:14 119:2,2

131:10 142:15 145:18

146:4 148:11 167:3

168:2 173:2 202:17

203:3 221:2 222:18

223:1 231:6 244:17

246:21 278:10 282:1

289:12 295:6 299:3,8

308:12,19,21 310:2

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365:6 375:22 376:1

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percentage 48:14 104:9

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172:15 175:18 177:6

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345:21 418:13

perennial 117:2

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perform 235:2 264:1

273:22 463:20

performance 262:6

performing 123:11

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period 35:7 37:5,9

38:21 48:11,16 85:15

97:5 160:21 175:6

363:12 364:12 368:4

434:19 452:22 460:4

periodic 263:3

periods 345:2

permanent 207:13

permission 163:21

Permit 317:4

permitting 173:6

peroxide 443:9 445:11

445:12,18

persist 214:5 264:7

persistently 360:4

person 15:11 90:20

121:14 258:14 315:9

390:11 406:6 449:21

person's 412:9

personal 40:21 91:2

98:17 171:3 327:10

Personally 419:15

personnel 28:4 29:19

52:3 262:6

persons 96:6 97:18

perspective 127:9

134:19 165:7,11,18

165:19 263:15 287:15

288:1 309:2 341:18

352:14 356:10 421:21

444:7,10

pertaining 98:3

pertains 382:16,17,18

Peru 43:9

pest 12:17 141:1,2,3

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pet 69:9

petition 71:2,12,16,19

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petitioned 77:15 276:10

389:15,18

petitioner 77:18

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73:3,7,21 74:13,16,19

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77:11,14,17 79:13

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petroleum-based 315:8

pH 235:4 239:6 240:13

370:11

Ph.D 2:12,13

phase 249:20

PhD 314:21

Phil 4:6 426:5 429:7

430:20,22 431:4

433:17 437:8

Phillips 3:11 442:6,7

philosophical 377:18

philosophy 316:22

phone 423:16,17

phones 93:18

phosphate 201:12,16

201:18,19,21 203:15

204:6,12 371:1,17

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375:17 376:8 400:2

400:12,17 411:12,18

412:6

phosphates 369:16,22

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182:14

pick 434:14

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picture 186:6 188:17

206:11 372:17 386:5

437:19 462:6

piece 107:19 108:9,20

111:4 226:14 269:19

338:15 393:2

pieces 249:13

pile 169:3

pillars 291:19

pilot 198:17

pinch 118:6

pink 365:15,16

pinpoint 106:18

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pipeline 191:5 359:15

pipelines 186:18 192:2

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pissed 224:16

place 1:20 32:1 84:7,15

91:17 111:5 124:13

163:15 165:22 182:1

183:9 187:21 189:14

191:16 221:17 304:17

341:16 358:20 363:20

377:3 425:1 445:18

placed 94:2

places 43:15 50:10

120:18 187:10 272:4

Plain 264:11

plan 30:1 54:6,11 72:20

73:1 94:13 101:20

124:4 128:18 149:21

184:3 191:4 273:8

281:6,10 282:9,13,20

282:21 287:20,20

288:7,8 331:13 358:4

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planning 191:19

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362:8 368:3

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102:15 111:6 113:1

114:14 140:11,15

143:22 144:10,13,22

166:13 167:2 168:7

169:16 182:14,15

249:18 252:2,20,22

254:1 257:7 258:22

270:1 275:8,22 297:7

327:7 338:11 406:10

406:10 407:20,22

408:4,13 414:10,11

424:20 427:6 428:13

460:3

plant's 182:12

plant- 100:12

plant-based 100:5

419:16

planting 175:12 176:2

plants 100:10 101:12

102:13,18 132:1,8

143:16,22 144:7

146:11 163:9 164:19

176:20 180:15,16

182:17,18,21 184:11

229:19 231:11 276:19

315:4 333:18,19

338:3 339:4 391:3

424:22 425:2 431:13

431:15 457:19 458:8

458:9 460:6 461:21

462:7 463:7

plants' 461:12

plastic 103:22 104:20

136:3 178:14,20

444:22 445:1

plastics 279:6

platter 113:15

plausible 136:9

play 60:14 158:16 198:2

255:22 256:17 266:7

plead 208:5

please 83:12 93:18,18

93:21 94:22 97:8

99:12 100:21 111:19

142:12 147:1,11

151:22 157:8 164:20

189:20 198:4 203:8

234:7 255:8 320:5

334:11 360:12 386:4

394:3 409:17 410:21

438:11 443:8 445:8

452:10

pleased 265:18

pleasurable 236:17

plentiful 335:10 336:5

plenty 141:21 235:12

plowing 423:19

plus 220:21 221:10

222:5 303:6

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point 25:4 36:6 39:3

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125:2 126:22 128:4

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302:14 313:11 322:5

325:18 347:12 382:22

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407:3 414:4 422:7

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points 89:20 140:2

193:1 249:16 345:14

policies 76:12 269:21

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116:8 123:6 130:18

174:6 200:8 201:1

269:10 272:5 274:21

279:14 350:19 357:15

363:10,20 365:20

383:12 464:1

political 23:3,9,10,12

23:16,21 25:5 69:16

poll 433:5

pollinators 447:19

pollutants 315:7

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polluter 405:9,10

pollution 208:8 217:7

218:4

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polyoxin 74:1,1

pomace 231:18

ponds 317:13

pool 116:11

poorly 274:7

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387:8,11

population 148:21

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portal 368:6

portfolio 27:5

portion 72:13 275:20

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Portland 130:15,16

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359:12

posing 275:18

position 62:17,18 93:1

283:4 376:11 384:14

384:19 385:1 391:20

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positive 157:22 313:14

possibility 170:16

359:2

possible 121:22 158:18

167:22 170:1 218:2

277:16 319:10 323:9

344:17 345:1 371:19

378:6 421:13 425:10

431:3 440:9 441:22

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post 41:22 49:9 127:22

322:14 465:8

post-World 324:7

posted 70:20 73:17

74:10 75:6 77:13 91:8

262:8

posting 62:12 71:22

potassium 102:20

315:20 316:4,10

349:10,13 395:12

potatoes 112:15

potential 76:1 90:22

91:10 152:19 302:11

315:11 316:15 391:16

400:12

potentially 161:10

172:16 204:7 212:12

279:1 319:6 349:21

pots 141:18 144:5

POU 106:12,13 119:12

poultry 18:18 19:7 26:5

35:6 48:4 86:17 87:8

88:1,2 278:3,6,15

293:21 396:5

pounds 422:10

powder 411:11

powdered 372:9 377:12

411:10

powders 370:11 373:6

398:18

powered 457:1

powerful 253:2

PPQ 64:12 65:6

practical 82:14

practically 316:7

practice 118:9 188:10

196:9

practices 18:18 19:7

35:6 48:5 86:18

168:16 266:14 275:4

275:6 278:6 302:19

303:13 309:14,21

322:1 335:14 337:7

344:21 351:15 404:19

424:16 440:13 451:13

459:4 460:12

prairie 298:14,16

368:22,22

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pre- 135:9

pre-NOSB 124:6

pre-requisite 133:4

precaution 194:19

precedence 211:12

precedent 210:9 211:14

precepts 130:22

precious 345:13

predate 291:20

predicted 363:16

predominant 252:22

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preempt 195:7 196:4

prefer 176:18 179:7

417:1

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429:16

prejudiced 409:14

preliminary 67:19

268:14

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prep 237:1

preparation 370:3

412:20

prepare 39:21

prepared 8:14 17:15

96:13 114:3 362:17

377:9 378:4,7,9

preps 240:19

prescribes 90:1

presence 111:7 122:19

198:18,21 335:6

365:3

present 2:1,10,16

231:11 232:14 248:6

273:6 290:22 354:4

376:5

presentation 70:10,13

70:19,21 97:15

145:17

presented 112:19 115:3

128:19 292:4

presenters 93:22

107:12

presents 262:8

preserve 447:15

preserves 235:13

382:19

preserving 425:6

president 4:13 13:20

14:21 249:7 251:13

presiding 1:21

press 20:17

pressed 413:4

pressure 221:3 283:9

pressures 336:22

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presuming 144:20

pretty 12:8 18:19 38:14

60:13,14 97:2 156:7

208:17 283:18 306:18

310:14 342:4 418:14

434:7 452:6

prevalent 322:8

prevent 59:5 147:20

149:17 162:2 174:20

225:14 358:9 396:6

411:14

prevented 205:21

316:12 358:21

preventing 214:21

346:15

prevents 247:14 411:19

previous 75:2 76:20

77:8 99:3 101:6 121:2

250:8 282:10,15

283:1 287:13 299:13

307:16 315:17 372:16

373:13 374:18 407:14

410:8 422:5

previously 73:10,15

128:14 366:10 414:8

price 26:18,20

prices 224:12 321:13

463:16

primarily 31:12 59:19

298:21 356:9 411:6

primary 343:7 346:17

348:4 349:9 437:13

450:6

prime 184:13 281:19

principle 231:13 312:18

323:6 414:20

principles 177:3 199:13

253:21 254:3,12

400:4 408:11 414:5

414:22 437:1 440:10

441:3 454:18

print 35:21

prior 11:17 91:13

132:22 246:17 358:4

375:16 383:14 432:2

priorities 28:3 60:18

66:3,5 158:17

priority 20:13 263:13

privacy 40:21

private 206:22

proactive 362:1,3

proactively 248:2

probable 245:2

probably 106:20 157:19

212:13 257:19 260:8

270:20 287:4 338:8

381:17 393:12 401:8

431:10 434:10

problem 51:1 135:1

153:3 154:9 166:19

167:15 208:17 221:9

246:19 253:7,18

261:9 309:20 367:3

369:2 432:1,19

455:16

problematic 228:10

420:7 422:13

problems 122:21

159:12 273:7 371:8

443:19 445:10

procedural 352:14

procedurally 353:1

procedures 50:19

70:17 78:22 89:15

91:7 96:3 197:12

proceed 97:14 163:8

171:6

proceedings 39:8

process 11:13 16:3

25:7 30:2,6 33:13

37:17 38:17 39:2,5,22

40:12,12 41:12 42:6

53:5 57:15 59:7,20

62:20,22 65:14 66:17

67:3,12,15,16,19 68:6

70:15 80:6,9 81:10

82:1,5,17 110:5 111:9

122:10,21 123:14

171:7 197:13,19,21

202:5 241:15 247:9

254:5 258:15 262:16

277:6 281:7 282:22

283:8 285:9,9,11

286:21,22 299:16

321:14 329:19 351:16

353:10 362:15 365:21

368:13 402:22 417:20

418:1,3 421:2,3,5
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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462:9 463:2

processed 40:22 204:2

204:7 339:15 375:22

377:12

processes 168:9

335:14 343:14

processing 72:8,11

127:5 220:18 232:7

300:6 394:14 395:14

396:4

processors 6:21 19:17

30:18 220:16 254:13

254:14 396:10

procurement 26:22

produce 107:2,3,8,9

111:1 116:20 131:6

139:16 141:12,12,18

153:11 184:16 202:19

223:1 251:14 252:1

320:16 321:13 333:3

344:20 345:15,21

346:6 374:20 396:5

396:13 434:3 435:6

436:12 454:5

produced 51:9 152:9

152:15 156:18 188:6

193:21 232:3,15

252:20 345:6,7 404:8

424:9 448:15 451:4

producer 139:16

175:15 260:17 350:21

437:3

producer's 13:5 230:17

230:22 231:3

producers 3:10 4:10,20

20:4 88:3 89:1 116:16

156:3 174:10 220:10

223:22 275:18 358:16

365:7 390:8 396:18

398:20 411:5 436:9

437:5 438:19 440:13

441:21 447:12 463:14

464:4

produces 140:14

225:19 231:6 232:9

343:2 451:1

producing 6:22 126:1

233:6,9 253:8 321:6

321:19 325:3 332:19

product 45:22 54:14

55:4,8,12 56:1,3

57:16,17 58:1,2,21,22

58:22 84:21 87:1 89:7

118:4 119:5 125:20

126:2,15 127:1

148:19 155:12 200:21

218:18,19 236:9

240:16 253:14 256:5

256:17,19 257:1,1

284:12,14 286:9

300:16 303:8,12

306:7 308:3,13,20

309:1 310:19,20

311:12 315:7 317:3

317:13 374:7,14,16

377:22 408:22 409:5

411:15 428:18 435:8

435:9 438:1

production 3:6 11:3

19:18,21 20:2 21:6

27:20 54:5 56:12 64:6

71:15 72:2,7 101:11

101:17 110:13 112:12

113:10 115:9,20

116:17 117:7 122:18

135:4 136:2,16 137:2

137:20 138:1,7,19

149:18 156:16,21

165:22 170:4 174:15

174:22 175:16 176:10

176:16,19 177:1

178:12,18,19 179:16

199:8,9 209:22

214:22 220:12 224:9

225:21 231:15,20,21

231:21 232:18 233:13

243:19 247:6 251:4

257:20 271:14 272:8

272:17,21 273:4,18

284:5 286:10 291:8

299:7,9 300:12

302:17,19 303:13

307:18 309:22 314:18

321:16 324:5 325:18

326:12,21 327:9

335:20 337:1,4

339:16,17 343:12,15

343:20 344:7,21,21

345:1,4,9,12,18,22

346:4,14,19 347:2,14

349:6,8 351:5,10,12

351:14,20,22 352:13

352:22 353:3,4,7

354:1,6 359:20

367:20 368:2 384:18

384:19 385:12 391:6

398:16 404:5,6 413:6

416:17 422:8 437:20

439:1 440:3,5 451:20

453:8,10 457:7 458:3

458:5 459:6

products 6:22 7:1

11:22 21:4,15 26:17

27:13 31:3 44:20 46:1

46:12 48:16 54:1

55:20 56:13 57:18

119:7 122:20 127:12

127:14,17 138:22

184:17 203:16 204:20

231:15,22 232:18

235:3,5,9,13,15,17,18

235:19,22 236:1,3,5,6

237:6,7,9,11 238:10

238:20 239:8,18

240:1,20,22 241:21

242:5,7,17,21 246:9

251:15,15 252:1,3

253:10,11,19 254:19

255:15,22 256:1,4,8

257:13,18 258:17

261:8 272:2,11

276:12 279:10 285:18

294:12,17 296:21

298:13,16 300:22

302:16 309:6 315:8

367:8 373:2,4,5,14

374:21 375:21 376:22

377:13 378:9 389:11

393:7,14 396:11

398:8,14,17 404:12

407:17 409:19 410:17

411:5 412:5,13,16,17

428:2,5,8 429:3

professionally 60:13

professor 10:16 309:13

profile 319:13

profitable 329:20

program 2:11,12,13,15

5:7,9 7:5,17 14:4 24:9

24:10,13,21 25:3,14

26:5,9,10,12 27:2,6,9

27:12 29:3 34:15

35:11 37:13 39:6

40:13 43:22 51:22

56:8 63:22 66:21 81:5

84:18 86:16,19 91:13

112:8 115:6,7 135:2

142:2 156:10 170:22

171:7 178:7 209:5

212:5 222:10 246:3

251:2 256:22 262:7

273:12 275:7,11

335:19 337:6 359:7

377:18 410:4,10,10

415:7 421:2,6,8,12

459:11

Program's 39:15

197:11

programs 13:19 25:2

25:12 26:3 27:3 44:6

286:1 365:8 367:22

421:1,3,15

progress 124:22 160:4

270:5 325:6,20 326:5

326:14 358:6 415:2

416:8 423:10

progressing 288:12

progressive 195:5,13

prohibit 123:4 278:8

prohibited 212:6

244:14,18 275:4

358:10 363:13 368:21

409:9

prohibiting 384:16

440:20

prohibition 154:12

176:14 201:21 273:16

436:19

prohibits 318:2

project 21:20 35:10

65:10 221:13 246:7

418:16 451:6

projects 63:20 359:15

423:3

promiscuous 261:8

promise 136:17 407:6

promote 85:12 363:4

370:12 435:11

promoting 435:14

promotion 27:4

promptly 200:3 215:9

proof 210:10

proper 232:5 358:12

properly 30:4 52:1

137:11 223:5 252:6

255:1 371:14

properties 231:16

232:3 238:16 239:18

239:20 240:11 314:16

372:12,20 375:18

property 206:7,14,22

234:19

proponents 330:22

proportion 344:2

proposal 48:12 72:16

73:5 76:2,6,10,15

77:9 78:19 87:5 123:4

123:5 124:19,22

126:9 128:21 174:16

198:9 262:6,19,22

265:19,21 266:17,21

266:22 267:6,7 270:3

272:6 274:5 295:14

328:20 384:21

proposals 75:10 77:10

84:19 85:16 91:8

391:17 392:10

propose 82:18 269:10

proposed 38:2,10

39:15 48:10 52:16

65:10 101:2 112:10

123:8 158:11 191:5
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

506

266:18 277:1,4

352:11 357:19 452:3

proposing 37:22

Proposition 214:11

proprietary 362:15

441:10

prospects 458:21

prosperity 20:1 158:15

protect 6:19 14:18

30:12 61:10 163:12

164:3 183:21 188:14

192:11 206:4 207:15

277:13 317:5 362:10

366:13 404:2 406:4

447:15

protected 365:12

405:15

protecting 6:16 20:12

21:13 27:16 30:10

35:20 130:21 132:6

134:19 201:8

protection 182:18

208:5 210:1 334:21

Protections 89:22

protective 142:14 146:5

protects 40:20 234:15

363:5

protein 236:15 294:14

295:5,12 297:11,11

297:12,17,20 370:10

protein-based 297:7

proteins 234:16,16

239:5 411:18

protocol 406:2 430:2

proud 87:18 108:19

141:18 341:21 435:18

proudly 255:15

prove 211:20 330:14

proved 335:9 423:12

proven 253:1

provide 21:11 46:10

90:7,7 102:12 103:4

140:11 159:8 166:13

212:16 214:8 239:1,2

263:16 267:2 308:3

316:19 360:10 361:17

365:9 368:5,11 370:9

372:9,12 373:7 389:1

401:9 409:22 428:17

441:21 444:18 463:22

provided 26:21 71:14

102:17,17 121:7

144:14 177:6 200:21

253:22 308:13 371:4

384:17 385:2 457:1

provides 26:14 91:14

102:20 113:11 234:11

234:18 235:21 236:21

237:9 275:3 455:20

providing 107:20

122:15 194:21 212:12

240:14 295:9 320:16

349:22 437:16

provision 225:8

provisions 142:21

proxies 98:16

public 5:12,16 9:1

13:15 17:19 48:14

71:22 74:11 76:14

78:18 82:18 84:17,20

86:1 87:4 89:11 90:4

91:8 93:17 94:3,7

95:3,21 96:2,16 98:7

99:9,10 123:15 130:5

138:21 152:7 155:11

186:12 200:22 207:2

207:6 240:3 265:22

280:4,5 301:7 303:2

309:10 337:9 359:8

393:20 394:2,3,5

407:8 438:20 463:22

465:12,15

public's 133:1

publication 81:8 114:3

publicly 218:21

publish 22:3 36:2

published 19:11 34:22

36:1 86:17,20 402:22

462:20 463:4

Puertas 2:16 403:16

405:1

puffs 411:9

pull 96:1 333:8 432:14

pulled 238:11

pulling 185:10

pulp 241:6,11

pulpit 192:19

puncture 183:8

purchase 21:16 57:19

184:16 255:10 257:17

purchased 373:22

purchasing 139:5

pure 132:10

Purees 11:22

purgatives 371:20

purity 159:14 249:15

261:16 404:10

purporting 353:9

purpose 117:21 159:21

277:6

purposes 258:20

294:16 414:14

pursue 211:2 348:9

pursued 347:19

pursuing 347:18

push 246:5,10

pushed 456:4

pushing 172:10 450:22

put 101:7 117:12

124:22 126:6 138:6

140:4 145:22 181:17

213:19 218:17 221:16

236:18 239:12 240:2

246:7,13 249:3

250:13 281:20,21

283:8 284:1 287:18

287:20,22 299:8

328:21 349:16 358:19

379:5 381:4 404:10

405:4 423:2 441:14

441:17 442:13 443:3

443:5 453:4,11

454:11

puts 14:16 71:21

464:20

putting 49:13 153:13

192:9 221:3 244:10

375:15 380:18 388:1

PVP 171:6

pyrethroids 312:5

Q

QFR 47:18

QR 47:18 63:7,10

qualifications 263:2

qualified 52:3 289:22

349:19

qualify 254:10

quality 11:19 22:1

26:15 33:15,22 34:2

46:7,9,10 50:15

108:17 148:1 156:5

182:2 218:19 232:16

330:5 331:5 335:1

343:8 401:11 402:11

421:11 459:1

quantities 203:16,19

314:13 315:1 337:2

quantity 232:16 382:7

quarantine 64:6

quarrel 228:4

quarter 37:11,11

202:15

quarterly 35:22 36:3

quarters 36:8

question 15:13 65:20

82:9 91:22 104:18

106:4 107:11 109:1,6

109:9 111:11 115:19

118:14 120:22 121:2

121:15,17 126:7

135:22 137:5 145:4

151:14 154:10 166:14

166:17 167:1 168:15

169:14 170:11 171:22

172:5 173:11,15

178:21 179:19 180:7

180:14 190:12 192:7

193:17 195:3 210:22

227:20 229:3 241:9

245:11,12 247:21

255:19 256:12,14

257:5 264:4 265:13

269:9 270:16 284:16

286:20 294:18 296:2

301:15 305:3,15,17

306:3 311:4,15

312:15,22 318:9

325:16 328:13 330:22

332:17 338:22 347:7

348:16 349:2,3,4,18

355:15 357:6,7 367:6

368:14 370:22 373:20

390:2 392:9 401:19

429:10,12 433:18,22

440:17 455:4 460:1

462:6 464:17

questionable 448:11

449:2

questions 51:7 61:12

61:13 62:8 63:4 69:21

71:17 81:17,19 83:8

87:12 97:13 98:7

101:15 102:7,10

103:2 106:1 109:4

111:14 113:2 115:11

116:12 120:20 125:13

130:5 134:12,13

136:8,10 137:4 139:7

143:1 150:18 152:4

152:19 160:12 162:5

165:2 168:15 170:6

173:18,22 177:15

178:9 180:21 185:2

189:17,21 194:18

199:18 203:9,13

204:22 205:9 208:13

210:19 215:5 219:11

221:21 223:14 227:8

230:7,9 233:1,2,19

234:5 237:17 241:2

243:1 245:7 246:12

251:5,7 255:17

261:19 264:16 269:1

274:10,14 275:18

278:17 279:21 283:14

283:16 292:10 295:16

296:9 297:4 298:1

300:20 301:6,17

305:1 310:11 313:9

316:2 323:16 327:12

337:10 346:11 351:14
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

507

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400:22 406:13 410:6

410:8 413:12 415:12

417:15 426:3 427:22

433:16 436:11 441:9

443:3 444:13 445:8

445:10 449:11 451:20

453:17 459:16,18

461:18 464:13,14

465:3

queue 185:14

quick 65:15 67:17

92:19 96:2 183:16

278:19 306:15 331:19

350:12 433:18 460:21

quicker 332:9

quickly 67:18 129:18

222:18 269:4 317:19

317:21 318:6 325:9

348:1

quietly 135:3

quite 25:9 43:6,16 51:3

55:5,5 66:13 69:19

97:12 108:3 137:18

165:14 168:20 221:8

226:5 230:3 448:6

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quorum 215:18

quote 128:12 136:6

182:21 309:11 457:12

R

race 260:22

rain 11:7

rains 359:1

raise 187:6 447:5

raised 202:19 282:4

370:15 381:6,8

raises 123:5 201:19

221:20

Rakola 67:8

rally 94:19

Ralph 4:13 248:14

251:12,12 256:19

257:14 258:18 259:4

Ramen 213:16

ramifications 176:6

415:2

ran 133:20 253:7 433:5

ranchers 30:18

range 86:3 124:17

235:4 273:2

ranked 218:8

ranking 263:12

rapid 316:11

rapidly 265:13 314:8

rare 205:19 252:10

364:9,10 365:3 366:3

369:1

raspberries 351:1

rate 119:4,5 306:17

311:9 323:10 407:16

rates 278:7 305:18

306:1 311:4 318:10

318:12 340:2

rating 126:17

ratings 200:22

raw 58:2 231:10,13,19

232:5,15 233:11

300:22

re- 230:22

re-distributed 80:15

re-distributing 82:6

re-establish 458:4

re-labeling 56:2

re-occurring 160:19

162:2

re-packaging 56:2

re-petition 74:2

re-registration 315:19

reach 203:9 204:9

353:17 408:15

reached 300:8

reaching 158:2

react 332:9

reaction 149:12

reactively 115:18

reacts 154:2

read 88:16,18 99:5

101:10 125:18 151:1

151:5,17 152:7,21

170:15 193:17 298:17

322:8 330:9 367:9

382:20 401:21

readily 57:3,6,12

290:19 428:12 460:20

reading 42:2,3,8 56:9

150:8 168:18

reads 205:5

ready 87:11 95:20

122:8 185:8 265:15

281:19 350:10

real 33:21 58:17,17

96:2 117:21 154:9

161:20 164:17 165:19

165:20 172:7 228:19

350:12 361:8 366:14

reality 405:17

realize 147:10 439:14

444:5

realizes 407:9

realizing 86:8 326:1

really 18:19 21:12

32:10 45:11 46:3,5

47:17 48:8 49:11 52:5

53:12 56:18,18,22,22

60:2,11,12 62:2,10,11

66:9 67:6 68:1 86:1

86:18 88:17,18,20

93:1 105:6,7 106:19

109:17 114:17 127:8

150:11 155:20,22

156:11 158:13 160:22

180:14 188:2,18,19

188:19,21 189:10

191:16 193:2,8

195:16 209:18 216:18

218:4 219:1 222:13

224:4 225:16 228:3

228:10 229:18 240:20

246:5,10 258:7 283:7

285:2 286:4 289:10

299:15 330:15,19

334:1 339:11 355:7

355:16 356:5,9,12

359:4 361:3 382:4,22

383:7 384:3,21,22

385:5 388:18 391:20

415:2 416:8 417:10

422:1,12 434:19

437:4 438:5 444:2

445:5 450:21,22

452:18 454:12,13,19

reason 293:14 295:8

303:10 306:4 366:15

reasonable 270:5 271:6

382:7

reasoned 205:3

reasoning 277:1 305:21

reasons 148:22 238:19

303:11 395:4

reassurances 187:22

rebuild 439:17

recalcitrant 100:7

101:4 165:10 199:6

352:16 443:18

recalls 397:1

receipts 58:3

receive 85:16 211:16

received 37:15 86:5

206:18 321:2

receives 90:16

receiving 36:15

reception 95:7

recess 215:8 465:14,19

recipe 110:18

recirculate 455:21

recognition 24:17

28:16 44:2,3

recognize 84:19 86:15

141:16 159:21 362:3

recognized 264:8

recognizing 9:8

recommend 198:17

234:4 273:15,18

276:16 278:2 303:5

303:14 334:19 366:1

425:19 436:20 459:8

recommendation 80:9

81:13 82:10 83:5 87:3

161:1 164:7 167:16

175:10 177:10 191:21

278:15 323:8 384:15

391:7

recommendations 19:1

28:10 31:8 49:17

74:22 75:2 83:7 87:1

124:8 160:21 177:10

271:20 272:9 273:9

405:19 417:8 445:2

457:11

recommended 114:14

167:18 273:10 277:2

384:16

recommending 277:19

reconsider 73:12

reconsideration 73:20

reconvene 159:1

record 34:2 54:4 56:6

56:20 95:18 97:19

98:1,12 99:12 122:6

130:10 147:12,13

157:13 174:4 181:4

185:11 196:13 200:6

205:12 215:14 216:1

220:5 223:20 230:14

234:1 237:22 240:3

243:7 251:11 259:9

262:2 264:21 271:10

274:18 280:17 289:19

292:15 302:3 307:5

320:6 324:1 334:13

342:19 350:15 357:13

363:1 369:10 378:19

381:21 383:10 394:10

397:19 400:8 403:14

406:16 413:15 422:22

436:5 446:18 450:3

456:16 465:21

records 34:4 41:2,5,11

53:7 54:13 56:12,15

56:16 57:11,14,15,22

58:3,6,13 59:2,8

recover 211:21

recovers 166:7

recreate 439:21

recreated 180:1

recusals 91:19 92:6,8

92:10
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

508

recycled 78:16 460:2

recycling 457:3

red 96:19 97:5,7,11

260:21 313:3,7

365:12

redact 41:7

reduce 160:2 264:11

319:16 426:22

reduced 164:10 235:18

236:6 346:5

reduces 276:6 319:18

397:8

reducing 269:22

reduction 426:19

refer 100:21 249:14

reference 17:20 91:19

100:22 250:20 273:21

395:21 401:22 452:21

referenced 118:18

references 271:21

399:8

referrals 37:4

referred 330:4

referring 109:13 128:8

156:22

refers 256:3

refine 46:3 358:15

reflect 120:8 346:22

reflected 404:6,16

reflection 346:6

reflects 389:18

Reform 464:11

refrain 94:3 98:17,22

393:21,22 438:12

reframing 353:14

regard 176:22 403:20

regarding 72:16 76:9

100:4 152:9 177:16

179:20 265:9 293:11

315:13 316:1 343:13

347:8 351:14 352:6

380:19 396:14 412:1

regardless 101:17

173:3

regards 396:13 414:6

regenerative 322:7

region 51:10 207:20

267:19

regional 31:1 95:9

268:5 269:18 271:4

379:13

regionally 159:16

regions 102:5

registered 205:16

registration 305:6,11

regs 352:1 356:13,16

regular 115:2 120:13

268:8

Regularity 397:21

regularly 125:8 181:8

268:2

regulars 433:7

regulate 290:10 408:16

regulated 190:21 211:7

290:19 420:20 447:11

regulates 192:2

regulating 114:18

417:9

regulation 37:16 84:4

88:16,20 158:7,8

195:6 389:2 396:12

regulations 27:21 31:6

44:16 48:3 53:13 59:1

72:9 85:10 109:12

114:19 133:2 134:18

135:7,7 147:20

155:21 156:7 190:7

191:16 197:14 211:9

212:5 240:18 256:3

256:16 265:14 273:18

290:9 351:7 368:7

376:2 383:20 385:14

386:14 393:13 418:10

420:12 439:19 447:10

448:18

regulatory 3:15,20 4:4

7:15 25:2,12 47:10

49:14 158:6 161:2,5

161:13 168:10 190:9

192:18 208:18 230:18

266:10,18 267:11

268:19 270:3 360:3

369:13 372:6 382:1

399:3 409:2 417:20

417:22 420:16 421:14

464:12

reignite 286:22

reinstatement 38:8,8

reinvent 163:21 164:3

reiterate 139:21 193:4

360:17 396:16

reject 202:2 451:17

rejection 303:10

related 72:18 73:2

170:15 262:15,21

263:19 277:16 278:3

328:5 352:9 414:1

relationship 338:5

371:1

relationships 91:12

relatively 26:2 29:19

32:14 45:18 62:16

211:16,19

release 20:17 141:5

182:7 240:21 462:9

462:11

released 42:1,7 202:12

391:17 460:17

relevant 58:7 98:2

99:13 111:20 139:11

157:12 162:9 181:3

189:21 248:6 372:1

reliable 245:18

reliance 319:16

relied 285:5

relies 411:11

relist 401:4

relisting 395:9 398:5

401:2 413:2,5,8

rely 102:15 155:13

199:10 323:3 331:18

relying 275:10 329:9

331:19 388:15

remain 222:8 234:16

277:10 385:10 391:13

395:4,17 443:6,7,17

remaining 9:10 223:3

remarkable 374:5

remarks 98:18

remedy 389:17

remember 19:2 35:7

73:8 121:1 131:21

136:4 142:12 293:19

remind 92:9 98:10

210:19 300:14 384:15

394:1

reminder 220:8,21

remiss 86:14 92:20

remote 97:16

removal 82:18 303:5

304:16 307:20

remove 48:12 239:14

292:6 302:21

removed 79:11 201:12

209:16 282:7 289:11

388:7

removing 316:18

renal 399:21

Renee 32:8

renegade 207:14

renew 354:2

renewal 42:16

reorganize 36:18

reorganizing 32:3

repeating 170:11

replace 378:4

replacing 271:20

report 5:6,7,11 8:19

17:16 18:1,5 23:15

29:3,6 34:9,10,10,22

35:22 71:17 78:5,8,14

78:17 83:12 121:8

145:22 146:3,15,16

146:18,19 147:2

156:21 167:15 198:1

272:4 273:8 288:11

399:9 400:7,8

reported 184:8,10

214:9 217:15 338:14

reporting 26:18,20

457:10

reports 4:19 58:3 70:15

71:20 74:6,8 75:3,13

77:4,12 78:1,3 196:12

200:9,15,20 246:6

represent 61:22 90:10

93:12 174:9 320:8

325:2

representation 263:14

representative 89:19

135:20 379:6

representatives 89:18

263:6 380:12 450:17

represented 56:14

90:15 113:7 263:11

representing 8:5 61:21

88:21 90:21 350:20

398:2 456:18

represents 55:20 85:20

113:9 164:15 345:8

379:10

Republican 189:5

request 39:16 41:4

92:15 124:2 128:20

190:12 258:6 267:5

298:15 354:2 360:4

365:7

requested 40:18 74:5

75:4 77:4 78:1,9,10

191:6 293:12 447:8

requests 28:4 40:22

41:9,18 207:2

require 47:11 65:11

114:11 133:3 137:13

158:13 175:10,21

181:22 235:14,19

269:5 277:18 293:16

294:1 296:11,13,17

356:13 376:3,10

393:12 436:18 444:17

453:7

required 37:16 40:17

47:6 54:16 55:18,20

92:16 117:5 135:16

197:14 246:20 254:6

274:4 290:18 307:17

346:6 356:16 362:5

365:20 371:14 412:20

requirement 156:2

252:8 262:16 266:3

267:15 268:12,18,19

270:11 271:3
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

509

requirements 42:13

52:18 54:4 56:21

87:10 102:1,3,4

109:11 124:16,20

142:2,8 143:15

144:13 177:7 251:3

266:10 278:3,15

393:15

requires 107:19 173:3

243:19 257:19 321:17

356:12

requisite 135:10

research 3:13,21 4:14

10:15 12:11 24:22

27:3 91:10 105:14

114:6 116:11 158:17

200:22 228:2 251:14

265:4 314:3 334:15

339:11 375:13 393:9

400:10 427:17 457:18

researchers 214:8

reserved 207:5

residing 344:10

residual 254:10

residue 226:17 228:13

244:15 246:2,15,17

290:13 383:19 386:8

386:15 393:3

residues 246:22 301:13

resist 443:15

resistance 311:14,19

312:2,10

resistant 100:7 312:7

396:21

resolve 198:14 287:21

resolved 160:20 262:14

264:5

resource 24:6,6 45:11

268:17 270:1 277:15

367:21 380:19 383:21

425:7

resources 24:4 36:20

39:4 40:15 41:20

45:17 116:11 136:12

247:15 267:13,22

286:5 358:16 459:7

respect 84:5,11 321:2

361:9 432:5,8,9

respected 321:7 323:13

327:1

respectfully 353:12

respecting 425:6

respond 331:5

responded 207:1

267:20 405:8

responding 440:18

response 78:9 261:20

264:17 274:11 279:22

292:11 298:2 301:18

323:17

responses 182:17

responsibilities 41:21

52:4

responsibility 32:22

52:21 63:17 244:6

344:5 346:20

responsible 41:1 58:21

64:21 66:7 208:4

344:3 351:5 408:12

464:7

responsive 41:2

rest 9:2 16:16

restaurants 149:1

rested 8:13

restore 164:9

restores 363:5

restricting 292:7

restrictions 305:6,11

316:11

restricts 304:18

restroom 334:11

result 207:10 208:9

276:7

resulted 358:22 360:7

405:12

results 197:22 202:12

400:15

resumed 95:18 215:14

resupply 461:3

retail 11:13 119:2 120:6

407:16 429:2

retailer 10:9

retailers 16:5 90:5

141:19 299:5 420:3

retain 290:3 291:5

292:5 316:16 337:3

retaining 314:6

rethink 36:18

return 33:8 169:9 352:7

returning 450:13

reuse 455:22

reused 140:22

revealed 358:20

revealing 309:17

reveals 122:21

revert 454:8

review 8:15 19:10 33:17

34:8,12 43:1 48:6

53:17 57:22 71:22

72:21 73:7 74:4,14

75:6,14 76:22 77:22

78:16 80:18 89:12

91:9 197:9,13,22

202:6 265:22 274:1

276:8 285:21 286:1,7

302:20 303:2 309:4

377:15 378:22 395:7

400:9 402:22 421:9

reviewed 73:14 80:14

209:11 272:13 274:8

315:18

reviewers 14:13

reviewing 54:13 123:14

281:7 285:11

reviews 34:7 36:9 365:9

revise 352:10

revised 77:9 262:13

315:16 316:3

revising 376:12

revision 101:22 262:7

revisited 316:8

revive 403:17

revocation 38:1

revocations 52:17

revoke 38:10 207:2

revoked 115:8

revolutionaries 321:11

revolutionary 423:14

rhizospheres 335:22

rice 2:7 14:1,2 53:4

67:22 192:22 247:22

297:15,19 402:9

rice-based 297:16

rich 431:13,16

Richard 4:9 456:13

463:10,12 465:10

Richardson 299:12

rid 228:22

riddled 253:12

right 25:1 34:12 39:16

44:21 55:7 59:21

60:17 62:14 63:5

70:12 91:16 93:14

94:15 95:7,12 96:22

97:4 108:2 117:3

136:7,8,14 138:7,8

146:8 152:21 157:2

163:19 167:11 189:17

199:19 203:8 206:5

209:12 213:9 219:17

219:18,21 225:22

226:7 227:2,4,13

236:13 242:1,3 246:1

246:3 247:17 279:13

283:20 289:2,9,13

324:13 325:14 341:12

350:10 355:1 356:22

369:11 374:19 388:6

388:16 392:19 393:18

414:4 417:15 420:13

430:13 438:15 448:6

449:8,16,22 453:5

459:12 460:22

rigorous 200:22

riparian 365:18

rips 311:21

rise 181:12 457:5

rising 458:22

risk 131:3 201:17 208:2

214:18 218:18 290:15

291:1 311:14 316:21

404:11 416:14

risk-based 262:10

risks 253:2 290:16

315:16

River 415:20

rivers 147:21

road 43:17 135:14

385:9 437:10

roads 224:17

robust 269:17 408:20

rock 451:9 455:9

rockwool 166:1,6

Rocky 95:9

Rodale 287:6

Rodenticide 284:8

role 54:18 123:11

158:16 197:2 198:2

266:5 343:8 409:12

roles 115:20

rolling 23:8

ROMERO-BRIONES

2:7 10:4 145:16

146:14,22

room 42:2,3,8 94:1

132:7 141:21 267:9

286:5 433:1,2

root 118:8 140:19

161:15 180:12 335:5

335:10 336:5 408:1

424:22 454:19 458:13

root-soil 339:2

rooted 322:18 337:6

458:9

rooting 275:15

roots 107:22 108:3

111:8 166:9 275:8

324:7 336:7 408:7

424:19 460:6 461:12

Rosemary 2:19 199:20

205:10,11,13 208:14

rot 169:3

rotate 168:19,20 341:1

rotates 341:2

rotating 169:12 341:4

rotation 109:15 168:16

321:22

roughly 116:3,14 119:2

roughshod 133:1

round 158:20 194:12

320:16 405:11

Round-up 310:15
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

510

routine 143:18

row 304:5 306:10

rows 311:3

rug 432:14

ruin 117:16

rule 18:18 19:7,10,11

19:12 35:6,15 48:10

49:2,7 56:8 65:10

69:5,18 82:5,16,17,19

82:19 86:18,20 87:18

87:21,22 88:4,5,7,13

124:13 175:2,10

192:4,5 193:3 203:2,8

221:16 246:15 251:5

278:6 366:1

rule-making 464:6

rulemaking 61:4

rules 28:8 48:19 61:20

81:9 182:1 261:16

447:9,13,15 448:18

448:20 451:19 452:16

ruling 302:21

rulings 132:16

rumors 380:5

run 97:11 200:1 220:9

rundown 392:19

running 45:13 94:13

96:10 133:1 147:10

163:18

runoff 317:12

runs 32:19 133:22

406:8

rural 4:15 20:5 24:19

157:15 187:5 208:1

ruts 358:22

S

sacred 405:7

sacrifice 249:4

sad 62:10

sadly 346:2

safe 201:4 222:15 239:7

335:2 337:2,8 370:2

371:11 372:5 376:14

376:18 396:22 397:5

397:12 399:3 443:10

safeguard 290:11

safely 188:21 189:7

safer 200:18 201:5

204:5 273:10,12

425:13

safety 3:19 11:19 24:21

135:13 160:10 182:1

274:21 319:12 336:11

336:12 386:13,18

396:2,12,13,20 397:1

399:14 413:9 445:21

sagebrush 364:2

Saint 198:8

sake 312:13 327:14

354:13

salad 113:9

sale 143:22 409:4

sales 21:3 33:5,7,10

65:22 119:3 120:6,9

120:10 148:11 407:14

407:16 416:14,16

448:1

Salinas 343:1 365:17

Salmonella 396:8

salt 74:1,2 299:16 314:9

316:4

salts 290:16 314:9,12

314:16 315:12,14

316:6,9,10,12 414:18

414:18

samples 245:16

sampling 336:19

383:19 386:8,15

393:3

Sampson 134:5

sanction 136:16

sanctioned 256:22

304:13

sand 186:22 453:20

sandy 236:16

sanitation 396:18

sanitizers 274:1

sat 13:5,8 405:12

satire 384:8

satisfaction 111:11

satisfied 228:1

satisfy 423:9

sativa 414:10

sauce 377:13

sauces 370:11 372:8

373:6 398:18

sausage 298:22 299:2

300:12

saved 261:4 446:13

saw 116:5 195:4

saying 98:1 126:22

133:12 155:6 181:12

228:19,21 309:5

340:8 354:15,22

416:22 432:1 450:19

says 171:9 210:7

284:22

scale 16:14 57:19

221:19 279:16 308:17

415:1 451:6

SCAN 106:11 118:19

120:3

scenario 405:17

schedule 40:3 96:11,11

147:11 189:19 200:2

210:20 288:3 334:8

334:10 381:14

schema 407:5

scheme 26:2

school 27:1

science 12:6 26:7

135:18 136:22 279:14

309:13 335:9 337:7

353:18,20 355:10

385:22 389:20

scientific 353:15

370:18 385:15 399:15

400:4,13

scientifically 273:20

scientist 90:4 314:21

354:22

scientists 130:19

337:22 354:3 355:2

scope 63:17 78:10

366:17

score 334:6

Scott 2:7 14:1 67:21

189:18 192:21 247:20

401:18 402:8 427:22

Scotts 3:5 426:7 427:15

428:2

scratched 326:8

screen 240:4 303:19

screening 365:1

screens 272:18

scrub 364:5

seafood 396:5

seal 21:14 62:1 164:4

197:18 221:20 281:14

326:13,18 430:11,14

437:12

seals 221:6

search 45:19 46:3,13

127:18,22

season 16:21 108:5

321:20 349:12,15

seat 10:9 13:5,8 14:2

16:11 17:4,11 62:13

230:13 274:17 442:20

second 13:16 14:7 15:4

37:11 71:8 79:10

112:19 170:14 240:2

244:12 250:19 263:12

263:19 265:18 281:13

320:8 347:9 352:9

417:17 433:10 448:7

secondly 158:22

217:14 297:19 307:20

361:14

seconds 226:18 227:4

409:17

secret 126:16

Secretary 2:4 13:6

22:20,20 23:15,16,18

85:2,7 87:9 158:4,18

405:5

Secretary's 5:6 17:16

18:1

section 72:12 95:21

112:11,17 223:2

225:13 244:13 409:7

414:21 415:8

sections 35:15

sector 6:17 22:4 26:21

131:20 355:9 407:10

463:15 464:7

security 47:20 94:21

407:7

see 21:5 22:10,17 32:18

36:11 38:22 42:3,4

43:2 46:8 47:15 53:5

62:4 68:3 87:18 88:17

92:6 96:21 106:2

108:12 115:11 119:14

119:15,22 120:2

125:7 144:4 145:22

146:12 167:9 170:17

179:13 181:8 187:8

195:18 198:4 218:1

226:2 234:10 236:3,7

236:12,19 239:17

248:7 259:3,20 260:1

265:18 266:21 267:13

289:7 292:16 301:12

308:7 310:13,18

312:5 317:14 320:10

337:11 346:11 359:4

372:22 382:21 387:1

399:7 409:12 433:17

433:21 434:19 437:3

438:2 440:4 443:6,13

443:17 451:21 461:4

464:17

seed 4:1 26:6 43:21

77:20 124:21 125:3,8

125:11 128:7,17,21

159:13,21 174:17

175:12,16 176:2

221:10,10,10 248:18

249:9,15 250:11,13

250:16 259:13 260:22

261:2,15 265:2,4,15

266:2,5,8,11 267:13

267:15,16,19 268:1,3

268:12,15,18,18

269:11,15,17 270:11

270:13,21 271:3

403:21 404:4,6,8,10

404:20 405:22 406:7

408:7 414:14 447:19

seeds 112:16 149:4
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

511

159:16 198:18 265:20

269:5 403:17 405:2

406:2,10 414:11

seeing 17:22 50:10

54:10 68:21 69:22

205:8 221:5 223:15

248:5 339:1 350:5

416:18 459:18

seek 409:21

seeking 73:19 75:1

seen 21:3 119:7 155:10

273:3 311:19 312:2

353:3 364:1 365:14

367:7 384:3,21 415:1

416:14

sees 155:11

segment 378:1

segregated 233:15

segregation 358:12

Seitz 2:8 13:14,15

81:21 125:15 127:2

134:15 150:19 151:16

151:21 173:15 193:16

195:2 241:5 255:19

256:13 269:2 278:18

278:22 283:15,21

300:21 330:2,21

367:6 368:14 401:21

417:18

seizures 252:12,14

253:5

select 135:3

selected 231:9 400:1

selecting 278:4 336:9

selection 232:5

self-introduction 92:20

sell 16:1,4,18 30:22

107:8 138:21 144:6

209:2 223:4 326:19

seller 58:22

selling 6:22 144:19

151:2 292:22 422:15

428:3,19 435:7

sells 55:19

Senate 464:11

send 146:17 147:1

157:5 254:7 300:5

sending 184:18

sends 182:6 206:9

Senior 3:19 4:19 200:8

274:20

sense 123:9 296:12

339:5 388:12

sensible 21:10

sensitive 9:17,19

205:17 364:17

sent 73:16 80:16 108:9

207:15 252:17

sentence 97:8 178:2

separate 47:4 75:20

178:7 291:5 352:5,5

411:13

separated 237:3 453:19

separation 411:19

September 380:12

sequestration 319:19

371:2

series 121:13 229:14

306:20

serious 273:6

serum 399:17,20

serve 11:21 12:15

13:17,21 100:9

116:12 163:12,22

164:2 433:2,3,4

served 14:12,13 85:2

90:9 133:19 162:14

248:21 280:20

service 4:2 12:19 15:6

24:5,6,7,13,15 25:13

25:15 26:1,21 29:5

32:9 37:18 47:12 86:9

199:16 238:2 280:22

327:11 354:8 367:22

421:2

Service's 7:5

services 3:9 4:21 24:12

24:20 26:13 27:6

134:3 292:19 342:22

364:11

serving 376:9 412:8

session 22:21

set 98:11 116:7 120:12

182:1 210:8 239:19

240:11 257:16 267:1

288:20 302:4 319:9

382:14 447:12

sets 437:6

setting 120:7 440:14

settled 39:12 48:8

settlement 37:5

settles 236:15

seven 24:1 41:19

117:15 133:16 224:1

450:12

severe 315:10

shade 99:20 104:20

Shannon 3:20 235:11

375:3 378:16,17,17

381:14,22

share 67:1,5 112:21

149:21 151:22 192:14

193:14 194:13 202:11

361:20 363:19 368:3

shared 70:2 240:9

357:17 361:22

shavings 100:6

She'll 306:21 381:10

sheet 18:7 126:17

152:8,13,18

sheets 58:2

shelf 234:22

shelf-stable 398:17

Shenandoah 3:18

139:14 141:11 143:3

shenanigans 195:21

Sheraton 1:19

shift 96:13 436:16

shifting 131:18 347:3

ship 55:11 58:4 94:13

225:19 228:7

shipments 54:22

ships 225:17 226:5

Shistar 4:14 264:20

271:11,12 274:13

shoppers 204:17

shopping 202:14

short 12:8 49:9 75:10

85:15 99:16 123:18

124:11 202:3 210:19

270:7 292:17 325:16

329:16 383:6

short-lived 406:9

short-minded 103:5

shortages 424:12

shorter 117:11

shortly 116:4

show 59:15,17 81:11

108:19 115:22 127:18

211:15 303:19 306:16

331:12

showed 114:6 115:4

310:20 319:1 372:16

showing 105:14 112:21

114:19 184:13 246:8

338:16 416:9

shown 203:21 214:5

304:2 365:15 370:19

373:6

shows 19:20 202:1

204:19 304:9 365:18

372:18

shrinking 344:2

shrinks 427:9

shut 427:13

sick 149:3,8 150:14,14

151:11 153:19 253:14

396:8

side 12:2 72:7 162:22

189:18 200:17,17

208:18 236:13 284:2

303:18 324:17 325:13

367:13

sides 161:7,19 324:16

330:11

siege 447:18

sign 96:7

signed 189:4,5 253:20

significant 22:10 38:15

41:20 69:11,15,17

88:10 113:22 174:19

208:1 291:13 314:11

349:14 455:9

significantly 31:17

36:12 439:11

signing 358:5

silence 93:18

silent 156:7

silicates 276:3

silt 358:10

Silva 3:6 449:17

silver 77:2

similar 159:5 193:12

227:1 277:20 312:14

330:6 336:5 339:1

341:16 370:22 373:14

439:18

similarity 460:11

simple 366:21

simpler 326:11 366:22

simply 277:5 300:6

399:6

single 102:22 103:2,3

201:15

sir 107:6 337:13

sit 14:2 16:11 17:3,10

327:16 403:18 442:20

455:19

site 217:22

site- 101:18 113:19

site-specific 102:2

104:19 109:17 118:11

sites 186:16

sitting 69:14

situation 105:10 175:19

176:18 188:6 211:2

232:20

situations 360:7

six 37:2,3 38:15 141:10

141:11 157:18 206:13

252:12,15 329:7

336:16 344:17

size 22:4 226:2 279:16

299:19

sized 300:6

sizes 275:21 299:19

sizing 299:18

skeptical 221:21

skepticism 108:7

skin 315:10

skipped 70:8

skyrocketing 184:17
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Neal R. Gross and Co., Inc.

512

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299:21,22

slide 20:14 96:15

327:22 328:4 330:4

372:16,18

slides 18:11 96:1 97:17

328:9 363:3 382:12

382:14

Sligh 4:15 147:9 157:11

157:14,14 160:15

162:6

slightly 114:6

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415:2

slowly 100:8

small 13:8 16:14 26:11

26:12 27:8 35:21

43:14 55:6 87:7

207:21 226:3 299:22

314:13 332:9 344:2

359:17 395:19 410:1

428:22 432:10,11

450:14 451:5 463:17

464:4

smaller 26:2

smallest 26:10

smart 439:20

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smooth 234:17 236:10

252:11 370:12 372:20

374:10

smoothie 236:13

snack 411:9 412:5

snacks 235:10 377:9

SNAP 24:21

soap 290:16 314:9,12

314:15 315:12 316:9

316:12

soap- 304:17

soap-based 302:11,16

302:17,22 303:3,8,17

303:19 307:17,21

310:6 311:18 314:6

315:17 316:17 397:5

soaps 290:4,5 291:6,7

291:17,22 292:5,7

315:20,22 319:9,13

society 324:7

society's 330:15

sodium 74:3 76:18 77:6

201:12,18,21 203:14

204:6,12 369:16,22

370:8,15 371:1,7,10

372:4,7,19 373:1,3,15

374:1,6,19 375:10,15

375:17 376:1,4,14

377:3,15 378:5,10

395:10,12,22 396:3

398:6,15,21 399:2

411:7 454:8

soft 234:13 237:13

soil 11:8 12:6 101:4

102:3 105:6 109:11

109:14 110:3,10

113:18 117:5 132:1

133:3 135:5,8,8,9

136:2 140:3,4 142:6,6

143:3,4,9,11 145:2

153:9 156:4 163:7,13

163:16 164:16,17

165:16,18 167:2,8,17

168:2,6,9,20,22 169:4

169:12 171:4 172:13

173:1 177:8,12,21

179:6,8 180:9,17

182:2,10,13,16,22

183:3,6,13 199:5

243:20 244:4,8

250:20,22 275:20

306:17 312:16 313:4

313:10 314:8,21

315:1 316:11 317:20

317:22 319:16,17,21

319:22 320:20 321:15

322:7,8 323:7 324:11

324:13 325:1,12,15

326:4 327:3,5,6

328:22 329:9,21

330:7 331:5,12,13,20

332:13,21,22 333:13

333:17,17,18 335:13

335:15 336:4 337:15

338:3,12 339:13,17

340:1,3,6 341:2

343:17 352:19 354:3

355:19 356:11 359:2

385:17,22 407:7

424:1,18,19 426:1

431:11,13,16 434:9

434:10,11 435:10

439:11,22 440:6,9

444:1,4 453:4 454:20

455:5,8,13 456:3,6,7

456:9 457:16 458:10

458:10,13,15,17

460:22 461:1 462:16

462:17

soil-based 283:3

340:22 344:16 438:17

440:1 459:5

soil-free 222:13

soil-grown 325:6

424:22

soilless 334:22 335:16

340:17

soils 330:16,17 331:2,9

331:10,17,20 333:4

333:14 335:22 339:22

340:9 358:12 439:18

439:19 457:3 458:9

sold 56:13 114:16

143:19 167:20 208:21

277:22 367:8

sole 294:2,3

solely 275:10 380:14

solid 101:5,13 242:16

275:15,17,19 341:4

391:4,5 414:1 428:8

solids 428:7

soluble 324:20 329:9

332:5 385:19 386:1

428:12 451:10

solubles 329:15 331:18

332:3,8

solution 101:14 132:9

140:7 162:2 177:19

235:3 237:9 339:7

341:15 391:3 416:10

437:11 458:15,17,17

460:9 461:1,21

solutions 275:9 307:8

461:7

solvents 254:10

somebody 118:2

135:11 144:7 204:4

284:22

somewhat 421:14

Sonoma 416:6

soon 45:2 62:16 164:12

186:7 323:8

sooner 120:2

sophomore 213:13

sorry 91:17 106:2 109:3

109:19 126:5 128:6

130:9 154:7 166:18

170:9 199:20 231:17

233:7 296:1 298:6

301:14 305:2,4,8,14

305:16 328:8,14,15

328:16 350:9 357:7

362:21 373:12 381:18

382:13 394:8 410:11

410:14 429:9,11

435:13 445:5 449:18

455:2

sort 12:20 125:21

226:11 286:17 354:22

355:2 356:18 388:10

417:20

sorts 193:19 270:20

sought 254:21 415:5

soul 164:12

sound 21:10 463:22

sounds 32:10 283:18

source 54:3 100:10,13

155:5 241:6,7,11

294:2,3 295:11

297:17 313:13 402:2

402:7 454:9

sourced 277:4

sources 152:22 153:2

156:8 227:17 275:17

316:13 317:14 318:1

318:3 376:19

sourcing 175:11,18

176:2

Southeastern 187:2

Southwestern 187:3

soy 51:6,9 131:9 259:21

260:6 293:13,18,19

295:4,12 297:20

soy-based 294:9,16

295:8 297:6

space 18:16 270:1

394:4

Spanish 60:5,6

sparkling 6:7

speak 96:9 109:10

122:5 133:11 145:20

193:7 217:2 234:7

280:4,8 296:10

307:13 343:11 344:4

351:11,15 381:19

394:20 452:9

speaker 111:15 280:5

306:20 328:5 403:11

speakers 383:7 393:22

394:3

speaking 119:14

139:14 156:19 230:16

254:22 259:15 320:9

431:18 432:2 458:16

spec 120:15

special 149:4 155:12

223:2 319:9 458:14

Specialist 2:11,14 4:5

7:8 234:3

Specialties 4:5 369:14

specialty 26:4 232:1

species 277:1 364:10

364:18 365:3,12

366:3 369:1 444:21

specific 46:1 54:22

70:18 92:15 101:19

113:20 155:11 166:17

177:15 187:1 232:2,6

241:12 276:6 294:8

351:14 353:22 355:16

395:22 402:10 416:4

453:11

specifically 100:4

109:16 119:9,12
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202:21 204:13 207:14

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specification 58:2

specifics 192:5 351:12

385:3

specify 177:5 247:1

specifying 295:2

speed 99:5,6

spend 9:1 186:5

spending 17:13

spent 11:1,6 17:15

87:20 214:1 238:4

375:12 422:5 431:10

462:21

spices 11:11,16

spills 217:6,15,17,18

218:2

spinach 336:16,20

SPINS 299:4,5

spirit 177:4 291:18

Split 404:22

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382:2

spoken 218:21 240:8

432:3

spot 174:3 464:21

spots 19:21

spray 207:10,10 310:21

311:2,21 427:2

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spraying 207:15

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240:18

spring 6:9 116:1 399:8

Springs 16:13

Sprout's 150:5

sprouts 408:8

squad 162:19

square 220:18

squash 106:7

squeezable 235:17

St 293:5

stability 234:22 236:10

372:10 373:9

stabilization 370:10

stabilize 239:5

stabilizer 412:12

stabilizes 411:18

stabilizing 231:16

232:4

stable 32:16 239:7,11

239:11 412:16 443:10

445:19

stack 249:11

staff 2:10 29:12,14,17

29:18 41:1,13,16

43:14 66:1 130:15

185:20

stages 67:7 75:5

268:14

stake 188:22 189:10

192:10 366:3

stakeholder 88:19

stakeholders 88:21

190:6 196:8 353:5

stamp 253:15

stamped 254:20 255:15

stamps 24:21

stance 219:4

stand 87:11 94:2

374:18

standard 47:7 101:21

102:1 114:10 117:4

118:1 173:5 176:21

179:10 183:11 221:2

221:4 222:7 224:8

235:14 247:9 250:15

289:8 383:2 417:3,12

420:20 421:14 425:13

456:8

standardization 26:14

standardize 447:9

standardized 263:17

standards 1:5 2:13 7:10

7:12,14 8:12 15:17

18:22 28:6,7,11 29:10

30:21 31:5,9 48:2

50:1,13 51:14,18

52:11,12 61:9 64:1

65:7 68:13 85:5 87:10

114:9,14 142:3 148:1

171:10 173:1,8 177:1

177:5 179:13,16

181:22 194:10 197:4

198:10 201:8,22

202:20 214:15 218:16

218:20 221:15 222:7

224:9 257:19 280:21

283:11 286:12 323:5

334:17 337:3 359:19

360:20 368:7,12

404:10 418:6 420:21

431:20 432:17,18

433:14 436:21 447:12

450:11 451:6 452:17

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Stansbury 4:16 403:12

406:14,17,19 410:7

410:13,16

staple 405:7

Stare 132:14

start 9:6,14,15,22 10:1

23:1 34:11 63:6 68:20

68:20 92:9 95:13

97:22 99:9,17 111:19

130:12 139:11 157:12

162:9 164:9 165:3

181:3,11 185:9 186:7

188:2 190:15,16

192:8 197:8 200:3,5

200:14 205:11 215:8

215:10,22 223:19

230:13 233:22 234:4

237:21 238:12 243:6

248:15 251:10,20

253:8 259:8 262:1

264:20 271:9 274:17

280:14,16 283:8

289:3,18 292:14

298:7 302:2 307:4

313:22 320:5 321:11

323:22 334:12 342:18

350:14 354:11,21

357:12 361:13 362:22

369:9 378:18 381:20

383:9 387:19 394:9

397:18 403:13 406:15

410:22 413:14 415:15

417:9 420:2 422:21

430:22 436:4 442:4

446:17 452:1 454:16

456:3,15 463:11

465:14

started 6:4 17:7 39:22

67:11 95:21 115:22

221:13 226:19 320:16

321:13 342:1

starting 8:17 15:3 84:6

84:15 94:15 115:18

130:4 163:8 168:22

187:19 454:12

starts 36:4 51:14 195:5

453:3

state 12:3,14 14:3 16:8

19:20 45:22 99:13

130:10 135:15 147:12

147:22 148:10 151:2

174:3 190:1,21,21,22

191:15,16,21,21

192:5,15,15 195:13

195:22 196:3,13

207:21 208:16 211:10

211:13 212:1 216:8

220:4 278:18 285:16

300:8 309:12 331:11

331:11 361:21 362:9

365:8 366:13 383:15

386:9 405:13 413:19

450:2 461:4

stated 100:11 103:12

128:14 151:3 207:9

262:22 283:2 457:11

statement 92:17,20

100:4 253:21 254:3

254:12 263:22 295:18

401:9 408:11 414:5

414:19,22 463:21

statements 55:1 92:16

121:14 450:20

states 43:12 74:7

102:20 115:1 126:18

131:19 132:15 189:3

195:5,19 209:9,19

211:7,12 220:15

225:10 227:16 257:2

257:3,17 275:5

290:14 294:19 295:6

299:9,22 308:1,11

309:6 343:21 344:10

344:15,16 345:6,9,13

346:2,21 361:22

362:2,5 378:10 380:1

407:1 414:9

stating 157:12 215:22

259:8

stations 358:8

statistical 430:2

statistically 113:21

statistics 345:4

status 70:14 225:6

226:18 325:6 362:11

364:18 385:10

statute 37:16 275:4

285:4

statutes 284:6

statutory 421:13

staunch 222:8

stay 32:21 48:8 148:4

193:13 195:20 218:14

236:1 266:12 286:2

332:5 443:13 445:8

stayed 32:16

staying 95:4

stays 236:19

steady 461:4

steering 403:19

stem 397:12

stems 257:7

step 8:2 192:20 270:5

325:20 334:11 386:10

Stephens 4:17,17 251:9

259:6,10,11,12

steps 229:14 273:13

359:11 386:21

stereotype 213:14

sterilants 274:2

sterile 387:16,16,20
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Neal R. Gross and Co., Inc.

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388:1,4

steroid 252:17

Steve 2:5 12:1 14:17

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173:13 179:3 241:18

305:14 310:12 312:12

312:13 318:19 327:13

332:15 337:11 338:20

354:11,13 387:2

400:22 438:12 439:7

Steven 390:16

stewards 281:4 359:7

stewardship 133:4

135:8 277:14 409:22

stick 356:18

sticker 138:10

sticking 284:13

sticky 397:7 443:11

stimulate 182:13

stint 11:6

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stipulating 278:7

stock 175:12 176:2

Stockyards 25:18

stomach 294:5

stood 210:11,15

stop 97:21 188:8,10

195:1 306:14 312:12

318:19 327:14 333:18

346:10 350:3 361:7

366:7 387:5 441:5

459:14

stopped 94:22

stopping 146:13

store 10:10 120:7

204:14 222:21 373:21

434:7,12

stores 150:6 220:14,15

345:16 367:7

stories 169:6

story 357:17 422:6

straight 41:9 98:12

173:7 302:4

strategic 4:3 20:10 30:1

350:18

strategies 277:13

strategy 164:11 276:1

Straus 4:17,17 415:14

415:17,18,18 418:2

419:12,15 422:3,17

Strauss 413:13

strawberries 350:22

stream 64:9

streamline 285:8

streams 136:19 147:22

street 113:8

strength 265:19 330:16

strengthen 122:12

124:1,19 266:2

strengthening 174:17

403:20

stress 249:1 359:14

382:22

stretch 244:4

strict 85:13 211:14

384:17 417:20 431:21

432:17 433:14

stricter 254:5

strictest 432:18

strides 425:14

strong 131:1 196:21

221:21 263:16 266:17

321:19 337:7 443:14

450:21

stronger 266:19 269:13

322:12

strongly 124:14 159:1

320:18 451:16 452:19

457:14

structure 29:1 235:21

236:1 239:2 240:15

319:17 361:18 455:19

457:16

struggle 191:14

struggled 321:7

struggling 193:9

270:14 463:16,17

students 86:12 213:15

studied 371:11

studies 203:20 204:10

312:3 330:3,10,14

338:16 370:19 400:1

400:5

study 194:5,12 198:17

198:19 328:3 374:9

402:15 416:21

studying 375:12 462:22

stuff 27:8 29:20,21

389:21

stunningly 194:2

sub- 222:6 225:12

sub-cellular 250:2,5

sub-standard 221:15

subcommittee 13:22

14:6 17:4 72:19 73:5

73:7,19 74:5,9,13

75:5,18 76:18 77:5

92:10 100:1 122:15

123:9 124:18 125:9

167:17 177:11 267:7

276:22 303:2 450:7

464:11

subcommittee's 75:22

128:12 177:15 265:21

subcommittees 7:11

9:5 71:22 91:10

subject 162:16 198:5

286:16 315:9 454:21

submerging 275:9

submit 263:5 403:3

443:2

submitted 22:1 74:21

77:17,20 271:15

272:3 303:7 363:7

369:20 395:1 400:7

submitting 46:8 55:8

392:13

subsoil 359:3

substance 125:22

212:6 255:7 274:8

319:1 427:7

substances 48:12

72:21 76:6 77:15

78:22 122:16,17

123:1,7,12,15 125:17

127:9 202:6,8 246:14

272:19 274:6 276:6,7

319:7 358:10 362:17

substantial 102:13,17

176:6 232:17

substantive 100:9

352:14

substantively 352:15

388:13

substitute 443:9

substrate 117:6 341:8

347:10 354:3 355:6

356:11 450:18 451:17

455:5,7

substrates 179:21

subtropical 364:5

suburban 142:16 146:7

success 21:19 35:17

88:6 131:3,12 197:1

successful 131:2

321:18 331:16 432:15

succinct 99:1

Sudan 110:10,11,13

Sue 2:2 14:8 152:5

154:5 429:13 435:12

459:19

suffer 182:3

sufficient 57:3,11 59:2

194:16 212:21 314:15

337:1 394:4 425:8

sugar 235:18,18 236:6

236:8,8 241:6,7,11,14

241:16,20,21 242:5,7

suggest 101:8 273:12

353:13 366:20

suggested 355:13

361:12

suggesting 127:20

288:14 366:16

suggestion 137:6 355:1

suitable 105:1 231:9,14

232:6 233:10 239:22

242:16,21 278:4

307:19 372:11 378:2

398:10 427:8

suited 263:7

sulfate 290:4

sulfates 276:2

sulfonate 76:19

sulfur 74:17

summary 5:9 70:4

372:4 378:8

summed 324:11

summer 68:8

Summers 29:4

sunflowers 447:5

sunlight 105:7,8

sunlight-free 222:13

sunset 48:10 71:4,7,13

72:21 78:15 80:1,7,9

80:11,21 81:7,7,9,12

81:15,22 82:7 83:2,6

83:7 93:8,10 288:14

302:20 377:15 394:18

395:6 396:15 397:3

Sunsets 394:22

sunsetted 81:22 82:8

superbugs 396:22

Superior 3:7 456:18

superiority 138:21

supplement 255:11

supplemented 295:13

349:15

supplements 149:5

supplier 58:14 120:13

suppliers 93:7 401:16

supplies 114:18

supply 45:8 49:10,16

55:14 56:5 59:13

60:19 61:1 93:9

124:11 184:14 204:2

269:17 270:7,22

309:19 310:3 344:1,4

344:20 395:18 401:7

401:14 402:11

supplying 346:20

415:21 416:2 453:4

support 7:11 21:9 24:8

45:6 74:4 75:14 87:21

115:4 118:7 123:17

123:22 131:1 174:19

175:5,9,20 177:9

178:5,16 179:6,14

182:16 186:4 188:13

198:11 232:14 250:13

257:16 265:16 266:17

270:2 309:15 314:5
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Neal R. Gross and Co., Inc.

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410:2 411:7 413:2,5,7

427:18 455:19

supported 87:5 359:11

384:20 399:14

supporters 162:18

165:16,17 216:8

222:9

supporting 269:15

367:13

supports 21:12 136:22

137:1 164:17 230:22

275:1 277:8 398:5

437:14

supposed 47:20 98:15

191:7 225:5 244:16

260:10

supposedly 260:13

Supreme 132:15

208:19 209:8

sure 30:2 33:10 40:9

56:4 57:8 63:18

111:21 118:17 140:14

150:20 168:1,17

170:12 174:5 178:3

190:13 195:20 200:7

213:9 216:3 234:2

243:8 288:1 298:19

302:5 310:16 324:3

350:11 379:17 389:4

402:3,13 419:14

435:17 438:16 441:12

surface 11:8 311:21

326:8 458:14

surfaces 396:5

surged 458:1

surprise 465:11,11

surprising 337:16

surrounding 213:15

survey 115:2 121:1,2

202:12 263:10 267:21

309:9,15 336:8

363:21 401:10

surveyed 336:14

surveys 395:2

survive 145:1 182:11

susceptible 182:19

suspect 228:11

suspected 214:12

246:18

suspend 38:10

suspended 46:2 236:19

Suspending 275:8

suspends 236:2

suspension 37:22

391:3

suspensions 52:16

suspicions 380:4

sustain 332:19

sustainability 343:9,13

344:6 356:1 464:3

sustainable 3:14 12:12

12:16 15:6 36:15

112:3,5 132:4 137:10

138:15,16 170:18

201:4,6 326:1 346:1

sustainably 277:4

sustained 39:11

sustaining 333:12

SVI 11:12

Swaffar 2:8 13:7,7

62:10 87:14,17 106:4

109:3 118:13 119:8

119:13,20 168:14

169:13 332:1 356:21

357:2 390:2 453:16

464:16

swallowing 296:15

sweet 112:15

switch 348:12

switching 347:13

sycophant 409:13

symbiosis 336:6

symbiotic 113:1 338:5

symmetry 311:1

sympathize 210:2

Synergistic 4:14

251:14

synopsis 429:15

synthetic 72:10 79:7

163:3 205:4 272:19

278:11 292:2 312:7

319:1,7,10 424:16

synthetics 292:1

319:11 428:5

system 30:13 36:15

45:9 50:5 51:13,20

53:2,7,9,17,17 54:11

56:21 58:8 60:21 64:7

64:13,17,20 65:4

96:21 101:20 104:15

105:1 107:13,14

113:10,11,16 117:16

118:3 120:14 124:1

137:11 139:3 140:16

140:17,19,21 141:1,2

141:7 142:4,5,11

164:18 167:13 168:1

168:4 170:18 180:18

182:13 186:10,16

187:15 188:22 191:11

194:21 201:5,6

222:16 226:20 244:2

251:3 258:15 270:20

320:1 321:5,16 322:6

322:19 323:13 324:6

324:8,11 325:18

326:2,12,17,18,22

327:9 328:20 329:21

332:17,19 333:1,13

335:19 337:15 340:21

341:5 343:16 344:7

348:20,22 349:11,11

349:17,20,20 421:11

422:15,16 428:14

438:9 439:16,17,21

440:1 441:1 451:7,12

454:3,15 456:7,9

459:2 460:15

systematic 290:7

systems 12:18 20:11

28:17 33:16,22 34:2

50:13,19 54:5,6 57:10

64:12 101:2,10

105:17 112:21 113:3

113:16 114:8 115:9

115:20 116:17 117:9

131:9 142:14 146:5,9

172:9,13,13 176:6,13

179:6 188:9 199:6,8

199:10,13 236:11

239:20 240:12,14

242:17 244:3 266:8,8

275:14 278:10 322:15

322:18 323:2 325:1

339:14 343:12 346:21

349:9 351:22 359:20

387:16 388:8 421:21

436:22 440:10 441:8

441:12 455:17,18

456:22 458:1,4

459:12

T

T 423:14

tab 17:20

table 27:14 379:16

tackle 360:21

tags 58:4

tailor 194:19

Taiwan 44:15

take 25:9 37:2 43:18

49:12 60:12 79:2,17

79:20 81:17 82:4,16

82:18 89:9 93:19

95:13 99:22 109:22

110:1 111:5,21 124:2

124:13,14 125:22

137:15 138:6 141:13

144:7,9,21 149:5

158:10 167:16 169:1

195:19 219:4 223:2

233:1 251:5 262:9

271:4 299:20 308:2

334:7 336:12 341:16

341:17 342:7,11

359:10 362:13 368:16

379:5 386:5 391:20

393:7 434:10 441:4

449:8 460:16 464:9

taken 52:14 88:18 96:3

251:17 358:7 366:18

404:1 425:12 450:16

takes 25:9 37:7 38:6

39:4 42:5 108:13

165:22 186:19 217:8

225:13 368:19 424:4

425:1 440:3

talk 20:10 21:18 31:11

53:20 70:16 83:12

89:16 99:2 109:17

129:3,5 150:2,2

162:17 188:15 218:17

219:1 228:17 261:6

281:2 381:10 413:20

416:13 417:3,4 443:4

444:11

talked 48:3 63:14 228:2

230:2 392:2

talking 48:18 55:1

97:21 157:1 186:5,7

188:2 190:14 195:17

209:4 238:22 244:8

262:19 332:22 339:22

349:19 355:18 379:4

419:22 420:2,3 422:1

445:1

talks 249:14 281:22

Tamarind 77:20

TAMAYO 3:3

tangerines 419:20

Tanimura 3:9 342:22

target 284:12 299:6

tarnish 397:1

tartrate 395:13

task 112:20 116:4

162:15 165:14,15

167:15 177:11 263:5

287:11,13 391:16

421:20 450:13,15

tasks 281:5

taste 372:9 373:8

374:12 433:6

tasted 374:5

tastes 377:1,7

tasting 433:1,2

tasty 113:8

taxonomy 46:12
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

516

teaching 12:11,12

team 35:4,5,18 46:16

63:15,19 65:16

137:15 233:2 252:14

teaming 182:22

tear 164:8

teas 108:3,4

technical 3:11 4:2 7:10

16:8 21:11 70:15

71:17,20 74:6,8 75:3

75:12 77:4,12 78:1,3

78:5,14 238:2 399:9

442:7

technically 221:18

techniques 158:22

161:11 198:11,15

337:5 435:19

technologies 325:2

technology 26:8 31:10

45:3 141:6,7 142:18

169:7 245:19 310:8

322:16 341:18 342:8

342:8 405:11 422:11

423:8,18 425:11

teeming 336:1

tell 85:22 94:22 102:14

104:9 115:14 121:5

132:8 207:18 247:2

295:10 326:7 354:20

434:5

telling 182:8 251:20

422:6

tells 96:22 135:11

temperate 344:17

ten 302:9 303:6 344:10

409:17 452:20

ten-acre 451:5

ten-year 451:11

tend 43:18

tendency 432:21

Tennessee 343:5

tens 52:8

tentacles 186:20 187:4

term 124:12 132:3,20

142:9 165:10 270:7

284:10 310:17 352:15

388:7,17 390:10

406:8 414:9,17

425:16 437:12

terms 19:5,16 20:12

21:1 25:17 29:2 32:6

33:13,15,19,21 36:3

37:1 43:6 44:12 45:21

46:6 48:2 49:13 52:11

52:21 55:4 56:6 66:10

66:12 71:10,11 76:16

78:3,21 82:11,22

113:5 134:19 135:17

156:1,6,12 212:4

258:10,13 271:2

279:11 282:11,11

297:14 313:5 339:3

349:5 439:15 461:22

terrestrial 101:11

316:14 319:15

Terry 4:14 264:19 271:8

271:8,11 274:9,10

284:16

test 96:20 207:7 244:16

246:22 247:1,3,5,6,7

247:10 248:11 362:18

374:3 416:3

tested 246:6,14 254:8

373:4 386:12 393:1

396:6

testified 269:3 434:8

testify 116:1

testimony 94:5 112:21

213:4 223:16 269:3

282:10 378:13 415:13

testing 136:12 194:6

200:21 214:4 226:17

228:13 244:15 246:15

246:17 247:14 301:11

451:11

tests 405:6

tetrahydrocannabino...

414:19

tetrahydrocannabinol

414:15,17

Texas 344:11,22

texture 234:11 236:8,22

237:11,12,13 240:15

240:22 370:13 372:9

373:8

textures 234:12

thank 6:18,20 7:20 8:9

8:10 17:1,8,13 50:2

61:7 65:19 69:22

81:18 83:9,10 84:17

86:10,18 88:11,14

89:8 93:4 95:16 102:6

102:9,9,11 103:11

105:22 109:4,7

111:12,13,16,22

112:5 115:9,10,13

122:2,9,11,14 125:12

128:2,9 129:11,12

130:7 133:10,11

134:8,9 137:3,3 139:6

139:7,8,12,18 142:21

142:22 144:17 145:7

146:22 147:3,5,7

150:15,17 153:20

154:4 155:7,15,17

157:7,9 160:11,15

162:4,5,6 165:1,5

166:15 168:12 170:5

171:17 173:9,12,13

173:19,20 180:21,22

184:22 185:1,2,2,3

189:16,22 190:17

196:10,20 198:7

199:14,17,19 200:11

203:10,11,12 204:21

205:1,5,9 208:11,12

210:18 213:1,3,4,7

215:3,4,7,11 216:1

219:9,11,13 220:6

223:7,9,12,13,15

227:5 230:6,8,9,10

233:19 237:16,17

241:3 243:1,2,12

245:6 246:11 247:17

247:19 248:12,13

251:6,7,16 255:13,17

259:4,5 261:17,18,21

262:5,11 264:9,13,15

264:18 268:20,22

271:7 274:8,9,12

278:16 279:20 280:1

280:2,18,18,22

283:11,13 286:13

288:2 289:14,15

292:8,9,12 295:14,15

296:19 297:2,22

298:3,4,9 300:18,19

301:5,19,21 304:22

305:1 307:1,2,11

310:8,10 312:11

313:17,18 317:7,9

320:2,3 323:14,15,18

323:19 327:11,12

331:22 333:20,20,22

334:3 337:10 338:20

342:5,14 346:9,12

350:2,3,16 354:8,10

357:8,14 360:14

361:1 362:19 366:4,5

369:5,11 372:20,21

374:22 375:1 378:11

378:12,13,14 379:1

380:22 381:1,12

382:14 383:3,4,5

387:7 389:7 390:1

393:16,16 394:19

397:13,14,15 400:20

400:21 403:7,9

406:10,12,13,21

410:4,5,6,19 413:10

413:11,12,16,22

414:2 415:10,11,12

417:13,14 419:3

420:5 422:3,17,18,19

426:1,2,3 427:20,21

428:1 429:4 430:17

430:18 433:15 435:12

435:22 436:2,6 438:9

438:11 441:4 442:1

442:19 445:5,7 446:9

446:10 449:9,10,11

449:19 451:21 453:15

456:11,12 459:13,14

459:15 461:15 463:9

463:9 464:14 465:4,5

465:6,7,10

thanks 7:1 18:12 61:12

62:7 112:3 124:18

134:6 151:21 219:10

354:9 356:8 357:9

358:3 389:5 393:18

426:7 429:6 430:19

THC 408:3

Theo 99:10,11,12,15

102:11 109:9 111:14

118:18

Theojary 3:3 99:15,18

therapeutic 251:15

therapist 181:6

Thermal 315:6

Thicke 2:9 17:2,3

102:11 115:13 120:22

121:9,12 165:5

288:13 310:13 337:12

338:7 348:11 387:3,7

387:10,13 433:18

452:14

thicken 238:5 398:8

thickener 412:12

thickening 239:3

thing 12:20 19:13 21:12

37:12 39:7 47:18,18

119:13 140:16 141:10

141:15 144:19 187:20

190:5 211:7 225:16

226:3,11 227:1,10,21

228:16 229:19 245:14

245:19 247:4 250:7

306:11 311:5 313:14

329:14 339:1,8

389:19 410:8 418:22

433:11 462:15

things 15:18 16:6 19:15

21:8 23:8 27:10 28:4

33:14,19 35:2 37:19

39:10 40:11,19 41:3

42:6 46:2,5 47:18

48:19,20 53:1,15

59:14 61:22 63:1

67:18 68:10,12,16,18

68:20,21 69:7,8,10

75:19 83:21 142:17
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

517

146:2,19 150:12

153:16 154:19 161:10

161:21 162:1,21

195:5 219:8 240:17

240:19 243:15 248:7

285:21 286:1 287:14

287:14,15,15 302:13

303:13 308:8 311:17

312:4,17 329:7

338:10 339:3,9,21

348:6 356:14 367:18

368:10 384:9,10

391:2 401:6 419:1,16

421:22 444:3 454:19

think 6:3 14:16 18:19

23:11 36:21 60:11

81:1,16 84:2,11 89:5

102:22 103:3,3

104:18 107:17 108:5

108:7,21 113:14

115:18 116:3 120:19

121:5 127:15 129:6

134:22 137:8,8,9,12

137:18 143:11,11

144:15 156:15,16

160:9 166:14 168:9

170:14,21 171:12

173:5 179:17 180:4

180:13,16 186:6

188:1,3,14,17 191:13

192:6,10,17,18 193:7

193:13 195:18 204:17

215:1 220:12 228:6

228:17 245:19 247:3

248:8 254:4 256:14

258:7,9,19 260:2

270:17,18,22 271:2

283:4 286:6 287:3,21

288:6,9 296:9 298:17

309:20 310:1 311:5

312:9 313:10 319:19

329:16 330:11 338:13

341:6 355:6 356:9,11

356:15,17 361:14,16

366:8,14 367:9

374:15 382:2 385:5

385:15 386:4,9,20

388:6,7,19 389:3,13

389:18 390:6,13,20

391:8,22 392:5,19

401:21 402:19 416:20

418:7,10,12,17 419:1

419:8,10,12,15

421:18,19 422:6,12

430:6 433:22 435:10

439:13 440:3,8,16

441:6,17 442:22

444:9 448:6 452:15

453:17 458:20 459:5

thinking 204:5 260:17

361:3 390:20

thinks 155:12

third 10:11 17:11 74:6

114:9 209:10 306:20

320:9 353:12

Thirdly 159:13

Thomas 2:19 320:5

323:20,21 324:2

thorough 43:3 52:2

thoroughly 132:17

396:6

thought 205:2 224:14

280:13 327:15 384:11

429:14 433:9 462:2

thoughtful 265:22

thoughtfulness 86:4

thoughts 339:5 381:5

386:6 392:6 464:20

464:22

thousands 15:8 41:11

52:8 64:18 206:10

340:6

threat 291:13

threatens 407:21

three 16:13,15,21 25:12

28:5 29:18 32:16

41:14 78:2 96:17 99:2

119:4 149:8,19 150:7

157:20 169:2 189:2,4

252:16 336:10 367:14

368:20 383:14 392:21

446:13 449:13 464:13

three-year 363:12

threshold 126:11,20

279:16 393:4 418:16

thresholds 198:22

418:14

thrive 145:1 278:9

463:7

throat 296:16

throw 118:5 131:15

throwing 338:8

thrown 225:21 455:22

thymol 74:18

tickets 57:19 58:3

ticking 286:3

ties 386:8

tight 94:13

tilapia 460:15

till 63:5

tillage 314:22 319:16

Tim 3:18 410:20 413:12

413:14,17

time 8:6 11:1,6 14:16

14:20 17:14,14 25:9

25:10 30:9 36:20 37:5

37:9 38:17,21 41:14

41:15 43:19 60:11

61:7 63:2 66:18 68:2

68:5,7 70:1 82:8

83:21 85:15,21 87:20

92:14,17 95:3 96:8,12

96:16,19 97:5 100:9

102:7 103:16 108:14

111:13 112:6 121:8

128:16 136:13 140:11

146:15 150:9,16

157:21 160:22 161:20

163:18 171:19 181:17

182:6 184:22 188:1

188:18 189:8 194:6

200:12 213:19 219:10

230:20 232:8 233:11

246:17 247:11 248:21

251:17 255:13 264:13

269:13 271:2 281:19

286:3 304:4 311:14

312:13 320:9,21

321:8,17 327:14

332:6 333:5 354:13

362:13 380:5 394:21

410:19 415:10 416:16

417:17 422:5 437:4

442:20 444:10 460:4

465:16

timely 159:5 265:12

281:11

times 8:2 16:1 61:19,20

108:15 119:5 149:8

203:15 206:15 207:8

207:8 297:10 336:16

336:17 439:20 442:18

timing 402:20

Tina 3:11 436:3 442:2,3

442:5 445:7,8,8

tinkering 289:3

tiny 240:4

tired 431:4

tireless 86:19

tissue 317:18

titanium 279:8

title 146:15 328:2

tobacco 26:4

Tocopherols 76:2

today 7:6,21 8:11 9:2

17:14 18:10,14 20:17

20:17 48:11 70:2,13

70:16 81:16 83:18

109:12 148:15 174:12

202:13 207:18 218:15

220:20 235:12 238:8

243:16 254:18,22

259:16 271:17 279:19

281:2,16 290:2 293:4

294:22 295:5 298:14

307:14 308:15 309:18

311:17 324:4 335:4

350:20 357:21 370:4

375:14 378:9 394:20

403:20 406:21 411:6

416:22 422:1 423:22

436:15 442:14 457:20

458:21 465:12

today's 232:11 426:9

426:18 465:17

tofu 413:6

told 222:17 252:18

283:15 441:9 459:20

tolerances 386:17

Tom 1:20 2:2 3:18 5:4

5:11 8:8 17:9 87:14

129:22 130:1 139:9

139:10,13 142:22

143:1,2 147:5 280:19

298:9 357:9 402:19

tomato 109:21 110:18

138:3 165:21 434:9,9

434:13,14,15

tomatoes 11:13 106:6

106:14,14 109:20

110:16 111:2 113:9

119:6,17 120:15

138:12 435:10 451:5

452:21 453:3

tomorrow 9:2,6 94:18

95:3,8 179:1 351:11

379:4 381:4,10,11

465:15

tomorrow's 426:10

tool 276:9 312:9 319:20

361:12 365:1,14

396:12 425:17

toolbox 322:2 396:20

443:22

toolboxes 396:2

tools 267:13 277:16

358:16 421:13

top 68:17 180:8 218:12

279:14 305:22 455:19

topic 159:18 175:1

183:16 211:5 258:2

263:19 278:12 287:6

379:19 380:14 399:16

464:17

topics 18:10 186:4

201:10 262:20 265:6

268:3 355:16

topsoil 359:3

torturous 222:11

total 29:8,15 85:21

171:11 277:18 285:2

286:9 293:16 295:11
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

518

345:5 348:22 412:4

totally 88:22 295:1

touch 193:13 238:21

265:5 306:9 313:16

town 222:3 341:21

towns 196:2

toxic 136:18 206:14

208:8 273:5 462:12

toxicities 312:21

toxicity 272:18 290:7,8

306:17 312:15 317:11

319:14,14

toxilogical 285:5

TR 399:11,14,19 400:1

400:13

trace 125:20 127:7,10

226:4

traceability 54:14 59:3

tracers 75:10 123:18

202:3

tracing 226:20

track 65:2 443:1

tracks 365:14

tract 294:6,7

trade 4:7 44:18 50:7

64:17,19 65:4 87:6

126:16 138:14 249:7

249:9 259:13 269:15

369:19 383:13 407:12

421:7

Trader 150:5

tradition 335:8

traditional 137:22

186:17 372:14 423:22

424:10 460:12

traditionally 456:21

trail 32:10 54:14 59:4

448:18

trained 30:4 207:6

training 11:21 21:9

50:16 59:14 60:20

65:5,6 262:22 263:15

263:17 267:14,21

268:4,4,5,8

trainings 263:1

transaction 54:21

transactions 57:2

transcript 401:15

transform 438:9

transition 16:10 117:6

368:1,17,20,21

transitional 367:9

368:3,13 421:8

transitioning 367:11,14

transitions 24:9

translating 60:4

transparency 45:8

122:15 276:7 313:8

437:17

transplants 178:19

transportation 26:6

27:6 135:13

transported 214:4

transposals 198:13

trap 397:8

traps 397:7 443:11

travel 206:10

traveled 83:15

traveling 8:11

travesty 207:4

trays 444:22

treat 396:11

treated 151:8,13 184:15

214:3

treating 151:9

treatment 184:3,11

194:16 214:6 239:6

tree 12:4

trees 112:15 306:11

tremendous 89:6

243:13,17 244:6

407:9

trend 36:11 146:13

181:13 236:7 457:18

trespass 207:20 209:20

210:6,10 211:18

trial 308:1

trials 260:12 268:9,11

tricky 227:20 228:19

tried 161:21,22 196:4

209:6 225:1 240:5

329:11

trimmings 110:16

trivial 162:22

Trope 4:18 215:11,19

215:20 216:3,3

219:10,13

TRs 282:21,22 285:22

truck 58:4 226:10

truck-mounted 206:8

true 57:8,10 90:18 91:3

170:4 376:6 377:8

truly 132:3 142:4 253:9

254:19 326:1

trust 27:15 89:4 164:3

222:7 255:7 321:9

334:17

Trustees 92:21

truth 420:13

truthful 420:15,19

truthing 365:17

try 20:14 62:4 93:21

116:12 118:17 120:1

121:20 134:15 138:18

166:16 189:20 209:8

245:5 258:14 280:7

324:4 431:2

trying 41:22 46:11 56:3

108:1 118:7 127:2,7

146:1 157:18 166:18

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Neal R. Gross and Co., Inc.

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Neal R. Gross and Co., Inc.

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Neal R. Gross and Co., Inc.

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146:21 156:9 159:6

163:15,17 164:19

165:19,20 200:19

245:2 260:7 327:1

337:2 342:9 344:1

376:21 379:7,11

380:13,16 399:1,3

411:5 423:18 442:12

458:22 459:3

world's 245:1 427:7

worldwide 33:1 53:9,9

228:4 231:6 365:10

worried 216:19 288:19

430:10

worry 70:10 269:7

worth 201:7 262:19

270:18 348:8

worthy 135:14 163:12

would've 328:10

wouldn't 104:16 106:19

120:7,8 153:18

188:11 388:3 444:2

456:8 460:7

wrap 108:22 109:2

154:5

wrapped 286:16

wrapping 9:10

wrestling 318:21

Wright 341:22

wrist 423:17

write 121:20 154:11

258:5,12 259:2

written 16:9 85:17

89:14 100:11,21

109:12 112:14,20

121:10 128:20,21

134:18 159:15 198:5

205:3 267:4,6 298:17

369:21 371:5 385:2

387:13 392:4 395:1

399:11 400:8 443:2

453:18

wrong 59:22 139:2

270:21 362:22 441:20

446:7

wrongfully 407:21

wrote 285:3 452:11

X

Y

yapping 97:5

yeah 62:15 66:19 67:6

67:19 69:1 87:16

105:12 129:9 157:1

166:15,19 168:17

170:1 172:18 178:3

179:12,12 185:12

211:3 212:22 258:2

402:4

year 10:12 13:16 14:7

15:4 17:5,11 19:4

20:14 22:5 31:19

32:20 33:3,16,22 35:8

36:4,13 42:14,15

59:12 60:19 61:4

62:12 80:14 86:16

116:10 125:7 146:3

162:14 175:5 197:10

218:8 220:16 224:22

225:19 262:8 287:9

320:16 326:7 331:14

332:7 344:18 345:2

345:17 379:14 407:14

419:9,10 422:10

448:16 450:15

year's 34:12

year-and-a-half 348:6

year-round 418:8

years 11:18 12:13,19

14:4 16:20,22 19:4

20:22 21:4 22:9,10,17

31:17 32:16 36:12

38:15,16,16,19 41:11

42:16 51:8 80:15 84:9

85:3 87:2 100:18

103:13 116:1 117:15

133:16 134:2 141:9

142:13 150:8 162:14

169:2 200:20 206:13

213:12 220:13 232:21

245:20 248:20,22

252:13 280:21 285:3

285:21 291:21 293:2

296:7 300:10 302:10

303:6 307:10 315:13

320:17 321:21 325:17

329:11 363:14 364:13

367:14 368:20 370:2

372:7 375:9,16

383:14 395:6 401:13

431:9 434:17 442:15

447:3,7 450:12

452:20 454:7 462:21

yell 280:10,12

yellow 96:17 236:4

yesterday 6:7 222:22

Yesterday's 426:8

yields 218:7

yogurt 235:7 236:21

237:1 240:19,20

yogurts 412:17

York 146:8 344:11

young 283:16 293:15

293:16

Youngblood 4:22

196:11,15,16,18

youngest 252:5,9

Z

Zareb 3:22 406:14

410:20,22 411:3

Zea 287:1,8,9

Zealand 44:4,7

zero 169:21 253:2

zinc 74:1,1

zone 118:8 180:12

335:5,10 336:5 338:4

423:6 424:22

zoom 444:1

zooming 442:22

0

0.3 414:16

0.4 299:8

1

1 126:14 127:19 375:22

412:8

1,100 141:16

1,200 174:9

1:00 200:2,3 215:9

1:40 215:14

10 14:4 16:20 74:18

79:20 100:18 103:13

214:12 218:12 336:1

344:15 365:6 435:4

10:08 6:2

100 36:10 40:22 184:7

221:1,2 223:1 278:10

281:22 289:12 336:2

354:16 375:9 418:4,6

100,000 22:15 95:5

294:22 295:18

10x 336:21

11 48:12 407:14,18

434:17 465:12

11-year 434:18

11:00 95:14

11:42 95:18

11:44 95:19

110 382:6,16 400:11

110,000 220:18

12 41:17 85:18 130:15

412:7

12:45 200:1

120 33:4 38:13 65:21

160:1 379:11 422:10

432:6

123 285:19

126 285:19

127 272:21

13 20:21 80:2 296:7

374:7

14 80:4 374:4,8

140 220:14 382:6,16

14th 16:21

15 12:13 37:8 79:19

147:10 222:21 365:6

435:2

150 260:3 382:6,15,16

382:18

1550 1:19

16 12:14,14

160 382:6,18

17 5:6

173 214:9

175 148:14

177 307:10

18 5:7 37:4 412:7

18,000 448:15

180 141:13

1800s 259:18

19 1:14 213:12

1975 17:7 431:9

1980 457:10

1989 15:15

1990 71:15 243:19

437:20 439:9,10

1990s 335:18

1992 306:22 313:3

315:19 316:5,10

1994 415:21

1995 316:6

1997 442:15

1999 292:22 295:10

19th 19:10 48:6 321:1

380:16

2

2,000 85:17

2.1 295:6

2.272 228:16

2:00 200:3

2:04 215:17

2:05 215:15

20 40:22 142:12 173:2

220:15 308:11 310:2

332:5 442:15 447:7

200 36:8 80:13 125:6

260:3

2000 407:11

2002 49:18 85:5

2005 22:8 450:5

2007 451:4

2008 22:8 49:18

2010 177:10 206:6

282:19 283:2 285:13

287:7 384:14 391:7

450:5,6

2011 19:2 87:3 244:14

309:4 345:3
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2012 32:14 246:16,19

281:21 282:5,19

285:15 286:21 293:8

293:9

2013 32:14 246:16

265:20 291:16

2014 32:15 45:5 256:20

344:8

2015 217:14 276:13

299:3 302:20 306:22

313:7 315:15 316:3,8

316:21 407:13 448:9

464:6

2016 17:19 20:19 32:17

32:18 36:5 44:6 198:1

265:11 299:3 307:22

376:12 399:9,11

409:11 448:9

2017 1:14 6:9 36:4 43:5

48:10 72:21 78:15

80:11 100:3 263:13

2019 71:4 80:1,8,16,20

81:12 394:18 397:3

2020 146:3

205.101 225:12

205.103 56:8

205.105 112:11 275:3

276:16

205.200 156:2

205.202(d) 277:20

205.204(a) 175:22

205.600(b) 72:12

205.601(b)(1) 291:7

292:8

205.601(i)(2)is 291:4

205.606 231:2

2050 363:17

20th 94:18

21 299:3 382:6,15,18

21.18(c) 292:3

215 5:16

22 263:11

22nd 244:14

23 38:20 226:18

24 318:7 460:10,16

461:11

25 95:14 248:21 447:3

25,000 20:19

2508 112:17

2611-1 244:14

27 325:16

272 225:13

28 464:6

28th 32:20

29 37:4

3

3 271:21 376:1 448:14

3,000 225:20

30 12:13 119:2 145:5,17

189:19 210:20 320:17

334:8,10 349:21

363:16 400:13 465:16

30-day 252:16

30-plus 451:1

300 447:2

30th 326:6

31 12:14

318.9 344:9

34 80:16

35 52:7 71:3,6 119:2

220:12 248:20

35,000 451:3

36 31:15 33:9 66:1

396:10

37 162:13

38,000 37:11

39 272:22

4

4 271:21 285:6,7 334:7

4,000 376:18

4/20 94:19 256:15

40 64:17 116:14 142:15

145:18 146:4 148:10

220:12 222:18 349:21

363:14

400 23:12 447:2

42-inch 358:1

43 33:4,10 65:21

44 431:8

45 288:3 346:1

45-year-old 379:9

45,000 37:10

45,682 345:7

450 363:7

450,000 225:18

465 5:18

48 346:1

491 6:11

5

5 45:5 418:16

50,000 95:5

50/50 144:16

500 448:8

51 308:21

52,000 216:13 217:10

53.2 345:8

54 308:12 344:9,14

55 85:20

55,000 216:7

55.15.1 281:22

57 344:15

6

6 5:2

6:00 95:8

6:11 465:21

60 62:20,21 145:5

336:17

60-acre 248:18

600 447:4

605 238:14

606 77:14 238:14

298:15 300:15

615 217:15

62-year-old 220:9

65 214:11

6706 409:7

68 447:1

6th 224:22 225:4

7

7 32:14 231:1

70 5:9

700 174:10

706 414:21

70s 131:21

7606 415:4,8,9

7th 48:17

8

8 5:3

8:30 465:16

80 50:7 131:10 200:20

348:18 434:2

800 379:11

80s 131:22 457:17

82 32:22 43:4 47:1,3

65:21

83 203:3

85 365:4

86 202:17

86,000 345:5

86.9 344:14

89 5:11

9

9 5:5 32:15

9:00 1:20

90 167:3 168:2 365:4

416:5 434:2

90-day 329:5

95 5:12 231:6
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

524

Board Meeting

USDA National Organic Standards Board

04-19-2017

Denver, Colorado
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1

 U.S. DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 MEETING

 + + + + +

 THURSDAY

 APRIL 20, 2017

 + + + + +

 The Board met in the Majestic Ballroom

of the Sheraton Denver Downtown Hotel, 1550 Court

Place, Denver, Colorado, at 8:30 a.m., Tom

Chapman, Chairperson, presiding.

PRESENT

TOM CHAPMAN, Chair

SUE BAIRD

HARRIET BEHAR

ASA BRADMAN

JESSE BUIE, Secretary

LISA DE LIMA

STEVE ELA

DAVE MORTENSEN

JOELLE MOSSO

EMILY OAKLEY

SCOTT RICE

A-DAE ROMERO-BRIONES

DAN SEITZ

ASHLEY SWAFFAR, Vice Chair

FRANCIS THICKE
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STAFF PRESENT

MICHELLE ARSENAULT, NOSB Advisory Board

 Specialist, National Organic Program 

LISA BRINES, Ph.D., National List Manager, 

 National Organic Program 

PAUL LEWIS, Ph.D., Director, Standards

 Division, National Organic Program

MILES MCEVOY, AMS Deputy Administrator

JESSICA WALDEN, Materials Specialist, National 

 Organic Program

ALSO PRESENT

KRISTEN ADAMS, Midwest Organic Services

 Association (MOSA)

JOHN ASHBY

JENNIFER BERKEBILE, Pennsylvania Certified

 Organic

ALEXANDER BOLLAG, Recirculating Farms Coalition

BILL BROYDRICK, Broydrick & Associates

LYNN COODY, Organic Produce Wholesalers Coalition

NICOLE DEHNE, Certification Director, NOFA;

 Vermont Organic Farmers 

MARCO DE LEONARDIS, Freeman Herbs

JACKIE DEMINTER, Certification Policy Manager,

 MOSA

LINLEY DIXON, The Cornucopia Institute

STANLEY EDWARDS, Quality Assurance International

TRACY FAVRE, Quality Assurance International

DAVID FERMAN, NS Brands

MICHAEL HASEY, The Farming Fish 

DAVID HILTZ, Research Director, Acadian Sea

 Plants

ULRIKE HODGES, Vice President of Business 

 Operations, SafeTraces

ANN MARIE HOURIGAN, Danone Wave

IAN JUSTUS, Driscoll's, Inc. 

GARTH KAHL, Common Treasury Farms; Independent 

 Organic Services, Inc.

JASON KAMIMOTO, Vice President of Sales and 

 Marketing, Rocket Farms 

PAT KERRIGAN, Organic Consumers Association

ED LEHRBURGER, Pure Hemp Technology 
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SUZANNE MCMILLAN, ASPCA 

MARTY MESH, Florida Organic Growers; Quality 

 Certification Services

MELODY MEYER, UNFI 

JOHANNA MIRENDA, Technical Director, Organic 

 Materials Review Institute

MICHAEL MOLINA, Applied DNA Science

JOAN NORMAN, One Straw Farm

RODRIGO ORTEGA, Green Health

ALEXIS RANDOLPH, Quality Assurance International

STEVE ROSSE, President, Biodegradable Products 

 Institute Board of Directors

KATHARINA SCHLEGEL, BASF 

MARGARET SCOLES, International Organic Inspectors 

 Association

CORI SKOLASKI, Executive Director, MOSA Certified 

 Organic

KYLA SMITH, Certification Director, Pennsylvania 

 Certified Organic

BETH STEPHENSON

CLARENCE WAGNER, CEA Fresh Farms

STEPHEN WALKER, MOSA 

RICHARD WALLICK

RUTH WATTS, BASF

JULIE WEISMAN

SAM WELSCH, OneCert, Inc. 

JASON WHITCHER

BILL WOLF, Wolf, DiMatteo + Associates

GWENDOLYN WYARD, Organic Trade Association
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 CONTENTS

Public Comments. . . . . . . . . . . . . . . . . . .6

Handling Subcommittee

2019 Sunset Substances

Attapulgite. . . . . . . . . . . . . . . . . . . .278

Bentonite. . . . . . . . . . . . . . . . . . . . .280

Diatomaceous earth . . . . . . . . . . . . . . . .282

Nitrogen . . . . . . . . . . . . . . . . . . . . .283

Sodium Carbonate . . . . . . . . . . . . . . . . .284

Acidified sodium chlorite. . . . . . . . . . . . .285

Carbon dioxide . . . . . . . . . . . . . . . . . .286

Chlorine Materials (Calcium hypochlorite,

 Chlorine dioxide, Sodium hypochlorite) . . .287

Magnesium chloride . . . . . . . . . . . . . . . .289

Potassium acid tartrate. . . . . . . . . . . . . .291

Sodium phosphates. . . . . . . . . . . . . . . . .293

Casings. . . . . . . . . . . . . . . . . . . . . .300

Konjac flour . . . . . . . . . . . . . . . . . . .310

Pectin (non-amidated forms only) . . . . . . . . .316

Proposal: L-methionine . . . . . . . . . . . . . .322

Proposal: Short DNA tracers. . . . . . . . . . . .334

Proposal: Tocopherols - Annotation

 change on the National List. . . . . . . . .343

Proposal: Marine algae listings on the

 National List. . . . . . . . . . . . . . . .353

Proposal: Ancillary substances permitted in

 cellulose. . . . . . . . . . . . . . . . . .361

Discussion Document: Bisphenol A (BPA) in

 packaging. . . . . . . . . . . . . . . . . .365

Subcommittee Discussion. . . . . . . . . . . . . .370
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 CONTENTS

Livestock Subcommittee

2019 Sunset Substances

Chlorine Materials (Calcium hypochlorite, Chlorine

dioxide, Sodium hypochlorite)

Chlorhexidine. . . . . . . . . . . . . . . . . . .386

Glucose. . . . . . . . . . . . . . . . . . . . . .390

Oxytocin . . . . . . . . . . . . . . . . . . . . .391

Tolazoline . . . . . . . . . . . . . . . . . . . .395

Copper sulfate . . . . . . . . . . . . . . . . . .397

Lidocaine. . . . . . . . . . . . . . . . . . . . .400

Procaine . . . . . . . . . . . . . . . . . . . . .401

Discussion Document: Clarifying "emergency" for

use of synthetic parasiticides in organic

livestock production . . . . . . . . . . . . . . .406

Compliance, Accreditation, and Certification

Subcommittee

Proposal: Personnel Performance evaluations of

inspectors . . . . . . . . . . . . . . . . . . . .413

Discussion Document: Eliminating the incentive to

convert native ecosystems into organic crop

production . . . . . . . . . . . . . . . . . . . .419

Subcommittee Discussion. . . . . . . . . . . . . .423

Adjourn. . . . . . . . . . . . . . . . . . . . . .444
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1 P-R-O-C-E-E-D-I-N-G-S

2 8:33 a.m.

3 CHAIR CHAPMAN: All right, welcome,

4 everybody, to the second day of the NOSB meeting. 

5 We'll come back into session now, and we'll begin

6 again with Public Comment, which will continue

7 until lunch. And then we'll get into the Handling

8 Subcommittee, followed by Livestock, and then

9 CACS.

10 Before we get into Public Comment, I

11 just want to again review the Public Comment

12 policy as outlined in our Policy and Procedures

13 Manual. So generally if you want to comment to

14 us, you need to sign up in advance. If time

15 permits, we will take last minute sign-ups or

16 walk-ins, but that's really dependent on time.

17 Our schedule may change. We were both

18 ahead and then greatly behind schedule yesterday. 

19 So please just prepare to come early or late. Can

20 you go to the next slide.

21 The time allotment will be three

22 minutes. I do again ask that you stop at the
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1 three minutes. I do not like interrupting folks

2 but will if needed. And that's just in order to

3 ensure equal access. But don't run away, because

4 we may have questions for you.

5 Persons, people are asked to give their

6 name and affiliation for the record at the

7 beginning of their comment. If any member of the

8 board has questions, I encourage you to ask about

9 folks' affiliations to get further clarity. Proxy

10 speaking is not permitted.

11 Public commenters are asked to refrain

12 from making any personal attacks or remarks that

13 might impugn the character of another individual,

14 be it on the board or in the public or part of the

15 program.

16 And then we ask you to be succinct and

17 clear about the issues you want to speak about

18 before the board, so we can comprehensively

19 understand the issues you're trying to convey to

20 us.

21 With that, we'll get started. As a

22 reminder, the light system will give you a warning
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8

1 with one minute left at yellow, and then we'll

2 buzz red when time has run out. And if you have

3 a PowerPoint, there will be a remote up there for

4 you to click through your slides.

5 So getting started, the first speaker

6 for this morning is Joan Norman. And on deck,

7 there's an on-deck chair over here by Dr. Brines. 

8 So we ask if you are on deck, that you come to

9 that chair. On deck is Richard Wallick.

10 Joan, if you could start with your name

11 and affiliation for the record.

12 MS. NORMAN: Yes, sir. My name is Joan

13 Norman, One Straw Farm. My husband and I own One

14 Straw Farm, a family-owned and operated vegetable

15 farm in Maryland since 1983. The second

16 generation has returned to the farm, and we found

17 out this week a third generation's on its way.

18 We've always grown organically,

19 becoming certified in 1986, and continued

20 certification for 26 years, until 2012, when we

21 withdrew our application for certification in

22 order to use biodegradable mulch film.
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9

1 All of our growing practices continue

2 to be done organically with this exception. We've

3 been using this mulch for eight years with no

4 negative results.

5 The NOSB voted to allow biodegradable

6 mulch film with a vote of 12-3. Later, the NOP

7 added Memo 15-1. This memo created a situation

8 where no biodegradable mulch films are allowed,

9 which was not the intent of the original vote. My

10 husband and I have spoken at several NOSB meetings

11 on this topic.

12 It occurred to me recently --

13 (Whereupon, the above-entitled matter

14 went off the record at 8:36 a.m. and resumed at

15 8:43 a.m.)

16 CHAIR CHAPMAN: Get it back up and

17 running. But in the interest of time, I apologize

18 if the speakers coming up had a PowerPoint, we're

19 going to just be audio only. And Joan, we'll

20 start your time over from the beginning.

21 MS. NORMAN: Start from the beginning?

22 CHAIR CHAPMAN: Given the amount of
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1 distraction.

2 MS. NORMAN: You didn't pull the plug

3 because I withdrew my application, right?

4 CHAIR CHAPMAN: What?

5 MS. NORMAN: You didn't pull the plug

6 because I withdrew my application.

7 CHAIR CHAPMAN: No, we'll start over.

8 MS. NORMAN: I'm just being a smart

9 aleck, sorry.

10 CHAIR CHAPMAN: Is everyone back? Most

11 people are back and the board is settled. All

12 right, so come back to order. We're going to

13 start her time over from the beginning. You

14 ready? All right. Name and affiliation for the

15 record, please.

16 MS. NORMAN: Joan Norman, One Straw

17 Farm. My husband and I own One Straw Farm, a

18 family-owned and operated vegetable farm in

19 Maryland since 1983. The second generation has

20 returned to the farm, and we found out this week

21 a new, third generation's on its way.

22 We've always grown organically,
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11

1 becoming certified in 1986, continued

2 certification for 26 years, until 2012, when we

3 withdrew our application for certification in

4 order to use biodegradable mulch film.

5 All of our growing continues to be done

6 organically with this exception. We've been using

7 this mulch for eight years with no negative

8 results.

9 The NOSB voted to allow biodegradable

10 mulch film with a vote of 12-3. Later, the NOP

11 added Memo 15-1. This memo created a situation

12 where no biodegradable mulch films are allowed,

13 which was not the intent of the original vote. My

14 husband and I have spoken at several NOSB meetings

15 on this topic.

16 It occurred to me recently you were

17 only hearing from us. So I started a petition to

18 share with you the opinions of those who were not

19 able to attend. Like my husband, they are home

20 working in the fields to produce food.

21 Biodegradable mulch is an important

22 part of our farming practices. It saves us water,
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1 reduces weed pressure, minimizes soil erosion,

2 keeps produce cleaner, which is an important part

3 of FSMA. Biodegradable mulch is more important

4 that polyethylene mulch for us in several ways.

5 It reduces our labor cost, which is

6 becoming much more important as the minimum wage

7 approaches $15 an hour. Most importantly, it

8 allows us to get our cover crops planted faster in

9 the fall, which prevents erosion and increases

10 fertility.

11 It also reduces the amount of waste

12 that ends up in a landfill, if the landfill will

13 accept it, and the costs associated with that

14 removal. It doesn't seem organic to put our waste

15 in someone else's backyard.

16 Comments from the petition: I think

17 it's important that the label organic be carefully

18 applied to reflect a truly broad-based and

19 science-based look at what are globally sound

20 practices.

21 What's happening on the focusing on the

22 letter of the law is that factory farms can
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1 maintain organic designation, while truly ethical

2 and cautious farmers who follow all best practices

3 lose their designation. I hope for not a

4 loosening of organic farming rules as much as a

5 reasonable inclusion of materials and practices

6 that are truly eco-based on science. 

7 From a farmer: I'm a certified organic

8 farmer with over 20 years' experience. Despite

9 using a variety of methods for integrated weed

10 management, including crop rotation, tractor

11 cultivation, hoe and hand weeding, weed management

12 is still a major challenge for some long-season

13 crops, like winter squash, melons, and sweet

14 potatoes.

15 Our farm has not historically used

16 plastic mulch due to the challenges of removal and

17 the environmental costs of disposal. I would use

18 biodegradable film mulch on our farm if it were

19 allowed in organic production.

20 Another says, As an organic farmer, I

21 absolutely need this option for weed control and

22 the overall economic viability of my business.
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1 Consumer: We need to continuously be

2 moving towards ways of living lighter on the land

3 and creating less waste that our children will

4 have to deal with. This technique that would make

5 farming easier for organic farmers I believe

6 should be allowed to use this film so it would

7 make their farming methods easier so we can --

8 CHAIR CHAPMAN: If you want to finish

9 your sentence.

10 MS. NORMAN: Continue to get their

11 wonderful and safe harvests.

12 CHAIR CHAPMAN: Thank you. Questions? 

13 I see Harriet and then Dan and Dave.

14 MS. BEHAR: Good morning.

15 MS. NORMAN: Good morning.

16 MS. BEHAR: Are you aware that more

17 than 80% of the mulch is a petroleum-based product

18 and that's what's breaking down in your soil?

19 MS. NORMAN: I think there's a comment

20 coming from some other people. But we did know

21 that there's things happening. And petroleum is

22 kind of a -- I know a lot of things, but I think
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1 you need to hear the comment from the biochemist

2 who's coming up.

3 MS. BEHAR: So let's say that it is

4 petroleum-based. How would you feel about that?

5 MS. NORMAN: At this point, I still

6 feel better if I'm eating organic produce. I

7 still feel like I have to be responsible for what

8 I'm eating, and putting that petroleum-based thing

9 in somebody else's backyard and saying it's not my

10 problem where it will never go away is wrong.

11 CHAIR CHAPMAN: Dan.

12 DR. SEITZ: So I imagine there are many

13 other farmers in the Northeast who are also

14 planting the same crops as you that are certified

15 organic. How are they dealing with their weed

16 problems so that they're retaining their organic

17 status?

18 MS. NORMAN: They're using the

19 polyethylene mulch and rolling it up and putting

20 it into a landfill. Some of them are burning it,

21 which is not, if their state allows it. Or

22 they're just leaving it on the side of their
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1 fields. So it's not going anywhere.

2 CHAIR CHAPMAN: Dave.

3 MR. MORTENSEN: Yeah, good morning. 

4 You made the comment that it helps facilitate

5 getting the cover crops down.

6 MS. NORMAN: Yes.

7 MR. MORTENSEN: Could you talk about

8 that just a little bit?

9 MS. NORMAN: So when you have to take

10 it out of the field, what happens is, you know, we

11 have to go through the field, you'd have to lift

12 the plastic, that's one pass through the field. 

13 Then it has to be rolled up.

14 It takes four guys several hours to

15 take a field out of production. Because this is

16 broken down, we just roll, take the tractor

17 through with a disk through it, roll up just the

18 drip tape. And it only takes two people, and

19 we're done, in and out of the field in a couple of

20 hours.

21 So in the fall, when we're pressed for

22 time, that becomes absolutely crucial. Before we
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1 started using this, we had fields that were left

2 fallow all year because we just couldn't get the

3 cover crop in.

4 MR. MORTENSEN: Okay, very good. Thank

5 you.

6 MS. NORMAN: I'm all done?

7 CHAIR CHAPMAN: Thank you, Joan.

8 MS. NORMAN: Thank you.

9 CHAIR CHAPMAN: So we're going to skip

10 over Richard for now because the AV is not up. 

11 Richard, I think you're fine with that. I'm also

12 going to skip over Katharina Schlegel from BASF

13 right now, because you also had a presentation. 

14 If you'd like to go, just talk, without the

15 presentation, talk to Michelle and we'll loop you

16 in.

17 But we're going to move on to people

18 who don't have video presentations. And so up

19 next is Linley, followed by Clarence Wagner. So

20 Clarence, you're on deck. Linley, if you can

21 state your name and affiliation for the record.

22 MS. DIXON: Sure, my name is Linley
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1 Dixon of The Cornucopia Institute. I have a

2 master's in plant and soil science, and a Ph.D. in

3 plant pathology. I have also worked in extension,

4 and as a plant pathologist at the USDA

5 Agricultural Research Service.

6 My husband and I started an organic

7 farm that now has a 150-member CSA and a farmers

8 market vegetable farm in southwest Colorado. 

9 After seven years of farming on rented land and

10 moving the farm location three times, we

11 understand some of the challenges that new organic

12 farmers are facing.

13 I'm a member of local chapters of the

14 National Young Farmers Coalition and the Rocky

15 Mountain Farmers Union. So I regularly hear about

16 the struggles of the beginning organic farmer. At

17 the same time, working for The Cornucopia

18 Institute, I hear from the original organic

19 pioneers, many of whom were part of the movement

20 to create the standards.

21 Neither group has good things to say

22 about what organic has become, yet they both
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1 express that OFPA was well written, if it's

2 enforced.

3 As we've seen with organic eggs, where

4 over 80% of the market is now CAFO operations,

5 where outdoor access is a porch, please remember

6 that market forces drive production to the minimum

7 standard. Through your tenure, please keep the

8 minimum standard in line with OFPA, because that

9 minimum standard is what organics ultimately

10 becomes.

11 On hydroponics, attempts to define

12 organic based on biology in the system, it's not

13 in line with OFPA, and all production systems,

14 including conventional systems, have biology. 

15 Whether or not fertilizers are readily available

16 to plants or made available by bacteria, that's

17 not the point, that's not OFPA.

18 Container systems aren't organic

19 because they're removed from the regenerative

20 organic practices that cycle nutrients and capture

21 carbon in the soil. And be careful of that word

22 regenerative, because it's quickly replacing
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1 organic.

2 We're tomato greenhouse growers in the

3 soil, in the ground. We're avid composters and

4 cover croppers. We use regular fish emulsion on

5 our container transplants, but once we plant, our

6 fertile soil takes care of the rest. These

7 practices are required of organic farmers in OFPA. 

8 U.S. authentic organic farmers aren't

9 getting the financial benefits of the increase in

10 demand for organics. Imports in industrial

11 hydroponic container operations that never should

12 have been certified in the first place are the

13 problem.

14 What we need to remember in this room,

15 when we're trying to grow organics, is that

16 there's a massive local food movement sweeping the

17 nation, including thousands of farmers adhering to

18 OFPA that can grow organics if given the

19 opportunity. Let's encourage these farmers to get

20 certified by keeping the standards strong.

21 The organic founding farmers paved the

22 way and taught us to strive for continuous
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1 improvement in our systems. They're working now

2 towards no till and greater soil carbon capture

3 and renewable energy in their systems. When they

4 ask for that same continuous improvement in the

5 organic standards --

6 CHAIR CHAPMAN: You want to finish your

7 sentence?

8 MS. DIXON: Sure, it's my most

9 controversial one. They're called the firing

10 squad, hooligans, or Luddites by the industrial

11 players that are profiting from their hard work. 

12 But just remember the heart and soul of the

13 foundation of the organic movement in your work

14 when decision-making.

15 CHAIR CHAPMAN: Thank you. Questions

16 for Linley? Emily, Ashley.

17 MS. OAKLEY: Hi, you mentioned the

18 National Young Farmers Coalition, of which I'm

19 also a member. And I'm a really big advocate for

20 beginning and young farmers to get certified, and

21 for direct market farmers to get certified. And

22 I was wondering if you could elaborate a little
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1 bit on that.

2 MS. DIXON: It's a huge problem in our

3 area, and these are what I consider organic

4 farmers. And kind of the rumor on the street is

5 that you can get certified to get into Natural

6 Grocers or some of the wholesale markets, but that

7 the prices are so low, and so it's not worth it.

8 And so what they've done in our area is

9 we have a farmer-distributed coop. And people are

10 getting GAP certified for that, but they're not

11 getting organic certified. You know, some of it,

12 I'm going to try to pave the way, but we now are

13 on permanent farmland, we hope.

14 Some of it is because we're all leasing

15 really expensive land. But a big problem is

16 people are just jaded with the organic word, and

17 so they're going to form their own cooperative to

18 distribute and sell themselves as better than

19 organic. And that's what we're doing in our

20 region.

21 CHAIR CHAPMAN: I have Ashley then

22 Harriet.
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1 MS. SWAFFAR: Linley, a couple

2 questions for you. So on your organic farm that

3 you have, what percentage of your nutrients come

4 from some type of liquid feeding? And then what

5 is your crop rotation? You say you grow

6 greenhouse tomatoes, can you describe that?

7 MS. DIXON: Sure, yeah, we're huge

8 composters, so that's how we get our fertility. 

9 And so I'm not sure if I can figure out the

10 percentage that, you know, a young tomato plant in

11 its container is getting from liquid nutrients.

12 But I would probably say that when it's

13 in that container, you know, it needs fish

14 emulsion once or twice a week for eight weeks

15 until we transplant. So it's not very much,

16 considering then the large bulk of the plant is

17 grown in the soil. So I don't know the

18 percentage.

19 MS. SWAFFAR: So you don't spray or

20 apply anything after you transplant.

21 MS. DIXON: No, no.

22 MS. SWAFFAR: And then crop rotation in
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1 your greenhouses, what do you do there?

2 MS. DIXON: Yeah, we go back to

3 tomatoes and basil and peppers in the same

4 greenhouses. But we bring in, you know, similar

5 to Dave Chapman's, we bring in compost material

6 for that fertility and cover crops as well. Like,

7 we'll mow it down and bring that in to the

8 greenhouse.

9 We grow over 40 different crops, so our

10 crop rotations are pretty elaborate. But in the

11 tunnels, we're bringing in material from the field

12 or from composting.

13 CHAIR CHAPMAN: Harriet.

14 MS. BEHAR: So organic is kind of a

15 dance between having no synthetics at all, and

16 being practical so we can actually have organic

17 food, so we can grow crops, we can process crops,

18 we can raise livestock.

19 And I think sometimes it's hard for

20 consumers to understand that perhaps a synthetic

21 might be needed, like baking soda or ascorbic acid

22 or fish emulsion because of the synthetic
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1 phosphorus that's added, or what acid is added.

2 So what does Cornucopia do to educate

3 consumers about the challenges of producing food

4 and help them understand that some synthetics and

5 practices might be necessary in order to actually

6 be practical in providing them organic food?

7 MS. DIXON: We post all our NOSB

8 comments on the website. And I think you'll find,

9 for example, you know, for this meeting, our

10 coppers, that's a synthetic. We try to educate on

11 the need for them and the need to use them smartly

12 so that it's not just a regular routine weekly

13 spray.

14 But I think our comments are very

15 elaborate, and so we point consumers in that

16 direction if they're confused about what organics

17 is.

18 CHAIR CHAPMAN: Thank you, thank you

19 very much. Up next is Clarence Wagner. And then

20 it looks like we have our AV up, so we'll do

21 Clarence first, and then we'll come back to

22 Richard after that.
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1 MR. WAGNER: My name is Clarence

2 Wagner, CEO of GSSI and International, and

3 consultant to CEA Fresh Farms.

4 I'm speaking in support of continuation

5 of organic certification of hydroponics,

6 aquaponics, aeroponics, and containerized organic

7 growing methods that I am labeling hydro organic,

8 which allow for the cycling of nutrients through

9 biologically diverse process and only use

10 certified organic inputs and practices.

11 In 2002, the NOP acknowledged the

12 advancements of all types of hydro organic farming

13 techniques when they redefined the USDA definition

14 of organic so it did not include the word soil and

15 it could be more broadly applicable beyond field

16 growing.

17 In 2014, they reaffirmed that

18 hydroponics and aquaponics can be continued to be

19 certified. Eliot Coleman's assertion that quote

20 there isn't any soil in hydroponic production, so

21 how it can be organic. Most people think organic

22 production is all about the soil.
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1 However, the reality is, they don't. 

2 A U.S. study, Organic Hydroponics and Aquaponics,

3 states that consumers associate organic with

4 chemical-free, healthy, and nutritious and

5 environmentally friendly.

6 Over time, the message of the

7 traditional definition of growing organic so as to

8 feed the soil was lost to the consumer because the

9 consumer see all produce as grown in soil. 

10 Therefore, soil was not the distinguishing

11 differentiator for the public today.

12 The consumer is more interested in

13 feeding themselves with chemical-free, healthy,

14 nutritious food that is environmentally friendly

15 for them. Those are the attributes that they

16 define as organic on the label today.

17 However, like soil growers, hydroponic

18 and aquaponic farmers also feed the water, if you

19 will, with compost-used nutrient solution, and

20 water feeds the plants.

21 The net result yields the same high

22 quality, chemical-free, healthy food to deliver to
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1 the public for what they want to buy as organic,

2 because it is organic. There is room for both

3 techniques in growing, in production of organic

4 food.

5 The NOP should establish a USDA organic

6 regulation for water-based organic methods that

7 clearly outlines what requirements are necessary

8 to continue to receive USDA certification, just as

9 there are for soil-based growing. 

10 The only difference between organic

11 methods, inputs, and practices boil down to one:

12 what is the medium, soil or water? We both feed

13 our plants through a medium and have biodiversity,

14 while practicing all other organically grown

15 requirements.

16 Therefore, I recommend that the NOSB,

17 NOP, and USDA should establish a USDA soil organic

18 label and a USDA water organic label, each with

19 its own rules and guidelines to ensure U.S.

20 organic practices are maintained by both.

21 These guidelines would be gratefully

22 received by consumers, the USDA organic
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1 certifiers, who have been asking for them, and the

2 organic hydroponic/aquaponic farmers. We need to

3 all work together in both letter and spirit of

4 OFPA and NOP regulations.

5 And it's time for us to come together

6 as one body so as to reinforce and maintain strict

7 organic standards for our various methods of

8 organic growing, and give our nation and the world

9 an abundance of the best and healthiest food

10 available. Thank you.

11 CHAIR CHAPMAN: Thank you. Any

12 questions, Harriet -- oh, Jesse.

13 MR. BUIE: What test do you use to

14 quantify the health of your media system? For an

15 example, in soil, we have the Haney Test. Do you

16 have tests like that?

17 MR. WAGNER: With the media readings in

18 the water and so on, of course we are testing

19 using organic nutrients that are, you know,

20 established and certified as organic.

21 And we can test the water for what's

22 going on within the water, both with the mineral
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1 contents as well as the biology that's going on in

2 the water. This can be done very simply by

3 systematic testing, both of the input going in and

4 going out, before it's recirculated.

5 MR. BUIE: Okay, and you are able to

6 quantify the different inputs that you have, a

7 test to quantify these different inputs?

8 MR. WAGNER: Yes, there are laboratory

9 tests that are available and can be used that tell

10 you exactly what the spectrum is going on in the

11 water. Yes.

12 CHAIR CHAPMAN: Harriet, Emily.

13 MS. BEHAR: Can you explain right in

14 the growing area where you grow your hydroponic

15 crops how you promote ecological balance and

16 preserve biodiversity?

17 MR. WAGNER: The plants themselves are

18 creating their own environments within the root

19 system. That's true in water, it's true in the

20 soil. They are taking the nutrients up within the

21 solubility factor with water itself.

22 That's true in water and true in soil. 
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1 So the biodiversity that takes place that's going

2 on there, which can be shown and tested and

3 proven, is, it's its little environment itself

4 within the rootball of the plant.

5 The same thing is happening in soil. 

6 The elements are put in, it's broken down, and

7 then it's taken up with water as a soluble into

8 the plant, so it can give the nutrition to the

9 plant.

10 CHAIR CHAPMAN: Emily.

11 MS. OAKLEY: Could you tell me, sorry,

12 about the fate of the water after it's been cycled

13 through the system and where it ends up, and the

14 testing that's done on it in terms of nutrient

15 load, and, you know, where it ends up.

16 MR. WAGNER: The water itself is

17 recirculated. And so nothing is dumped out. We

18 have nothing expelled from the system itself. So

19 the water is taken and is recirculated.

20 And after it goes off out of the

21 system, to go back into the system, it's

22 completely tested in order to know exactly what
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1 the mineral levels are and what the biological

2 levels are, so that it can be re-injected with a

3 nutrient, so it can go back into the plant, in

4 order for the plant to take up what it needs.

5 CHAIR CHAPMAN: Yeah, briefly, and then

6 we'll need to move on.

7 MS. OAKLEY: I don't have a scientific

8 term for this, but basically how do you keep the

9 water from getting funky after all that recycling?

10 MR. WAGNER: It's a --

11 CHAIR CHAPMAN: Could you speak into

12 the microphone, please? Thank you.

13 MR. WAGNER: Oh, I'm sorry. The water

14 is filtered. When it goes out, it's filtered. 

15 And then when the filtering takes out anything, of

16 course it's tested constantly in order to be sure

17 there's no unwanted biology going on in there. 

18 Which of course you need to do in the

19 field as well. So it's filtered in order,

20 basically purified, and then it is re-inoculated

21 with the elements.

22 CHAIR CHAPMAN: Thank you very much. 
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1 Sue, and then we're going to have to stop, because

2 we're already 20 minutes behind schedule.

3 MS. BAIRD: Do you have a way to

4 measure in biological activity as opposed to --

5 CHAIR CHAPMAN: Sue can you please use

6 your microphone.

7 MS. BAIRD: I'm sorry, did it again. 

8 Do you have a way to measure biologic activity as

9 opposed to just mineral uptake in your plants? 

10 Are you doing that?

11 MR. WAGNER: There is a way to test the

12 biology. I mean, how do you test the biology in

13 the soil? You take it and you take a sample and

14 you test the biology, and you have a

15 microbiologist take a look at it. Yes, we can do

16 the exact same thing.

17 MS. BAIRD: You do that same thing.

18 MR. WAGNER: Yes.

19 MS. BAIRD: Okay, thank you.

20 MR. WAGNER: It's the same method. You

21 just take it and check the microbiology going on.

22 MS. BAIRD: Okay, thank you.
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1 CHAIR CHAPMAN: Thank you, Clarence. 

2 So up next, I have Richard Wallick, and on deck is

3 Katharina Schlegel. Richard, if you'd start with

4 your name and affiliation for the record.

5 MR. WALLICK: My name is Rich Wallick,

6 and I am simply a consumer of what is supposed to

7 be organic.

8 Federal statute and regulation are

9 quite clear. Both intentionally differentiate

10 between fertilizers farmers make and commercial

11 fertilizers that are purchased.

12 For ten years, big organic ag in

13 California was using urea on tens of thousands of

14 acres. According to CCOF, the users include

15 Earthbound Farms, Driscolls, and Grimway Farms. 

16 In 2007, NOP staff wanted to take action, yet the

17 CDFA and the CCOF, with NOP's blessing, simply

18 ignored the gross violations.

19 CCOF was aware of the questionable

20 nature of these fertilizers, by its own admission. 

21 CCOF claims the right to certify regardless of the

22 use of prohibited substances. This is what
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1 happens to small farmers when honest mistakes are

2 made.

3 How does one ask for better flow

4 characteristics and increased nitrogen and be

5 unaware that the wishes are granted? CCOF on what

6 to do when prohibited substance are proven to be

7 used, Miles McEvoy on produce grown with

8 prohibited urea.

9 NOP wanted to disallow the crops to be

10 marketed as USDA organic. Today, we have no way

11 to ascertain whether the certified products meet

12 USDA organic regulations as NOP has, and possibly

13 still does, allow the CCOF to accept

14 determinations by an opaque OMRI.

15 OMRI has absolutely no oversight. OMRI

16 refused permission for NOP to accompany an ISO

17 audit.

18 The NOSB recommended that MROs be

19 accredited or authorized entities and that

20 material decisions only be made by NOP-authorized

21 entities. Unless NOP was requesting a change to

22 OFPA, this means that MROs must be NOP's
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1 accredited certifiers.

2 OMRI uses its own advisory board to

3 circumvent USDA organic regulations, resulting in

4 their allowing chemical fertilizers containing

5 prohibited substances, including toxic metals. 

6 How does one import commercial fertilizers

7 containing toxic metals without contaminating the

8 soil?

9 NOP 3012 implied that certifiers cannot

10 accept a determination by an MRO that is not an

11 accredited certifier, though it muddies the water

12 by implying that, quote, if their manufacturer may

13 submit their products for review to more than one

14 certifying agent or MRO.

15 From the CCOF form, compost and manure,

16 it appeared the CCOF is currently accepting OMRI

17 determinations. That should read what CCOF

18 accepts, rather than what OMI requests. I did it

19 in three minutes.

20 CHAIR CHAPMAN: Thank you, any

21 questions?

22 MR. WALLICK: Any questions?
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1 CHAIR CHAPMAN: Harriet.

2 MS. BEHAR: It's more of a comment that

3 we are working on contaminated inputs on the NOSB,

4 to try to give some guidance to. Because there is

5 consistent inconsistency, and some issues here and

6 there, that this is a complex subject. And so we

7 are taking --

8 MR. WALLICK: This is not a complex

9 subject. This is a question of the law, and the

10 law clearly differentiates where it provides for

11 a zero tolerance on commercial fertilizers. 

12 Fertilizers that firms are making on the land have

13 a different set of requirements.

14 This was done intentionally so that

15 there would be no importation of outside

16 prohibited materials to pervert the soil and

17 contaminate the soil. Oh, this is about soil.

18 CHAIR CHAPMAN: Thank you, Richard. 

19 Any other questions? Thank you very much. Up

20 next we have Katharina, and on deck is Margaret

21 Scoles. Katharina, can you start with your name

22 and affiliation for the record.
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1 MS. SCHLEGEL: So Katharina Schlegel

2 from BASF. Good morning, and we're waiting for a

3 slide. Yeah, good morning, thank you very much

4 for giving me the chance today to talk to you. 

5 I'm a microbiologist working on biodegradable

6 polymers in soil at BASF, a producer of

7 biodegradable polymers.

8 I heard that there was a lot of

9 discussion on biodegradable mulch film. And

10 that's why I would like to take the chance and

11 talk to you today about the scientific background

12 of biodegradation of biodegradable polymers.

13 I would like to start with this highly

14 discussed topic of biobased and biodegradable

15 materials. As you can see, there are materials

16 that are biobased and that are, and you have

17 materials that are biodegradable. So it's just

18 the carbon that's deciding if you have something

19 that's biobased or fossil-based.

20 For example, there are materials like

21 the so-called bi-polyethylene, which is completely

22 biobased, but it's absolutely non-degradable. And
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1 there are materials which are called

2 biodegradable, but they are fossil-based, so their

3 carbon is coming from a fossil source. But these

4 materials are completely biodegradable, degrading

5 into CO2 and biomass.

6 And of course, there are materials that

7 are in the middle, biodegradable and biobased. 

8 All these materials have different properties, and

9 as they do have different properties, you cannot

10 make a mulch film out of all of them.

11 And therefore we have a product on

12 market which consists of a mixture of different

13 polymers which are all completely biodegradable. 

14 But some of them are biobased and some are not. 

15 And this mixture is needed to have a functional

16 mulch film which is working in the field.

17 So why is it that some materials are

18 biodegradable, others are not? I want to give you

19 a little insight on the biodegradation process,

20 and I know it's a complex topic. I just want to

21 highlight the most important parts. So how does

22 it work if you have a biodegradable coming into
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1 the soil?

2 You have the polymer, and the polymer

3 is cut down into small pieces. And these small

4 pieces are then taken up for organisms and

5 degrading to CO2 and biomass.

6 So what is important is organisms do

7 not differentiate between the material that you're

8 having. They do not care if it's fossil-based or

9 biobased. They simply care if they do have

10 enzymes that are able to cut down the polymer into

11 pieces.

12 What you can measure and what comes out

13 is CO2, water, and biomass. Biomass is like the

14 organic material of organisms inside the soil. 

15 Unfortunately, only CO2 can be measured. 

16 Therefore, we always talk in our standards about

17 the 90% conversion to CO2, simply because we

18 cannot measure biomass.

19 This does not mean that there are any

20 residues left. And we did a lot of

21 ecotoxicological testing. We never found any

22 negative effect on plants, animals, or bacteria.
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1 CHAIR CHAPMAN: Thank you. Any

2 questions? Harriet, Steve, Asa, Lisa.

3 MS. BEHAR: Good morning. We talked

4 yesterday, and I am not a scientist, but I think

5 I understand something. I just want you to verify

6 it, and maybe I'll try to clarify things a little

7 bit for the rest of the board too, if what I am

8 understanding is correct.

9 Is that the source of it is petroleum,

10 but in the laboratory, you fractionate that

11 petroleum and produce a molecule that is something

12 that microbes can recognize as food in the soil.

13 MS. SCHLEGEL: Yes.

14 MS. BEHAR: So this is correct, okay.

15 MS. SCHLEGEL: Yes.

16 MS. BEHAR: So actually, the point that

17 you're trying to make here, that it's the

18 biodegradability that we should be looking at on

19 this mulch, and that the amount of the biobased is

20 actually not important. That actually even some

21 things that are biobased are not as biodegradable

22 as the product that you are trying to sell.
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1 So I think that part of the issue for

2 the board to think about is how they feel about a

3 material whose mother source is petroleum, how

4 they feel about that biodegrading in the soil. So

5 that's where I think we need to be thinking.

6 I like that Dave is shaking his head,

7 because he's a weed guy. And so I think that

8 maybe that's going to help us understand a little

9 bit where some of our questions are. And so

10 that's what I'm now struggling with.

11 MS. SCHLEGEL: Should I comment? Yes,

12 I totally agree to you. So what is important for

13 these products is that in the end, the natural

14 microorganisms in the soil can degrade it. So it

15 must be make sure that these organisms cut it

16 down, that no other factors do it, but only the

17 soil biology can do it.

18 And that soil organisms take it up and

19 then convert it to CO2 and biomass. This is an

20 important point, that you do not harm the

21 organisms present in the soil, that they are

22 actively taking part, you actually feed them. And
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1 that you do not have any ecotoxicological issues

2 for them during the degradation process.

3 So there are some guidelines on the

4 standards, and also which you had for the last

5 time, and they really make sure that you test on

6 these factors and the source of the material. So

7 if something is originally fossil-based, like you

8 said, it's completely converted into some small

9 pieces.

10 Chemically and biologically, it has

11 nothing to do with the petroleum anymore, it's

12 just where the carbon comes from. It needs to be

13 broken down and then used in fractions that

14 organisms can use. And this is the important

15 point.

16 CHAIR CHAPMAN: Thank you. Steve.

17 MR. ELA: So one of the concerns we had

18 in looking at our technical reports and things is

19 that in different soils and different climatic

20 conditions, which, of course, all organic farms

21 represent a huge spectrum of, is whether in some

22 cases, whether these actually aren't breaking down
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1 in some situations.

2 So how could you guarantee to us that

3 there's going to be 100% breakdown into that

4 carbon dioxide and biomass in all organic

5 situations? Because I think that's a, we don't

6 want petroleum products and plastic pieces out in

7 our fields.

8 And so we need to make extra sure that

9 that is a complete breakdown in all environments. 

10 Could you comment on that?

11 MS. SCHLEGEL: Of course. I mean, it's

12 a biological process, it's biodegradation. It's

13 completely natural process. And we all know that

14 the conditions out there in the world are

15 different in different places. 

16 Biodegradable polymers is a technology

17 like any other technology, and of course there is

18 important that the farmers test this technology

19 for their fields. I mean, if you would have a

20 biodegradable polymer in a desert, for example, I

21 think it will take longer than if you have it in

22 an agricultural field.
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1 I can never like for any technology

2 give a 100% guarantee on something. I tested in

3 my lab round about 20 different soils and isolated

4 polymer-degrading organisms in a field culture and

5 looked down for polymer degradation. Every soil

6 I tested so far was active.

7 So every soil had degrading organisms. 

8 But of course, I cannot give 100% guarantee, like

9 for any other technology.

10 CHAIR CHAPMAN: Thank you. Lisa then

11 Asa.

12 MS. De LIMA: That kind of addressed

13 the same question I was going to ask about the

14 studies, that you saw no negative effects. But

15 how long did you test for, and like how much was

16 the load that you were using? Did you feel like

17 that really was going to truly mimic an organic

18 farm?

19 MS. SCHLEGEL: So we calculated that

20 the load that we would expect would be 0.06% in

21 the soil. We usually take 1.0% inside our

22 testing. Because we wanted to make sure that it's
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1 not accumulation of anything. So if you're having

2 a one-year test, for example, we really for our

3 testing increased the concentration to see a worst

4 case.

5 But we are way higher, like 160-fold

6 higher than anything we would expect in nature. 

7 And something I forgot to add for the first

8 question, so these products have been used for 15

9 years, and so far we never had a negative

10 feedback. We never had any residue formation or

11 anything that was accounted on.

12 I think it's important to keep on

13 research on that, because we did not sample the

14 whole world. I mean, it's not possible. So what

15 we are doing, we're going out there, we do

16 sampling, we do lab tests with increased

17 concentrations.

18 We make ecotox tests with partially

19 degraded films to see if anything during the

20 degradation process is happening. And yeah, we

21 did not see negative effects.

22 CHAIR CHAPMAN: Thank you, I'm going to
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1 stop you there. Asa, do you have a question?

2 MR. BRADMAN: I have a couple of

3 questions. One, how do you do the degradation

4 tests, and what do you test for? And you

5 mentioned that the outcome is CO2, H2O, and

6 biomass. Can you be more specific on what that

7 biomass is?

8 MS. SCHLEGEL: That biomass is

9 something that we are also currently doing

10 research on, together also with external partners. 

11 We see that the organisms take up the food that we

12 offer them as a polymer. So they take up the

13 carbon.

14 We do that with the 13C stable carbon

15 labeled tracer, and we see they take it up and

16 they grow. So they have it inside the cell walls,

17 they have it inside their DNA. This is the

18 biomass, so they multiply on it, they grow on it. 

19 And this is what we call biomass.

20 MR. BRADMAN: Okay, and within that

21 biomass, are there any other degradation products

22 that you're aware of?
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1 MS. SCHLEGEL: We never found any. So

2 we only found so far like natural occurring amino

3 acids, proteins, fats, this kind of thing.

4 MR. BRADMAN: And when you do these

5 tests, are you doing them on fields and collecting

6 soil samples? Or are you using small chambers or

7 greenhouses, or other more controlled

8 environments?

9 MS. SCHLEGEL: We have different kind

10 of tests. For the CO2 measurement that we are

11 doing, for the mineralization, to follow that up,

12 we have to do lab tests, because we cannot do that

13 in the field. It's simply not possible. So if we

14 test mineralization or label carbon experiments,

15 we do that inside a lab.

16 But we also have field experiments

17 where we follow up how it's degrading. We talk to

18 customers and see that we can sample soils from

19 the fields. So it's a mixture depending on the

20 question, because we cannot, yeah, give answers to

21 all questions just using one test system.

22 MR. BRADMAN: Sure, but if you collect
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1 samples from the field, for example, if it's been

2 disked in or something, you may be diluting any

3 materials through kind of a large volume of soil

4 in the upper layers. So have you done any

5 laboratory tests, chamber tests where you've tried

6 to degrade it?

7 MS. SCHLEGEL: Yes, lots of them.

8 MR. BRADMAN: And then analyze the

9 soil, say in a smaller volume from a laboratory

10 chamber?

11 MS. SCHLEGEL: Yeah, we do that as

12 well. I hope that within the next two months, we

13 can publish the method how we do that.

14 We developed together with the ETH

15 Zurich extraction method, so everybody can use

16 that method as well, how to optimize extraction

17 from soils to see if we have residues. So what's

18 happening between and all of that.

19 MR. BRADMAN: Okay, two last questions,

20 and then I'll stop. What percentage of the

21 material is petroleum-based versus bio-based? And

22 is it possible to make 100% bio-based film that
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1 would also be fully biodegradable?

2 MS. SCHLEGEL: For biodegradable mulch,

3 it depends on what kind of product you have in the

4 biobased content. Because you have different

5 properties from the different polymers we used in

6 that mixture.

7 And therefore, you can have like

8 something between 10-20% of biobased. But there

9 are different products on the market on that, and

10 they have different properties.

11 What was the second part again? Would

12 it be possible? So in my opinion, it would be

13 very, very difficult. Like I said, all these

14 polymers that we have as biodegradable versions

15 have different properties.

16 So if you want to make a film out of

17 it, if you have like a biobased pile, it's a very

18 tough and strong and rough material. So making a

19 film that's elastic that you can lay it on the

20 ground would be very, very difficult. So

21 therefore, we have this mixture to have it more

22 elastic. 
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1 And this is the problem with having

2 100% biobased. I don't think you can make a

3 material that's cost-effective and working on the

4 field.

5 CHAIR CHAPMAN: Thank you very much. 

6 We're going to have to move on now, but appreciate

7 your testimony. We don't have time, I'm sorry.

8 MS. SCHLEGEL: I'll be here all day,

9 and we can also offer, if we want to have like a

10 joint webinar for everybody --

11 CHAIR CHAPMAN: Thank you very much.

12 MS. SCHLEGEL: It's possible.

13 CHAIR CHAPMAN: So up next, we have

14 Margaret Scoles, followed by Melody Meyer. 

15 Melody's on deck. Margaret, can you start with

16 your name and affiliation for the record.

17 MS. SCOLES: Margaret Scoles, the

18 International Organic Inspectors Association. 

19 Thank you to the board for your good work,

20 especially for tackling some of the difficult

21 issues at the heart of organic, such as seed

22 purity and disincentivizing the conversion of
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1 native ecosystems to organic. And thank you for

2 listening to our many comments.

3 I will comment on the CAC

4 Subcommittee's proposal on personal performance

5 evaluation of inspectors. IOIA delivers training

6 around the world to inspectors and others, and we

7 support inspectors. We do that by working closely

8 with certifiers.

9 Certifiers have supported IOIA's

10 training programs for more than 20 years, and more

11 recently, our peer field evaluation program. 

12 We've commented in writing, I will not repeat

13 those here. We did ask that you reconsider your

14 differentiation of certifier staff versus contract

15 evaluators.

16 The most important criterion for

17 evaluators is not whether they're employees or

18 contractors. More important is that they must be

19 trained and experienced as inspectors. If the

20 surgeon operating on me is being evaluated, I

21 would hope that they would be evaluated by another

22 experienced surgeon.
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1 We have and will continue to support a

2 risk-based approach to evaluating inspectors that

3 could include credentialing through IOIA's

4 inspector accreditation program, as was suggested

5 by the NOSB in 2011. The most recent, third

6 version of NOP 2027 sufficiently addressed the

7 major concerns voiced by certifiers, as well as by

8 this proposal.

9 I doubt anyone here believes that

10 anything we say is likely to engender yet a fourth

11 version. I want to say two things for the board

12 and the NOP to consider. We've diverted a lot of

13 energy over the past few years resisting

14 evaluations and implementing systems to get them

15 done. It's time to refocus on consistent

16 inspector qualifications and training.

17 So my two things, one, it has not been

18 said enough how good 2027 has been for all of us. 

19 Field evaluations have provided valuable

20 information that has informed both the certifiers'

21 in-house training programs and IOIA's training

22 program. Good for NOP for not backing off on the
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1 requirement for field evaluation.

2 And second, over the past few days here

3 it's been challenging to stay positive in the face

4 of so much uncertainty. IOIA's request is that we

5 look at what we can do about inspection quality

6 without rule changes or revising the program

7 handbook. We just want your encouragement.

8 The NOSB to encourage the NOP, and the

9 NOP to work with the organic community. That

10 includes ACA, and IOIA, and the NOP, to move

11 forward on raising the bar for inspections and

12 inspector quality and achieving greater

13 consistency.

14 I have no desire to see us follow

15 Germany, where the government approves every

16 inspector for every certifier. The NOP contracted

17 -- 

18 CHAIR CHAPMAN: Thank you very much. 

19 Questions for Margaret? Scott.

20 MR. RICE: Thanks, Margaret. I wanted

21 to clarify part of that proposal that we put

22 forward that, I think there was some confusion on
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1 the language around who was evaluating whom. And

2 I think the intent, and obviously it wasn't clear

3 enough, was that there be a distinction between an

4 evaluation and an audit.

5 And we did not want to see peers put

6 into a position of evaluating their fellow peer,

7 and instead have that role be done by the

8 certifier, who is the employer or director of

9 work. So we're trying to, it's a little bit

10 nuanced and we were trying to make that

11 distinction.

12 It wasn't a slight or a thinking less

13 of the inspector-on-inspector audit process. I

14 think there is definitely a place for that. But

15 I wanted to try and clarify that a little bit.

16 MS. SCOLES: Can I respond to that? 

17 CHAIR CHAPMAN: Yeah.

18 MS. SCOLES: Yes, it was unclear. And

19 we all, we completely agree that evaluation of

20 inspectors is the responsibility of the certifier. 

21 And the field evaluation part is just one part of

22 that. And that's why in our program, we clearly
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1 are not evaluating inspectors. We're doing that

2 part, the field evaluation part. Thank you.

3 MR. RICE: Yeah, and one other --

4 CHAIR CHAPMAN: Briefly.

5 MR. RICE: I agree that, I think we'll

6 be shifting the focus to really focus on the

7 inspector qualification and training. And I think

8 it's good to move on from the every year, every

9 inspector issue that we have had. Thanks.

10 CHAIR CHAPMAN: Harriet. 

11 MS. BEHAR: Hi, Margaret. In my

12 experience, I became a much better inspector after

13 I also was a reviewer. 

14 And I'm wondering, in your inspector

15 trainings, as you're working to improvement, if

16 you're looking at including a module on putting

17 the inspectors on the other side so they really

18 understand what needs to be read by a reviewer, so

19 their reports and their inspection really cover

20 what's necessary.

21 MS. SCOLES: I totally agree, and I

22 think I became a lot better inspector after I was
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1 a reviewer as well. And we are talking with the

2 ACA about how to better train inspectors and how

3 to train reviewers both.

4 And one of the things that I didn't get

5 to say is that in 2011, the NOP contracted with

6 IOIA to propose qualifications and training

7 content, and the concept of operations for

8 training and licensing both inspectors and

9 reviewers. And we feel like the whole reviewer

10 part has been languishing and not addressed well

11 enough. Thank you.

12 CHAIR CHAPMAN: Thank you very much,

13 Margaret. Up next, we have Melody Meyer, followed

14 by Ulrike Hodges from SafeTraces. Sorry if I

15 butchered your name. Melody, if you can start

16 with your name and affiliation for the record.

17 MS. MEYER: Yes, thank you. I'm Melody

18 Meyer, VP of Policy at UNFI, and also the

19 executive director of the UNFI Foundation. UNFI

20 has 40 years' experience distributing organic

21 food. We're the largest distributor of organic

22 food in North America. We care deeply about
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1 organic.

2 I want to welcome the new members and

3 ask you to take your time and consider all the

4 views as you learn about these important issues. 

5 And I really want to thank the whole board for

6 your extensive work, tireless hours, and

7 commitment.

8 As Tom mentioned yesterday, we all care

9 deeply about organic. That's why we're all here. 

10 The deliberations of this committee represent

11 everyone who cares: growers, handlers,

12 manufacturers, and consumers. All actors are

13 integral to your discussions. 

14 I heard testimony yesterday on the

15 values of organic, the movement that birthed this

16 amazing industry. Those values, the movement, is

17 also represented through the trade. It is not a

18 separate philosophical entity. Indeed, the trade

19 makes the movement possible.

20 It's the dollars and cents, the

21 economic growth that organic represents for

22 producers, manufacturers, and retailers. For
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1 consumers, it's the option to have an informed

2 choice through the USDA label. Expanding and

3 preserving that choice helps consumers avoid

4 persistent pesticide exposure.

5 Limiting organic because of ideologies

6 does not serve anyone, not even the self7 proclaimed movement. With that, I ask, Is the

8 outermost crust of the earth the only place

9 organic production can make a difference?

10 Organic regulations must continue to

11 allow growers the flexibility to meet their site12 specific requirements. To face our challenges,

13 those ever-evolving challenges in farming, and

14 with respect to the limited resources with water,

15 land, labor, and natural resources, these are more

16 severe than ever.

17 You must fairly evaluate how container18 growing methods can help meet the challenges of

19 sustainability, while fulfilling the legitimate

20 and original intent of your organic movement to

21 use biology to cycle natural inputs while avoiding

22 prohibited substances.
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1 These methods present a sustainable way

2 to produce food, especially in urban areas, or

3 where access to land and water is a barrier. 

4 Feeding more people and future generations with

5 organic food must be our goal.

6 In addition, organic farmers deserve

7 the choice of using biodegradable mulch film. 

8 Please do not hesitate to make those choices to

9 make this tool available as soon as possible. 

10 In conclusion, I urge the NOSB to adopt

11 balance and moderation, aiming for continuous

12 improvement in the production of the world's gold

13 standard for producing food and fiber. The

14 benefits and challenges of organic production must

15 be weighed as we grow U.S. organic agriculture.

16 Let's be accessible to creativity. 

17 Let's not reject progress for attaining

18 perfection. We need to allow for the most

19 progressive and positive tools for organic

20 farmers. We must grow organic to be more than two

21 percent of U.S. organic agriculture. Thank you.

22 CHAIR CHAPMAN: Thank you. Any
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1 questions for Melody?

2 MS. MEYER: And I submitted detailed

3 comments on a lot of things earlier, so you have

4 that in writing.

5 CHAIR CHAPMAN: Thank you very much for

6 your testimony.

7 MS. MEYER: Thank you.

8 CHAIR CHAPMAN: Up next, we have

9 Ulrike, sorry again. You'll have a chance in a

10 moment to correct the name. And then up on deck

11 is Marianne Cufone. If you can start with your

12 name and affiliation for the record.

13 MS. HODGES: My name is Ulrike Hodges,

14 I'm from SafeTraces. Coming. Thank you very much

15 for giving me the opportunity to address you this

16 morning. I would like to present our comments on

17 your recommendation on short tracers, Short DNA

18 Tracers. I'll wait a second.

19 There we go. Short DNA Tracers are

20 what we're petition for to be included. 

21 SafeTraces, our company, is developing food source

22 assurance solutions. For source verification and
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1 traceability, and also for adulteration detection.

2 Our company was founded on the belief

3 that food safety must be improved for organic and

4 conventional foods. We are faced with increasing

5 recalls that undermine the integrity of food

6 labels and threaten the livelihood of farmers.

7 Regulators and consumers are asking for

8 more transparency. And in response, our company

9 uses molecular biology to ensure the integrity of

10 organic food labels, and to help make organic

11 foods safer.

12 This is also a very personal issue for

13 me. I've been lucky to live 25 years in Berkeley,

14 California and enjoy local and organic food. But

15 I do worry about the safety of the food chain and

16 the supply, and the integrity of the labels going

17 forward.

18 What are Short DNA Tracers? They are

19 safe, edible, invisible, flavorless, DNA-based

20 markers. They provide item-level assurance for

21 source verification, purity, authenticity. They

22 are applied to food in parts per billion. That's
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1 about a drop per Olympic-sized swimming pool.

2 They're recognized by the FDA as grass. 

3 They are non-viable, non-living. It's about 100

4 base pair of DNA from any living thing that can be

5 used to produce this marker. There is absolutely

6 no modification of genetic material for use in the

7 organic foods, and there's no insertion into the

8 food's genome.

9 Tracing food back to its source is

10 time-critical. Existing methods are insufficient,

11 they lack completeness in many cases. Between

12 1992 and 2014, for example, there were 18

13 outbreaks caused by organic food products. The

14 organic sprout contamination in Germany many years

15 ago caused 53 deaths and cost the EU organic food

16 industry over $2.8 billion.

17 Short DNA Tracers enable us to identify

18 the source of contaminated food in just a few

19 minutes. It's a fast, safe, accurate, cost20 effective method that protects consumers and

21 growers. Tracing food back to its source helps

22 prevent fraud.
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1 There's increased globalization that

2 threatens the integrity of the food supply. The

3 EU deems some country high risk, the USDA cited

4 the Istanbul port. The NOP receives hundreds of

5 complaints annually. Again, Short DNA Tracers are

6 able to protect consumers and growers and conserve

7 regulatory resources.

8 We urge you to consider that integrity

9 is essential to the organic food industry. We

10 appreciate the opportunity to address you today. 

11 The growing challenges that we face with regard to

12 the organic food safety, we have the facts

13 relating and the benefits, so please give us some

14 time and postpone your decision. Thank you.

15 CHAIR CHAPMAN: Thank you.

16 MS. HODGES: Any questions?

17 CHAIR CHAPMAN: Questions? Lisa and

18 then Harriet and then Dan.

19 MS. De LIMA: This is more of a

20 comment, and if you have anything in response. 

21 Under our current definition of modern biotech, we

22 define it as the application of in vitro nucleic
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1 acid technologies. 

2 And so it's my understanding that you

3 guys use PCR to create the large number of the

4 copies of the DNA. And that would fall within our

5 definition of an excluded method.

6 MS. HODGES: Right, and that's where

7 the discussion can continue, I think. I am not

8 the scientist, I'm not the biologist. But the

9 only thing we do is we amplify, and the reason we

10 amplify is that we want to use just a few base

11 pair.

12 Because economically, using more base

13 pair would not make any sense. So it's about the

14 amplification, it's not about multiplication or

15 insertion into the food's genome. So, but we do

16 use the PCR method for that process, that is

17 correct.

18 MS. De LIMA: Right, and that would

19 fall within our excluded method terms.

20 MS. HODGES: And that's where we would

21 like to present more evidence on why we consider

22 this should be included.
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1 CHAIR CHAPMAN: Up next, Harriet and

2 then Dan.

3 MS. BEHAR: How does the end user

4 verify, you know, that this is present in the

5 product if you're, you know, as a tracer?

6 MS. HODGES: It is not something where

7 in the near future you're going to wave your phone

8 over it and see where it's from. This is not what

9 we set out to do. We set out to provide a very

10 fast verification method in case there is any

11 question about the integrity.

12 So this is for any large retailer, it's

13 for a processor, it's for a regulator. The

14 process takes about 15 minutes, and it's a swab of

15 the food, in most cases. And it uses off-the16 shelf equipment, so it's not like a big,

17 complicated process that requires any skills.

18 CHAIR CHAPMAN: So I have Dan, then

19 Sue, and we're going to stop it there for the sake

20 of time. Dan.

21 DR. SEITZ: It seems to me that if you

22 were to use this to detect fraud in terms of
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1 imported grain or whatever, that you'd have to

2 require every producer to use your technology. 

3 Otherwise, you'd have some using other, the paper4 based approach and others using that. Is that, I

5 mean, is that a correct assumption, that if you

6 were to use it for that --

7 MS. HODGES: It is a correct

8 assumption. You don't have to go all the way back

9 to the producer or the grower even. You can

10 decide at some point during the food chain you

11 want to assign the chain of custody. So you can

12 say upon import, you verify the paperwork, you

13 say, It's fine from here on out. It gets applied.

14 Or you work with your foreign partners

15 and want to assure that your vanilla bean is

16 really from Madagascar and your organic oil is

17 really from Italy.

18 CHAIR CHAPMAN: Sue.

19 MS. BAIRD: Thank you. You did answer

20 a little bit. So this is not something that

21 they're going to insert the DNA splicing tracer

22 into the food that is then going to be consumed.
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1 This is a test that you're planning on

2 being used by a retailer or a grain elevator or

3 something at that level, just for a test to be

4 sampled. Or am I misunderstanding?

5 MS. HODGES: The tracer is applied to

6 the food.

7 MS. BAIRD: So it does remain in the

8 food.

9 MS. HODGES: Yes, it does remain in the

10 food. It gets removed from the food the same way

11 that if you wash an apple, if it's applied to the

12 wax, the wax comes off. If you cook your food,

13 after a while, of course, because it's a fraction

14 of DNA, it'll disappear.

15 But it is DNA. I mean, it is

16 comparatively so little DNA. You have much more

17 in your food just by --

18 MS. BAIRD: Right, but this would be

19 applied to a sample for a testing. It's not

20 applied to the whole food chain.

21 MS. HODGES: It is applied to all the

22 food, yes.
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1 MS. BAIRD: Oh, it is all food. Thank

2 you.

3 CHAIR CHAPMAN: Thank you very much for

4 your testimony.

5 MS. HODGES: Sure, thanks very much.

6 CHAIR CHAPMAN: Up next, I have

7 Alexander Bollag and on deck is Alexis Randolph. 

8 Alexander, if you could start with your name and

9 affiliation for the record.

10 MR. BOLLAG: Good morning. Yes, I'm

11 obviously not Marianne Cufone. My name is

12 Alexander Bollag, I'm with the Recirculating Farms

13 Coalition, representing them on USDA organic

14 certification of hydroponic and aquaponic farms.

15 Currently, hydroponic and aquaponic

16 farms are certified as USDA organic, and they

17 should remain so. These farms, like in-ground and

18 raised bed growing, can meet organic standards. 

19 We, too, feed the soil, not the plants, by adding

20 amendments. Soil is about the biology of the

21 system creating nutrients for the plants.

22 The main difference in these versus
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1 traditional in-ground or raised bed farms is the

2 medium holding the plants. Some have dirt and

3 others rocks or other media. Hydroponic and

4 aquaponic farms, depending on the design, are

5 essentially container growing.

6 Our executive director, Marianne

7 Cufone, was on the NOP's Hydroponic and Aquaponics

8 Task Force. The discussions were contentious

9 during these meetings. She believes there was a

10 lot of misinformation about how hydroponic and

11 aquaponic farms function.

12 And we're worried that this could

13 result in the NOSB making a bad recommendation for

14 hydroponic and aquaponic farms that meet organic

15 standards to lose the USDA organic label. That

16 would send a terrible message to both farmers and

17 consumers.

18 USDA regularly says it wants to

19 encourage new farmers and engage more young people

20 in growing. Hydroponics and aquaponics do both. 

21 Though these techniques are centuries old, like

22 the hanging gardens of Babylon and Chiapas in
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1 Mexico, there are new twists making them exciting

2 and innovative.

3 We should be encouraging farmers to use

4 resource-smart techniques and invest the time and

5 money it takes to be USDA organic, not discourage

6 them by taking away the possibility of

7 certification. For consumers, seeing products

8 once labeled USDA organic but no longer carrying

9 the label means they were duped, that the farms

10 and products they bought shouldn't have the USDA

11 organic label.

12 This is a dangerous precedent. It

13 risks the entire integrity of the organic label. 

14 These products have not changed. It's just that

15 politics are shifting, and that's not a good

16 reason to pull organic certification from

17 deserving products and farms.

18 The concept of organic is both about

19 known inputs and consistent outputs. And we agree

20 it is about not harming but improving our

21 environment. Years ago, this was primarily about

22 soil, meaning earth. But today it should be more.
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1 Many hydroponic and aquaponic farms

2 improve our environment, by using less water, less

3 space, running on alternate energy, recycling and

4 reusing waste, and being located right in the

5 communities where food is used, thus cutting down

6 on fossil fuels for shipping and refrigeration. 

7 All of this contributes to a healthier planet.

8 Nowhere in any law or regulation does

9 it explicitly say organics require soil. It says

10 that organics should improve or not harm soil. 

11 Certainly, hydroponic and aquaponic farms easily

12 fit this.

13 Hydroponics and aquaponics as styles of

14 commercial growing weren't contemplated when the

15 law for organics was written. But that doesn't

16 mean they should be excluded now based on an

17 outdated rather than an inclusive interpretation

18 of the law. 

19 We urge you to take the time to learn

20 more about these growing methods before excluding

21 them all from USDA organic certification.

22 A separate but supposedly equal type
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1 label isn't a good approach. There is only one

2 USDA organic. Labeling products as anything else

3 is a waste of time and resources. USDA organic is

4 an important label to consumers. And hydroponic

5 and aquaponic farmers want to be a part of that,

6 not some separate, lesser label as a consolation

7 for losing USDA organic certification.

8 It's unlikely that hydroponic and

9 aquaponic farms will spend time and money on an

10 alternate certification, and they shouldn't have

11 to. Hydroponic and aquaponic farms, if they meet

12 USDA organic standards, should remain eligible for

13 USDA organic certification.

14 Thank you for your time, I'd be happy

15 to take any questions or comments back to

16 Marianne.

17 CHAIR CHAPMAN: Questions? Harriet.

18 MS. BEHAR: Based on the feeling, I

19 believe that you're saying is that hydroponic is,

20 you know, very sustainable. Do you see a time

21 when most, or do you believe that most organic

22 produce should be grown hydroponically for its
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1 sustainable nature?

2 MR. BOLLAG: So I think I'll let

3 Marianne answer that officially on behalf on of

4 the organization. But I don't think that that's

5 our, I mean, there's an opportunity for a lot of

6 different methods of growing. I think this is

7 just one more method of growing that should be

8 encouraged.

9 CHAIR CHAPMAN: Thank you very much. 

10 Up next is Alexis Randolph, followed by Bill Wolf. 

11 Alexis, if you start with your name and

12 affiliation for the record.

13 MS. RANDOLPH: Yes, good morning, my

14 name is Alexis Randolph. I'm from Quality

15 Assurance International. We're an organic

16 certification agency.

17 QAI appreciates the research conducted

18 by the Crops and Handling Subcommittee regarding

19 marine algae-derived materials. However, by

20 annotating all materials with the Latin binomials,

21 the expectation would be for certified operators

22 to obtain information on the species sourced to
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1 produce each material.

2 In many cases, this would be a

3 substantial amount of additional work, since the

4 harvested material is several steps back in the

5 supply chain. I've reviewed specification sheets

6 QAI has on file for several of these materials,

7 and most do not specify the class or species of

8 the marine algae.

9 It would be preferential to annotate

10 the algae materials only if the NOSB has found a

11 reason to restrict or exclude species from use.

12 Regarding tocopherols, the update to

13 annotation removing the rosemary oil reference and

14 requiring they are derived from plant oil is

15 supported, as it will not have any adverse impact

16 on products QAI has previously approved.

17 We also appreciate the motivation for

18 adding commercial availability requirements to

19 tocopherols and other materials on 205.605. When

20 this is done, however, it increases the workload

21 and paperwork for certified operators.

22 This is particularly troublesome when
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1 it's already known that an organic alternative is

2 not yet commercially available. In lieu of taking

3 this approach one material at a time, I'd like to

4 challenge the NOSB and the USDA to create another

5 mechanism for incentivizing development of non6 synthetic and organic alternatives.

7 Perhaps this could be done through

8 outreach, research programs, or grants. Organic

9 operators are already burdened by enormous amounts

10 of additional work and documentation. Let's find

11 another way to force the development of

12 alternative materials.

13 And this relates to the concept of

14 continuous improvement, which is a foundational

15 value of the organic industry. It is relevant to

16 the organic seed proposal, native ecosystem

17 discussion, and many other areas of the

18 regulation.

19 Again, instead of tackling this issue

20 one section of the regulation at a time, there is

21 an often overlooked section, 205.200 which may be

22 useful.
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1 It says, Production practices must

2 maintain or improve the natural resources of the

3 operation, including soil and water quality. To

4 codify the industry values of continuous

5 improvement, the NOSB could propose a rule change

6 for 205.200 that removes the word maintain and

7 expands the intent for improvement to all areas of

8 the organic system plan.

9 And finally, I need to clarify our

10 webinar comment regarding sodium phosphate. It

11 was listed for use in non-milk products,

12 parentheses fortification. Sodium phosphate is

13 not used for fortification. It was meant to be

14 listed as non-milk products fortified. Thank you.

15 CHAIR CHAPMAN: Thank you. Questions

16 for Alexis. Francis.

17 DR. THICKE: Thank you. Can you tell

18 us how many hydroponic operations QAI certifies?

19 MS. RANDOLPH: I actually can't tell

20 you off the top of my head. I know that we do

21 certify some.

22 DR. THICKE: Can you give us any
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1 ballpark?

2 MS. RANDOLPH: Five maybe.

3 CHAIR CHAPMAN: Steve.

4 MR. ELA: I'm just curious, with the

5 marine algae listing, I obviously hear your

6 comments about, you know, trying to break things

7 down. But if we have concerns about the

8 sustainability of wild harvesting of these kelps

9 and things, how would you propose we deal with

10 that?

11 MS. RANDOLPH: Well, I think we've done

12 an excellent amount of research. And you know, I

13 do support annotating materials on the national

14 list if you have concerns, if you want to prohibit

15 a species from use.

16 But, you know, certifiers go back to

17 the technical reviews, we go back to all of your

18 comments and your deliberations when you put out

19 these proposals for the meeting, and we look for

20 these issues as you've identified. So that when

21 we're reviewing a material, we want to make sure

22 that we're reviewing it for the same use and from
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1 the same perspective as you have also reviewed the

2 material.

3 So again, if you have those concerns,

4 I'd go ahead and leave them noted in your -- well,

5 if you're concerned, annotate them. But if you

6 just want us to know what species are commonly

7 used, then go ahead and leave those in your

8 committee comments and in the TRs. We'll find

9 them, we always do.

10 CHAIR CHAPMAN: Thank you for your

11 testimony.

12 MS. RANDOLPH: Thank you.

13 CHAIR CHAPMAN: Up next is Bill Wolf,

14 followed by Bill Broydrick. Bill, can you start

15 with your name and affiliation for the record.

16 MR. WOLF: Hi, I'm Bill Wolf with Wolf,

17 DiMatteo and Associates. 

18 Our firm works with growers, companies,

19 NGOs, and governments to grow organic. And I want

20 to thank all of you for your hard work and welcome

21 the five new members. Especially, thanks for

22 volunteering your precious time.
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1 We've submitted a range of comments

2 intended to improve the organic standards. Some

3 of them are listed on this slide. They were

4 numerous pages, I won't go into the details. I'd

5 like to get to some other topics as well.

6 We've also made several comments in the

7 past that we included in this year's comments, but

8 I'd like to highlight two notable comments that

9 would have a larger effect on the national list.

10 One of them is requiring organic when

11 available be applied to the entire national list. 

12 And two is not making the regulations and

13 annotations too prescriptive. Sometimes we have

14 a unintended consequences for extensive,

15 prescriptive in the regulations rather than in

16 guidance.

17 I'd like to actually talk about two

18 things. One, I have a passion for soils and

19 earthworms, and our comments are rooted in the

20 philosophy of continuous improvement, that organic

21 is striving to use the gentlest methods and tools

22 to produce better food and fiber for people and
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1 animals.

2 And one of the principles behind

3 decisions about organic regulations for decades,

4 for decades, has been to think about the

5 biological system. So what is okay in organic? 

6 I'd like to introduce the principle of thinking

7 like an earthworm. Visioning what products and

8 practices promote our biotic living systems, that

9 can help sort out what materials are okay.

10 The list criteria attempts to quantify

11 this principle, but was not intended to overly

12 restrict the toolbox of organic producers and

13 handlers. We need choices, not just one solution

14 for a problem. Don't make shrinking the national

15 list toolbox a goal. Be open to innovation and

16 creativity that fits the organic philosophy.

17 The precautionary principle actually

18 cuts both ways. We shouldn't be doing something

19 that would have unforeseen consequences in the

20 future. Will your vote help increase organic

21 acreage and earthworms?

22 Finally, I have another passion, and
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1 that's seaweed.

2 CHAIR CHAPMAN: Thank you, Bill. Any

3 questions for Bill? Harriet.

4 MS. BEHAR: Do you feel that, well,

5 maybe you could answer this question: Are there

6 sustainable harvest standards out there, so that

7 if we wanted to look at applying those to input

8 harvest, could that happen for like kelp and maybe

9 fish, whatever?

10 Because right now, we have that

11 sustainable harvest standard as part of our food,

12 when kelp is a food that has to, and it's a wild

13 harvested crop, and it has to follow our wild

14 harvest standard. But that's not covered when

15 it's harvested for an input in organic production.

16 MR. WOLF: So, I mean, there are

17 numerous standards out there in marine systems. 

18 I'm not an expert on fishery standards, but there

19 are a number of fishery management systems that

20 could be applied to even the harvesting of

21 products for use in fish emulsion.

22 And it's possible, once we have a fish
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1 standard, that we could be, if that continuous

2 improvement principle were applied to the national

3 list when there were organic fish emulsions,

4 derivatives from certified organic fish, that

5 would be needed to be used like in the Canadian

6 standard. That would be a huge step.

7 But the Canadian standard, for example,

8 requires that inputs be from organic sources once

9 they become available. Even manure, that's how

10 that standard was written.

11 Getting to marine algae, first of all,

12 marine algae aren't plants. And yet on the

13 national list, we say, we use the word plants in

14 601. So if we were going to start correcting

15 nomenclature, I would start there.

16 But the thing about sustainability of

17 sea marine algae should be addressed, and it

18 should be carefully thought through how to do

19 that. One of them is that continuous improvement

20 principle of requiring certified organic when

21 available. 

22 And that would push the envelope for
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1 inspection. There are standards around the world,

2 and they're evolving fairly quickly in terms of

3 how seaweeds are harvested. And those are mainly

4 being driven by countries and states.

5 Your TR discussed some of those

6 standards. 

7 CHAIR CHAPMAN: Thank you, Bill, I'm

8 going to have to stop you there.

9 MR. WOLF: Okay.

10 CHAIR CHAPMAN: Any other questions for

11 Bill? Asa.

12 MR. BRADMAN: Quick question here. In

13 your comments, you mentioned retaining humic acid,

14 briefly, and I have a question. You just raised

15 the issue of annotation versus guidance. 

16 There's been some public comments that

17 are concerned about the use of coal as a

18 manufacturing source for humic acid, and a

19 preference for natural sources, or at least non20 fossil fuel sources. And I'm just curious if you

21 have an opinion there about guidance versus

22 annotation.
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1 MR. WOLF: I'm not a humic acid expert. 

2 I've seen and used the materials. I think it's a

3 tool that a lot of farmers are currently using. 

4 And this comes back to the issue of the toolbox

5 and removing materials before we fully understand

6 and figure out how we can make them give that

7 farmer another alternative is premature.

8 At the same time, it's worth looking at

9 the sustainability of the incoming materials. But

10 those criteria were not intended to be absolutes. 

11 It is agriculture, it does impact our ecosystem.

12 CHAIR CHAPMAN: Thank you for your

13 testimony, Bill. Up next, I have Bill again,

14 followed by Julie Weisman. Bill, if you can start

15 with your name and affiliation for the record.

16 MR. BROYDRICK: Sure, it's Bill

17 Broydrick, and I'm here on behalf of Hortifruit. 

18 As I say, my name is Bill Broydrick and I'm here

19 on behalf of Hortifruit, who is a partner with

20 Munger Farms. 

21 Hortifruit's mission is to be the

22 world's leader in blueberries. In our joint
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1 venture with Munger, we work together under the

2 Naturipe label, offering organic berries year

3 round in the United States.

4 Hortifruit has been growing organic in

5 Chile for 20 years, to provide healthier foods for

6 our families, to grow without chemical and

7 synthetic fertilizers, to offer workers and

8 communities safer and more natural environments. 

9 Hortifruit, we support the continued work of NSOB

10 and are hopeful that the issue of container growth

11 can be resolved.

12 Yesterday, there was a great deal of

13 discussion about recalcitrants within the systems

14 that exist. And I consulted with our agronomist,

15 and he tells me that the inputs that we would be

16 use in the soil are not terribly different than

17 the inputs we would be using in a container

18 medium.

19 And so we believe that there's a great

20 similarity between the two. We would like to see

21 the committee consider separating the concept of

22 hydroponics and container growing.
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1 The traditional methodology of

2 hydroponics was the use of water. And we would

3 recommend to you that the definition that's used

4 be truncated from the recommendation to just

5 discuss in effect liquid mediums. 

6 That mediums that are recalcitrant,

7 which is found in every soil, in every soil. We

8 believe that we have a sustainable and

9 environmentally friendly methodology for growth. 

10 We use less water. We use less land. We use less

11 organic fertilizer. And most importantly, we have

12 been certified for many years.

13 We have made substantial investments. 

14 We continue to make, plan to make substantial

15 investments, and we don't want to be stripped of

16 the USDA organic label. Thank you very much for

17 your time. And I'd be happy to answer any

18 questions. I lost my presentation, so that's why

19 I was speaking somewhat spontaneously.

20 CHAIR CHAPMAN: Thank you. Questions? 

21 Thank you very much. Up next is Julie Weisman,

22 followed by David Hiltz on deck. Julie, if you
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1 can start with your name and affiliation for the

2 record. 

3 MS. WEISMAN: My name is Julie Weisman,

4 I'm an owner of Elan Vanilla and Flavorganics. 

5 I'm a past member of this board. I served on the

6 NOSB from 2005 to 2010, during which time I

7 chaired the Handling Committee and served as both

8 vice-chair and secretary of the board.

9 So first of all, good morning. Welcome

10 to our five new board members. I feel you. I

11 promise that the fog is normal and it clears

12 quickly. And thank you very much for answering

13 the call to serve.

14 I also have a special shout-out that I

15 must give to five of my friends who find

16 themselves without a mic for the first time in

17 five years. I feel you too. I had to be

18 restrained at times during my first post-term NOSB

19 meeting.

20 I would like to talk about two issues,

21 flavors and 606, both near and dear to my heart. 

22 I've been making certified organic vanilla extract
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1 for 20 years, and many other certified flavor

2 ingredients for only slightly less time. 

3 And I was glad to see the notice of the

4 final rule on Sunset 2017, which included the re5 listing of flavors non-synthetic on 605(a) for

6 another five years, because for certain products

7 they are still needed.

8 But now, I would like know where is the

9 annotation change that goes with it? The OTA

10 submitted a position to add commercial

11 availability language to the annotation of listing

12 on flavors on 605(a).

13 My companies were signatories, and it

14 was passed by the full board at the fall 2015

15 meeting in Stowe, Vermont at the same time as they

16 passed the renewal of flavors on the list. It was

17 a package deal.

18 I strongly urged the program to please

19 continue the rulemaking on this much needed board

20 annotation change and get it into the Federal

21 Register, please.

22 Okay, so 606. I see also that the 2017
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1 Sunset includes nine items that are going to be

2 allowed to sunset and leave Section 606. And this

3 makes me happy, but not for the reason that you

4 might think.

5 In 2006, this board scrambled ahead of

6 the deadline in the Harvey lawsuit to get dozens

7 of non-organic agricultural ingredients then in

8 use onto Section 606 of the national list. There

9 was great objection then to what was perceived by

10 some as lowering or watering down the organic

11 standards by adding so many substances to the

12 national list.

13 I insisted at the time that listing

14 these substances was going to expand the organic

15 domain, not compromise it. I saw listing these

16 items as a de facto brief to the ingredient

17 companies to develop organic versions of the items

18 they already made.

19 More than two dozen items got added to

20 606 that year, 18 of them were colors, and of the

21 remaining 11 that were added, nine are now going

22 to sunset because they are now commercially
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1 available as organic. 606 works, commercial

2 availability requirements work, don't be afraid to

3 use it. Thank you.

4 CHAIR CHAPMAN: Very good, thank you. 

5 Any questions for Julie? All right, thank you

6 very much, Julie. Up next is David, followed by

7 Lynn Coody on deck. David, if you can, yeah,

8 David, if you can start with your name and

9 affiliation for the record.

10 MR. HILTZ: Thank you, Mr. Chairman. 

11 My name is David Hiltz, I'm a research director

12 with Acadian Seaplants. We're a Canadian company

13 that produces products for marine plants for use

14 in animal, human, and agricultural applications

15 around the world.

16 Acadian appreciates the recent efforts

17 of the NOSB to clarify the use of marine materials

18 in organic agriculture, and we would like to take

19 this opportunity to comment on the proposals set

20 forward.

21 With respect to the Crops Committee

22 proposal to specify that extracts from only brown
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1 algae should be allowed in organic crop

2 management, we question the scientific rationale

3 behind this suggestion.

4 While most aquatic plant extracts that

5 are currently in use are produced from brown

6 algae, we would not like to see a barrier imposed

7 to new, innovative products that are derived from

8 green or red algae, should future research show

9 their benefits in organic cropping systems.

10 With respect to the Handling Committee

11 recommendation to annotate listings for marine

12 algae with Latin binomials at the class level, we

13 support that effort, as it will further clarify

14 the exact nature of the material being used in the

15 organic system.

16 And finally, we support the efforts of

17 the NOP and the NOSB to clarify the term kelp in

18 the evaluation of the various harvesting criteria

19 around that.

20 However, we continue to notice that

21 many of the public comments on this issue continue

22 to signal the harvest of Ascophyllum nodosum,
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1 commonly known as rockweed, as an example of a

2 practice that, in their opinion, does not meet the

3 sustainability and wild harvest criteria of OFPA.

4 As part of previous public comments,

5 Acadian Seaplants and other commercial entities

6 have provided numerous peer-reviewed scientific

7 studies that demonstrate that the use of a

8 science-based resource management and harvesting

9 plan can ensure that the commercial harvest of

10 this species can be done in a sustainable manner. 

11 And it does not have negative impacts on either

12 the resource or the ecosystem that it grows in.

13 We therefore urge the NOP and the NOSB

14 to draw upon the facts from these government,

15 industry, and scientific studies, while closely

16 scrutinizing the opinions that are often presented

17 with little to no scientific evidence in their

18 support of claims that rockweed harvesting is

19 detrimental and is inconsistent with the OFPA

20 rule.

21 So, appreciate the time and effort of

22 the board to continue these issues or consider
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1 these issues, and we'd be happy to answer any

2 questions if you have them.

3 CHAIR CHAPMAN: Emily.

4 MS. OAKLEY: Hi, thank you. You

5 produce products from brown algae, correct? So,

6 and you said you would like to not be restricted

7 for potential future use of red or green. Can you

8 elaborate on that?

9 MR. HILTZ: Just, you know, if there's

10 a scientific reasoning behind that, by all means,

11 put that annotation in place. But in lieu of any

12 scientific reasoning, which I'm unaware of as to

13 why a product produced from a green algae or a red

14 algae would be inconsistent with an organic crop

15 system, I don't see why you would put that barrier

16 in place right now.

17 And there are some products on the

18 marketplace, I believe one of the other commenters

19 pointed out that there are some products already

20 out there from red and green -- or green species.

21 MS. OAKLEY: I'm not the original

22 author of this document, but I believe some of the
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1 original intention was to address sustainability

2 issues. And so the intent behind naming the

3 classes being used was to ensure that we didn't

4 overly broaden extraction in the future of marine

5 materials.

6 So just to provide that background. 

7 And yes, I think there are going to be some people

8 coming forward from OMRI, and I will have some

9 questions for them as well. So thank you.

10 MR. HILTZ: Wonderful, thank you. 

11 Thanks for your time --

12 CHAIR CHAPMAN: We have more question. 

13 Dave.

14 MR. MORTENSEN: Yeah, I was curious, I,

15 a long time ago studied algae in several places. 

16 And I have a hard time just understanding how you

17 can harvest to a species level from a community of

18 algae. 

19 MR. HILTZ: In most cases, the area,

20 like our company focuses heavily on Ascophyllum. 

21 Ascophyllum, you're right, is not 100% of the

22 actual species. There is a small amount of other
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1 brown species that will grow in those beds.

2 But usually we choose the specific

3 areas that we harvest that are 95% or greater

4 Ascophyllum, and that way it allows us to focus

5 mostly on that species when we bring the material

6 in.

7 MR. MORTENSEN: Okay, thanks.

8 CHAIR CHAPMAN: Thank you. Up next, I

9 have Lynn Coody, followed by Kristen Adams on

10 deck. Lynn, if you can start with your name and

11 affiliation.

12 MS. COODY: My name is Lynn Coody, and

13 I am presenting comments for the Organic Produce

14 Wholesalers Coalition, which is comprised of seven

15 businesses that distribute fresh organic produce

16 in the United States and internationally.

17 In our comments to the NOSB, we worked

18 to express our own ideas, as well as to provide a

19 channel for the voices of the many certified

20 growers who supply our businesses.

21 In February, OPWC polled its members

22 about the Sunset materials to be considered at
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1 this meeting. In turn, the wholesalers reached

2 out to the growers in their supply chains, which

3 supplied well over 100 comments explaining

4 certified growers' need for the material

5 sunsetting from Section 601.

6 We support the re-listing of all 2019

7 crop Sunset materials, particularly the

8 micronutrients and soluble boron, which were the

9 materials for which we received the highest number

10 of comments. Produce growers also emphasized a

11 need for copper-based products for control of a

12 wide variety of diseases on many types of crops.

13 Of particular note was the need for

14 copper-based products and the mix of materials and

15 practices used to control fire blight on apples

16 and pears now that antibiotics are no longer

17 allowed.

18 OPWC appreciates the Crop Committee's

19 continuous works on hydroponics and containers. 

20 This is of great interest to our members because

21 it affects the supply of organic fruits and

22 vegetables.
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1 Our members do carry products that fall

2 within this scope of the discussion, so we are

3 aware that OPWC businesses and our supplier

4 businesses will be impacted by any decision made

5 about hydroponic and container production. 

6 Depending on the direction of the decision, there

7 will be both positive and negative impacts to

8 members of the wholesale produce sector.

9 Additionally, these decisions are

10 likely to have impacts on both hydroponic and

11 field-based growers, because so many operations

12 have already been certified for production using

13 methods that will fall within any definition of

14 hydroponics.

15 Therefore, it is very important for the

16 NOSB to carefully consider both immediate effects,

17 and to anticipate the potential for unintended

18 future consequences. We urge the board to make a

19 clear distinction between hydroponic and container

20 production systems.

21 Focusing on developing standards for

22 the required and prohibited materials and
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1 practices for container organic production will

2 result in more productive comments and discussion,

3 both from the board and the organic community in

4 the future.

5 Due to the unusually short period given

6 to consider the NOSB's most recent proposal, we

7 intend to continue our work on this topic by

8 arranging meetings with operations that grow crops

9 and containers.

10 Our goal will be to better understand

11 their particular approaches to providing crop

12 nutrients and to identify successful biologically

13 based systems for cycling these nutrients through

14 multiple trophic levels. Thank you.

15 CHAIR CHAPMAN: Thank you, Lynn. 

16 Questions for Lynn? Ashley.

17 MS. SWAFFAR: Lynn, I'm going to ask

18 you my question that I asked --

19 MS. COODY: I don't know.

20 MS. SWAFFAR: I didn't even get to ask

21 it.

22 MS. COODY: I have no idea.
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1 MS. SWAFFAR: Okay. I thought maybe

2 you would know, of all --

3 MS. COODY: No, we, OPWC members deal

4 with such a wide variety. We sell every fruit and

5 every vegetable that you can imagine ever coming

6 onto your table organically. So I don't really

7 have the data set to provide answers to that

8 particular question. But it's a good one. 

9 Thanks.

10 CHAIR CHAPMAN: Thank you, Lynn. Up

11 next I have Kristen Adams. On deck is Suzanne

12 McMillan. Kristen, if you can start with your

13 name and affiliation for the record.

14 MS. ADAMS: Kristen Adams, MOSA, from

15 the Midwest.

16 So MOSA appreciates the work of the

17 Crops Subcommittee as they attempt to define

18 aeroponic, hydroponic, and aquaponic systems. 

19 However, MOSA does not support the prohibition of

20 these systems in organic production by proposing

21 that they be added to 205.105 as prohibited

22 practices in organic production.
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1 MOSA agrees that a standardized set of

2 definitions must be carefully considered, and

3 lacking firsthand experience of aeroponic

4 production, we offer no changes to the proposed

5 definition of aeroponics. We see the proposed

6 definition of aquaponics as a workable definition,

7 clearly separating aquaponic production and

8 aquaculture production.

9 MOSA suggests that the term biologically

10 recalcitrant be removed from the definition of

11 hydroponics. This term is a broad term and could

12 be misinterpreted as applying to container

13 production, which would then blur the lines

14 between hydroponic production and operations

15 growing crops in containers.

16 MOSA supports the development of

17 specific production standards for hydroponic

18 systems and aquaponic production, and supports the

19 continued expanse of the organic industry.

20 We believe that the inclusion of these

21 production systems within the context of organic

22 production offers innovative, creative solutions
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1 to our food sovereignty challenges and may even

2 have a place in reducing the conversion of fragile

3 ecosystems to soil-based organic production.

4 For example, one of the aquaponic

5 producers that is certified with MOSA is located

6 on the edge of the largest freshwater catfish

7 marsh in the United States, which is also

8 recognized as a wetland of international

9 importance. This aquaculture facility on this

10 particular parcel contributes significantly to the

11 economic stability of this multi-generational

12 family.

13 On the other end of the ecological

14 spectrum, these aeroponic, hydroponic, and

15 aquaponic production systems could contribute to

16 local food systems in urban and per urban

17 settings.

18 We also need to acknowledge the

19 Aquaculture Working Group and remember the

20 potential for certification of aquatic animals. 

21 While the suggested amendments of 205.105 by

22 definition of aquaponics refers to only plants,
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1 this amendment may reduce the potential of organic

2 certification of fish.

3 Will we eventually find ourselves in

4 the position of being able to certify aquatic

5 animals, but not the plants growing underneath

6 them? Or will we allow certification of half of

7 a whole system?

8 MOSA feels a sense of urgency in the

9 development of a clear path forward. As

10 certifiers, we continue to receive enquiries from

11 hydroponic and aquaponic growers who are seeking

12 inclusion in the certified organic community.

13 We also acknowledge the concerns of

14 those who do not support the inclusion of these

15 systems. And we really encourage the further

16 consideration of these ideas and support the

17 contributed development of these production

18 systems.

19 CHAIR CHAPMAN: Thank you. Questions? 

20 All right, we got Emily, Sue, Steve.

21 MS. OAKLEY: Hi, thank you. You

22 mentioned the possibility of hydroponic and the
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1 ponic systems operating in urban centers. And I

2 was wondering how many of the hydroponic

3 operations that you certify are in urban centers?

4 MS. ADAMS: Zero. We've only received

5 enquiries from those folks.

6 MS. OAKLEY: Okay.

7 MS. ADAMS: So none are currently

8 certified with us.

9 CHAIR CHAPMAN: Thank you. Sue.

10 MS. BAIRD: I think that may have

11 answered -- are you currently certifying aquaponic

12 and hydroponic systems?

13 MS. ADAMS: We are currently certifying

14 aquaponic systems that are a part of larger

15 systems.

16 MS. BAIRD: Right, so --

17 MS. ADAMS: Yeah, and none in urban

18 areas.

19 MS. BAIRD: Okay. How do your clients

20 meet, through their OSP, how are they meeting the

21 soil and crop rotation and all those standards

22 that would normally be written into an organic
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1 system plan?

2 MS. ADAMS: They're part of a larger

3 system. So if we look at the whole system, that

4 site and setting, that's how those requirements

5 are met. Yeah. Other questions?

6 CHAIR CHAPMAN: Steve.

7 MR. ELA: So two questions. I mean, in

8 an urban environment then, they're not going to be

9 part of a whole system, which you just said. So

10 I'm curious how you see that.

11 Then the other thing I'm curious about

12 for certification is, I mean, we've heard a lot

13 about with, you know, hydroponics or whatever

14 definition, you know, the biological activity and

15 such.

16 But what I don't hear about is the

17 other trophic levels, such as arthropods and

18 nematodes in those systems. And so could you

19 address, I mean, I look at soil as a whole, you

20 know, multiple trophic levels. Could you address

21 both those questions please?

22 MS. ADAMS: Yeah. So your second
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1 question, I'll respond offline. I can submit some

2 written comments to you when I have been able to

3 pull some other thoughts together. And your first

4 question, the urban setting, correct?

5 So I think if we expand and look a

6 little bit differently at how we define

7 biodiversity, that's how I personally believe that

8 those standards can be met. If we look at site

9 and setting in a larger context. Very vague

10 answer.

11 MR. ELA: I guess, I mean, that you

12 said you were able to certify these other

13 hydroponic systems because they were part of a

14 larger system in their farm. And in an urban

15 setting, they're not going to be part of a larger,

16 I mean, so that's.

17 MS. ADAMS: Yeah, we don't currently

18 certify any hydroponic, aquaponic systems in

19 urban. And I think that that would require the

20 organic community to expand how we look at

21 biodiversity and what we consider life diversity

22 and the specific elements of those parts. 
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1 What we currently have as standards,

2 what is a really good start. But having spent

3 time with some of the original drafters of the

4 standards, I know that there were other ideas that

5 have not been able to be incorporated, such as

6 animal welfare, which we're now just, you know,

7 pulling into our context.

8 And also some of the food justice of

9 the people involved. So with some of the expanded

10 vision, that would answer that.

11 CHAIR CHAPMAN: Thank you. And if you

12 have additional information to submit, please do

13 it through Michelle, thank you. Or the open

14 docket. Up next is Suzanne, followed by Jennifer

15 Berkebile, apologies, on deck. Suzanne, if you

16 can start with your name and affiliation. 

17 MS. McMILLAN: Hi, Suzanne McMillan,

18 content director, Farm Animal Welfare Department,

19 ASPCA, American Society for the Prevention of

20 Cruelty to Animals. Thank you for the chance to

21 present to you today on behalf of our over 2.5

22 million supporters nationwide.
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1 With regard to the allowed substances

2 lists, local anesthetics, lidocaine and procaine,

3 and the analgesia reverse agent tolazoline, should

4 continue to be listed with the anesthetic subject

5 to the proposed shortened with shortened

6 withdrawal period.

7 Organic animals, just like those raised

8 conventionally, are potentially subject to a range

9 of painful procedures, such as physical

10 alterations. So pain control should clearly be a

11 priority. That said, we urge the NOSB to champion

12 prevention.

13 Many painful procedures, like tail

14 docking and debeaking, can be avoided by providing

15 comprehensive, fundamental animal welfare. 

16 Stressors like overcrowding and social deprivation

17 can lead animals to injure themselves and others.

18 Rather than relying on painful physical

19 alterations which do not address underlying

20 welfare issues, organic should require outdoor

21 space, outdoor access, indoor and outdoor

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1 These go a long way toward preventing problems

2 before they ever develop to a level that might

3 require painful physical intervention.

4 The USDA recently finalized the organic

5 livestock and poultry practices rule, which

6 codifies much of these of preventive tools I just

7 enumerated, coupled with limits on physical

8 alterations. We thank the NOSB for crafting

9 recommendations toward this rule and urge

10 implementation as soon as possible.

11 Finally, the National Organic Program

12 declined to take up a number of outstanding animal

13 welfare issues in the final rule, opting instead

14 to wait for NOSB recommendations.

15 We urge the NOSB to develop these

16 recommendations, particularly on the following

17 topics: genetics for meat birds, stocking

18 densities for species other than chickens, swine

19 living standards, and ammonia levels for mammals.

20 These standards are essential to robust

21 animal welfare. The ASPCA looks forward to

22 working with the NOSB to formulate meaningful
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1 recommendations. Thank you.

2 CHAIR CHAPMAN: Thank you. Questions? 

3 Harriet.

4 MS. BEHAR: Do you have an opinion on

5 oxytocin, the re-listing of oxytocin?

6 MS. McMILLAN: No. Not at this time.

7 CHAIR CHAPMAN: Any additional

8 questions? Thank you very much.

9 MS. McMILLAN: Thank you.

10 CHAIR CHAPMAN: Up next is Jennifer,

11 followed by Jason Whitcher. Jennifer, you can

12 start with your name and affiliation.

13 MS. BERKEBILE: Good morning, my name

14 is Jennifer Berkebile. I'm the materials program

15 manager at Pennsylvania Certified Organic. PCO

16 certifies over 1200 operations in the Mid-Atlantic

17 region of the U.S.

18 I wanted to begin my comment by

19 thanking the members of the board for all of your

20 time and effort. Today I will be commenting on

21 several petitioned and Sunset materials. 

22 I would like to first comment on the
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1 proposed annotation change for tocopherols put

2 forth by the Handling Subcommittee, which would

3 read, Derived from plant oils, non-synthetic or

4 organic tocopherols are to be used when

5 commercially available.

6 The subcommittee has indicated that

7 this will have a companion listing at 205.605(a). 

8 However, this proposed annotation change at

9 205.605(b) may necessitate an additional listing

10 for tocopherols at 205.606. A listing for

11 tocopherols at 205.605(a) will only allow for non12 agricultural, non-synthetic tocopherols.

13 So if a processor finds a source of

14 non-synthetic tocopherols derived from plant oil,

15 but it is determined to be agricultural, they will

16 not be able to use it unless it is certified

17 organic, since tocopherols are not listed at 606.

18 An additional listing for tocopherols

19 at 606 would allow producers to use non-organic,

20 non-synthetic agricultural tocopherols when

21 organic versions are not available.

22 If a listing for tocopherols is added
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1 to 606, PCO encourages the subcommittee to

2 consider whether a listing for tocopherols at

3 205.605(a) is necessary. It may not be necessary

4 if all tocopherols derived from plant oils are

5 only either agricultural or non-ag synthetics.

6 I also wanted to briefly mention that

7 this annotation might not be straightforward for

8 operators to document, because it is unlikely that

9 an operator will be able to determine if a

10 tocopherol is synthetic or non-synthetic. This

11 puts the responsibility for determining the

12 commercial availability of non-synthetic

13 tocopherols on certifiers.

14 Okay, next I want to comment on the

15 cellulose proposal. PCO questions whether it is

16 sound and sensible to not only require certifiers

17 to obtain complete ancillary ingredients, but also

18 their specific functionality. This seems

19 unnecessary and burdensome, and will not likely

20 add any value to the review of cellulose.

21 I would like to briefly comment on

22 humic acid. The Crop Subcommittee discussed
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1 whether this listing should have an annotation

2 requiring that humic acids are from sources with

3 the lowest environmental and human harm. This

4 alone would be difficult to verify, so more

5 clarification on quantifying environmental and

6 human harm would be needed.

7 Finally, I wanted to briefly discussed

8 coppers, fixed. The Crop Subcommittee has

9 requested feedback on the possibility of an

10 additional annotation, such as no visible residue

11 is allowed on harvested crops.

12 Such an annotation may be

13 inconsistently applied, as it may be difficult to

14 verify if inspections do not occur close in time

15 to harvest. PCO instead requests additional

16 guidance on the current annotation, which states,

17 copper-based materials must be used in a manner

18 that minimizes accumulation in the soil. Thank

19 you.

20 CHAIR CHAPMAN: Thank you. Any

21 additional, any questions? Asa?

22 MR BRADMAN: You mentioned humic acid. 
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1 And I think, you know, from what I can see,

2 everyone supports that, and it's an important

3 tool. But there is concern about using material

4 that has been derived from coal as opposed to,

5 even though it's a manufactured product, can come

6 from natural sources.

7 I wonder if you had thoughts on at

8 least encouraging or preferring one over the

9 other, and how to evaluate that.

10 MS. BERKEBILE: Sure. PCO doesn't

11 currently allow any humic acids derived from coal. 

12 We don't, yeah, we don't currently have any that

13 are approved. So I would encourage the NOSB to

14 put out guidance or an annotation change, as you

15 mentioned, to really specify not derived from

16 coal, if that's, you know, what you would like to

17 require.

18 CHAIR CHAPMAN: Dan.

19 DR. SEITZ: I don't know if this is a

20 question for you or for one of my fellow board

21 members, or for Miles.

22 When you get tocopherols, there were
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1 comments about if it's derived from vegetable

2 oils. Of course, a lot of vegetable oils are corn

3 and soy based. So would there be the possibility

4 that GMO oils would be a source of tocopherols

5 under that listing?

6 MS. BERKEBILE: Can you repeat the

7 second part of your question?

8 DR. SEITZ: Is there a possibility that

9 GMO oils, such as soy or corn oil, could be a

10 source for tocopherol in organic products?

11 MS. BERKEBILE: I think maybe with the

12 way the annotation is written. So maybe, again,

13 if you list it at 606 -- oh, gosh, I don't know,

14 I think --

15 DR. SEITZ: This might be a question

16 for the NOP staff. I'm not sure. 

17 MR. McEVOY: I think I'll pass this to

18 Dr. Brines.

19 DR. BRINES: Thank you. Yeah, the NOP

20 regulations do prohibit the use of excluded

21 methods or GMOs in organic products. And that

22 prohibition does extend to the of use non-organic
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1 ingredients that are on 205.605 or 205.606.

2 So as part of the verification process

3 for those ingredients, certifiers do request

4 verification that those products aren't produced

5 using excluded methods which led to radiation. 

6 Thanks.

7 MS. BERKEBILE: Right, yes, we do

8 request it. Sorry.

9 CHAIR CHAPMAN: Steve.

10 MR. ELA: You didn't get to finish your

11 comment on coppers, but I'm curious if you've seen

12 any issues with the soil accumulation of coppers.

13 MS. BERKEBILE: So we do have some

14 farms that use coppers that do have high levels in

15 the soil. But, you know, perhaps they are using

16 them in a manner that minimizes accumulation in

17 the soil. So that's why guidance might be

18 helpful. What would you consider a manner that

19 minimizes accumulation in the soil?

20 Is there some threshold of copper above

21 which that, no matter what manner they're using it

22 to minimize accumulation, if it's higher than
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1 that, they're not doing a good enough job, for

2 example. What if copper levels are higher in that

3 soil prior to farming even? So, again, more

4 guidance would be helpful.

5 CHAIR CHAPMAN: Thank you very much. 

6 And thank you for the comments on tocopherol. It

7 raised some issues we did not consider in the

8 subcommittee, so thank you.

9 MS. BERKEBILE: Thank you.

10 CHAIR CHAPMAN: Up next is Jason, and

11 on deck is Sam Welch. Jason, if you can start

12 with your name and affiliation for the record.

13 MR. WHITCHER: My name is Jason

14 Whitcher. I don't, stating any affiliation at

15 this point. More as a citizen and a concerned

16 person in the organic farming industry. Sorry, no

17 affiliation, just a concerned citizen in the

18 organic farming industry.

19 Good morning. I stand before you today

20 to speak on the subject of container production of

21 organic vegetables. I'm not going to give you

22 opinions or ideals, I'm not going to discuss what
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1 tomatoes my chickens prefer.

2 I'm not going to suggest that there's

3 some unexplainable magic between the bedrock of

4 the earth and the soil, as the opposition to

5 container production did in St. Louis.

6 I am going to share with you some facts

7 and data for you to consider for your

8 recommendation, and to ensure you understand the

9 disastrous consequences removing greenhouse

10 organics would have on the marketplace if de11 certification were to happen.

12 Facts. Greenhouse production of

13 organics have been certified for over 15 years. 

14 Container production follows the same rules, uses

15 the same inputs as their field counterparts.

16 Container production is environmentally

17 responsible, uses up to ten times less water and

18 land, has zero fertilizer runoff, zero soil

19 erosion, and a controlled environment provides a

20 better platform for food safety programs.

21 It is not possible to replace the

22 greenhouse production of organic vegetables with
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1 field organics. And removing them would create a

2 giant hole in the market, restricting the

3 availability of healthy organic produce that

4 consumers are looking for.

5 Removing organic greenhouse production

6 from the market would cause a severe financial

7 strain to hundreds of organic greenhouses and

8 jeopardize thousands of jobs in the sector. 

9 However, there would be a significant financial

10 windfall for the remaining producers.

11 Surveys show that people who consume

12 organics are concerned with the inputs and are

13 indifferent to the substrate that they are grown

14 in.

15 Some data to consider. Tomato category

16 growth overall was 1.5% year over year. Organic

17 tomato growth was 16%, more than ten times the

18 conventional market. Pepper category growth was

19 2.3%. Organic pepper growth, again, was

20 exponential at 17%.

21 Cucumber category growth was also 2.3%. 

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1 Fifty percent of this growth came from greenhouse

2 production. Twenty-three percent of all tomato

3 production, organic tomato production, comes from

4 greenhouses. Forty-four percent of all organic

5 pepper production comes from greenhouses. Thirty6 seven percent of all organic cucumber production

7 comes from greenhouses.

8 I'll end with a question. If organic

9 greenhouse production is de-certified, where will

10 the public get its healthy organics that they are

11 looking for, and what will be the explanation as

12 to why they are unavailable?

13 CHAIR CHAPMAN: Emily, Ashley, Steve.

14 MS. OAKLEY: Hi, Jason. We are asking

15 people to give people their affiliations because

16 it helps us better understand the context of their

17 comments, and you listed yours as a citizen. But

18 you seem to have perhaps an interest in this.

19 So I was wondering if you could

20 identify that. And when I Google you, I see you

21 work for a, yeah, so if you could just elaborate

22 more.
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1 MR. WHITCHER: I work for a greenhouse

2 marketing company. I also sit on several boards. 

3 I don't have permission from them all to affiliate

4 themselves with my comments, so I refrained from

5 that at this point in time. I am heavily invested

6 in the greenhouse industry. I have been for 24

7 years.

8 CHAIR CHAPMAN: Ashley, then Steve.

9 MS. SWAFFAR: So I kind of think you

10 answered my question, and I couldn't write it down

11 fast enough. So 23% of tomatoes --

12 MR. WHITCHER: Of organic tomatoes.

13 MS. SWAFFAR: Yup. Forty-three percent

14 peppers.

15 MR. WHITCHER: Forty-four, I believe.

16 MS. SWAFFAR: Forty-four. And

17 cucumbers?

18 MR. WHITCHER: Thirty-seven cucumbers.

19 MS. SWAFFAR: Thank you. Been waiting

20 for that all week.

21 MR. WHITCHER: And that's predicated on

22 available retail scan data. So there are
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1 companies like Costco that don't share their

2 retail scan data. I think that would skew the

3 numbers the other way, as Costco goes to

4 greenhouse prior to going to the field for food

5 safety purposes.

6 MR. ELA: So I'm curious, I mean,

7 you're talking about greenhouses. You know, part

8 of our discussion document is hydroponics versus,

9 and trying to separate out hydroponics versus

10 container grown. Am in clear in understanding

11 you're probably talking about container-grown

12 versus straight hydroponic?

13 MR. WHITCHER: Both. Both would be --

14 MR. ELA: Do you have a sense that one

15 could be disallowed and not the other?

16 MR. WHITCHER: I mean, that's all up to

17 the NOP. But is there a scientific basis for it? 

18 No. Has there been any presented? No.

19 CHAIR CHAPMAN: Emily.

20 MS. OAKLEY: Would some of those plants

21 in the greenhouses be grown in the ground for the

22 statistics that you provided us?
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1 MR. WHITCHER: We currently, the

2 company I do work for currently has 12 organic

3 greenhouses that produce a significant amount of

4 volume, and none of them produce in the ground. 

5 It's all container production.

6 CHAIR CHAPMAN: Thank you very much. 

7 Up next is Sam Welsch. If you could start off

8 with your name and affiliation for the record.

9 MR. WELSCH: My name is Sam Welsch from

10 OneCert. I was a member of the Hydroponics Task

11 Force. First, I want to congratulate Miles and

12 the NOP for acting to improve traceability of

13 organic products handled by uncertified operations

14 in the supply chain. 

15 This is a huge risk to organic

16 integrity, and typical verification is currently

17 much too superficial to determine the actual

18 organic status of such products.

19 Second, I want to highlight an area of

20 extreme inconsistency among certifiers. As you

21 know, land where a prohibited substance was

22 applied must undergo a three-year transition
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1 before organic crops can be harvested. The

2 organic rules allow the use of non-organic

3 planting stock if organic is not available.

4 Some planting stock is bare root and

5 some comes with roots still in growing media. If

6 that growing media contains a prohibited

7 substances, the land where it's planted must

8 undergo a three-year transition before crops from

9 that plant can be certified organic. 

10 However, some certifiers allow such

11 plants to grow organic crops with no transition

12 period, or a transition period as short as one

13 year. This means that an operator growing in

14 containers could transition conventional plants as

15 planting stock to organic hydroponic production in

16 one year or less.

17 As we begin, and now lastly I'll

18 discuss our work on the Hydroponic Task Force. 

19 The NOP presented some background information. 

20 This slide is one example of that. The

21 presentation cited the mandatory portion of the

22 law that requires soil fertility to be fostered
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1 primarily through the management of the organic

2 content of the soil.

3 The NOP asked the task force, How could

4 hydroponic or aquaponic systems align with this

5 requirement. The simple answer is they can't. 

6 I'll repeat that. They can't. This is in the

7 law.

8 So it begs the question, Why does the

9 NOP allow hydroponic and aquaponic systems to be

10 certified when such systems do not comply with

11 this mandatory requirement in OFPA. 

12 As the NOSB works on this issue, you

13 must remind the NOP that OFPA rules. You don't

14 need to propose new regulations to prohibit

15 certification of hydroponics. OFPA already does

16 that. Certifiers know this.

17 The only way they can certify

18 hydroponics is to designate this section of OFPA

19 is not applicable when granting certification. 

20 When asked what authority they have to designate

21 federal organic law as not applicable, they reply

22 that NOP says that they can certify hydroponics. 
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1 You've heard many comments about

2 certification of crops grown in containers. I

3 urge you to keep the organic program rooted firmly

4 in the soil. Keep it simple, as OFPA says it

5 simply. Don't let the meaning of organic get

6 watered down.

7 CHAIR CHAPMAN: So I have Ashley,

8 Francis, Steve. Ashley, go ahead.

9 MS. SWAFFAR: Okay, in this same thing

10 that you've put up here, how does a no-till system

11 comply with OFPA? How do systems that are

12 rotating soils, not doing crop rotations, comply

13 with OFPA? Would you deny certification to those

14 types of systems?

15 MR. WELSCH: Could you restate those?

16 MS. SWAFFAR: No till and the no crop

17 rotation rotating soil, how would those comply

18 with what you put on the screen, and would you

19 deny certification to those?

20 MR. WELSCH: The rules do allow for

21 perennial crops to have alternative ways of

22 meeting the crop rotation requirements. And no-
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1 till operations do have crop rotations.

2 MS. SWAFFAR: But as a part of this,

3 no-till, this says it has to have proper tillage. 

4 No till has no tilling.

5 MR. WELSCH: Many people would say no

6 till is proper tillage. And it more like a

7 natural system than is the cultivation systems. 

8 So it is, you know, I don't see any inconsistency

9 with this.

10 MS. SWAFFAR: So you would not deny

11 certification to those types of operations?

12 MR. WELSCH: No. In those systems you

13 described, the soil fertility is coming primarily

14 through management of the organic content of the

15 soil.

16 CHAIR CHAPMAN: Francis, Steve, then

17 Harriet.

18 DR. THICKE: Sam, from your work on the

19 Hydroponic Task Force, what's your thinking about

20 containers? Do you have any suggestions -- well,

21 first of all, would you suggest we could have a

22 standard for containers, and do you have any
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1 guidelines in mind that they might think about?

2 MR. WELSCH: I think the only

3 appropriate, or the only allowable under the law

4 and regulations as it exists now, you could grow

5 organic transplants, which would be transplanted

6 into the soil. So that's a temporary use of

7 containers. Things like sprouts or microgreens

8 might be grown in containers.

9 Other than that, the difficulty with

10 allowing certification of crops grown in

11 containers is what we saw is the huge increase of

12 organic hydroponic or container-grown systems

13 after the 2010 recommendation. 

14 Because it seemed to allow things, and

15 people saw loopholes in that recommendation where

16 other saw it tightening things up. Others saw it

17 as an opportunity for loopholes and allowing more.

18 So if you're designing a proposal for

19 certification of containers, which right now I

20 think it should be limited to soil, but if you

21 want to design a, make recommendations for

22 containers, you have to be very, very careful and
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1 very clear that you're not creating loopholes for

2 those who want to continue what is essentially,

3 you know, hydroponic systems.

4 CHAIR CHAPMAN: Thank you. We have

5 Steve, then Harriet, then Dan, then Scott, and

6 then myself. And we'll cut it off there.

7 MR. WELSCH: Good you have the last

8 word.

9 MR. ELA: Could you come back to, I

10 didn't quite follow. So the transition of

11 conventional planting stock grown with

12 conventional or prohibited methods being able to

13 transition to hydroponics and not go through the

14 three year -- could you expand on that? I didn't

15 quite track with that well.

16 MR. WELSCH: Well, I was quite amazed

17 to hear, you know, at some training just a few

18 months ago, that there were certifiers who did not

19 consider the media that's in the pot, that goes

20 with that planting stock. They didn't even

21 consider it when they determined whether or not

22 prohibited materials were being applied to land.
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1 But if we're planting treated seed or

2 even a pelleted seed, any seed coating, it's very

3 clear we have to assess that. So why wouldn't we

4 assess the media that's in a pot in planting

5 stock? There's no logical, you know, no

6 consistency there when that takes places.

7 Those same certifiers who are not

8 looking at what's in the pot when they allow

9 potting, planting stock to be used in organic

10 production are also certifying hydroponic and

11 container growing systems.

12 So it leads me to the logical

13 conclusion that they're allowing conventional

14 container-grown planting stock to instantly become

15 organic that first year, with no transition

16 period.

17 MR. ELA: So if it was a bare root

18 planting stock of whatever, then we'd be okay. 

19 But it's the movement of that soil it was grown in

20 or whatever media it was grown in into the

21 conventional, okay.

22 MR. WELSCH: Yeah, just like uncoated
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1 seed that's conventional can be allowed, a bare

2 root conventional product, or conventional

3 planting stock could be allowed. That's allowed

4 in the rule specifically.

5 MS. BEHAR: Sam is the expert on the

6 OFPA. So we're looking, I know at least in my

7 mind, I'm looking at a possibility for container

8 productions, productions splitting out annual

9 versus perennial with different standards.

10 And I'm wondering, as a certifier,

11 could you verify if there was a specific amount of

12 the crop's nutrients coming from liquid fertility

13 inputs? Would that be something that would be too

14 much of a challenge for you to verify in the

15 container?

16 So if we said, No more than 30% of the

17 crop's nutrients can come from liquid fertility

18 inputs, meaning of course that the media could not

19 recalcitrant, it would have to be a compost or a

20 soil-based, or at least a majority of it.

21 MR. WELSCH: That is certainly

22 possible, and many certifiers are already looking
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1 at auditing the amount of fertility products that

2 are being used by any operation. 

3 However, it surprised us greatly, those

4 of us who do that, that were on the Hydroponics

5 Task Force, were greatly surprised to learn that

6 certifiers of these container-grown hydroponic

7 systems were not verifying the quantities that

8 their clients were using in those systems.

9 And in fact, it appeared that they were

10 not even learning exactly what substances were

11 being used. They're just being told, It's OMRI12 listed, or it's one of these products on this long

13 list, without getting specific information. 

14 Now, I cite back to Miles's favorite

15 part of the rule, which requires records that are

16 completely auditable, you know. Their organic

17 operations must have those kind of records. So it

18 is possible to do it, if the standards clear

19 enough for us to have something that we can

20 verify. 

21 CHAIR CHAPMAN: Dan, then Scott.

22 DR. SEITZ: From a number of people who
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1 have testified, we're heard about the adverse

2 economic impact that would happen if container or

3 hydroponic operations were disallowed under the

4 organic standard. What is the potential impact on

5 soil-based farmers if those continue to be allowed

6 under the organic stamp?

7 MR. WELSCH: I think some of them have

8 already spoke to that. But, you know, it does set

9 up a very uneven playing field for those who are

10 growing in the soil, versus those who can come in

11 with much cheaper, much less rigorously enforced

12 hydroponic or container-grown systems. 

13 I should remind you that I talk to

14 consumers who do care about things being grown in

15 the soil. Now, most of the consumers I know are

16 in the Midwest, where they also do gardening. So

17 they're aware of the difference between organic in

18 the soil and hydroponic operations.

19 And in fact, for 30 years, we used to

20 call conventional agriculture hydroponics in dirt,

21 because it was all about inputs and not about

22 building fertility in the soil. Organic has
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1 always been about building soil through the

2 management of organic matter.

3 That's where organic got its name. You

4 know, we really should not be allowing things that

5 are an oxymoron, like organic hydroponics.

6 CHAIR CHAPMAN: Thank you, Sam. Dan,

7 or sorry, Scott next.

8 MR. RICE: I'm curious if OneCert

9 certifies mushrooms, and how you view that in

10 terms of OFPA, where those are typically in a, for

11 lack of a better reference, a container and with

12 not always a rotation. It doesn't fit in OFPA as

13 well, but it is commonly certified.

14 MR. WELSCH: Sure. Mushrooms are not

15 a plant. And they're more like, they fit better

16 under the livestock definition, which would

17 require that the substrates in which mushrooms are

18 grown to be all organic. 

19 You know, the practice of some

20 certifiers to allow mushrooms to be grown on non21 organic substrates, including GMO substrates, I

22 think is not acceptable.
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1 MR. RICE: And in terms of those that

2 are grown in a compost or a soil, once those

3 substrates have been used, assuming those were

4 organic?

5 MR. WELSCH: Sorry, I didn't --

6 MR. RICE: In terms of, assuming that

7 the substrate is organic, from organic sources,

8 and then that is grown out in, you know, some of

9 the white button mushrooms in a non-soil, be a

10 compost mix of some sort. How would OFPA apply to

11 that?

12 MR. WELSCH: Well, I think, so you need

13 to look at it more in terms of is it getting its

14 feed from organic substrates, not from

15 conventional ones. It's one of those areas that

16 I think we were promised regulations back in 2000

17 or 2002, and they still haven't been promulgated.

18 We need better regulations for

19 mushrooms. You know, they're not plants, they're

20 not really livestock, we don't have regulations

21 for them. People are doing the best they can. I

22 don't think it's really directly relevant to this
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1 discussion of container growing. It's really a

2 separate issue because it's not plants. 

3 MR. RICE: And I have one response to

4 your concern on inputs versus media. I think a

5 number of certifiers rely on the guidance 5029,

6 which makes the distinction between an application

7 or an input. And I think that's how our agency

8 views that distinction, and a number of other

9 certifiers.

10 There's perhaps room for further

11 clarification from the program. We could go down

12 that route. But I would just point folks to the

13 guidance 5029 in how that's addressed.

14 MR. WELSCH: Now, that guidance is very

15 clear that anything applied to seed must be on the

16 national list. And it says that things that are

17 applied to planting stock before harvest are not

18 considered. It does not say that you can ignore

19 what's in the pot that comes with that planting

20 stock.

21 So if it's not bare root stock, there's

22 nothing in that guidance that says we should
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1 disregard what's in the planting media. And I

2 think, unfortunately, there has been some comments

3 in answering questions, because it wasn't as

4 clearly written as it should be, that some NOP

5 staff have given contradictory information about

6 whether or not that should be considered.

7 But if you consider that we care about

8 that thin layer of coating that goes on seed to be

9 planted to grow an organic crop, we should care

10 even more about what's in the pot that comes in

11 with planting stock. It's the only way to look at

12 it consistently.

13 CHAIR CHAPMAN: Thank you. And then I

14 had a question similar to Scott's. In terms of

15 6513 and in looking at, say, seaweeds or

16 watercress, how would those type of plants be able

17 to meet the requirements, or are they not able to

18 meet those requirements in your opinion?

19 MR. WELSCH: In regards to seaweed, I

20 was specific in the preamble to the rule when it

21 was published. They changed the wording in wild

22 harvest to allow it to be aquatic plants to be
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1 harvested. They're covered under the wild harvest

2 not --

3 CHAIR CHAPMAN: Specifically related to

4 OFPA, non the rule, the OFPA. How does OFPA

5 authorize the production of those plants, or does

6 it not?

7 MR. WELSCH: I did not look at OFPA

8 with regard to wild harvest. But it's the

9 seaweeds are collected under the wild harvest

10 provision, which OFPA does have a section on that.

11 And I think what's in the rule is very

12 similar to the wording that's in OFPA. So it's

13 not part of the OSP for crops, it's separate and

14 coming from the wild harvest area.

15 CHAIR CHAPMAN: So it is possible to

16 have plants, even if it's in the wild harvest

17 area, that does not use soil. I mean, you had

18 mentioned earlier that organic was, you know, that

19 came from soil management. But we do have this

20 disagreement in that area.

21 MR. WELSCH: I don't see it as being

22 inconsistent. I think there are different parts
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1 of OFPA and the regulations that are being applied

2 in those cases.

3 MR. McEVOY: Sam, you filed some

4 complaints with Compliance and Enforcement, and

5 maybe some of the things that you mentioned here

6 today are under review. But if you have any

7 additional allegations or complaints, evidence of

8 violations of the standard, please file them so we

9 can look into them and ensure --

10 MR. WELSCH: I'll remind my colleagues

11 that you invited me to do that.

12 MR. McEVOY: Okay.

13 CHAIR CHAPMAN: Okay, thank you very

14 much, Sam. So we are about 40 minutes behind

15 schedule, but looking at the angry eyes from the

16 board members, we will still take our break. 

17 It'll only be a ten minute break, or nine minutes. 

18 So we will start back up at eleven. 

19 One other note, for the speakers later

20 in the afternoon, Tracy Favre, Stanley Edwards,

21 Gwendolyn Wyard, Pat Kerrigan, Ann Marie Hourigan,

22 Mike Molina, and John Ashby, we may need to move
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1 you guys till after lunch. Try to find Michelle

2 or I if that's a problem, and we'll rearrange our

3 schedule. Thank you.

4 (Whereupon, the above-entitled matter

5 went off the record at 10:52 a.m. and

6 resumed at 11:07 a.m.)

7 CHAIR CHAPMAN: Okay, we'll get

8 started. Beth, come on up. On deck is Michael

9 Hasey. Beth, if you can start with your name and

10 affiliation for the record?

11 MS. STEPHENSON: Hi, I'm Beth Walker12 Stephenson, and I'm an organic consumer, and I'm

13 wife, mama, environmental writer, and I've come to

14 talk about bioponics. It's a difficult subject,

15 and I appreciate having an opportunity to share

16 from my experience and my wisdom. 

17 I read the hydroponic task force

18 writings, and here and at the St. Louis NOSB

19 meeting, I heard many good points both for and

20 against raising food using alternative methods. 

21 I see both sides, and I feel the real fears. 

22 I too am fiercely pro-soil, and I'm
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1 grappling with my own understanding and beliefs,

2 sometimes to a point where my husband noted that

3 I was talking out of both sides of my mouth. I

4 understand that bioponic systems can increase food

5 availability to areas where there is great need. 

6 I want everyone to have the opportunity

7 to have organic food, to heal food deserts. And

8 in recent months, I have been listening to many in

9 the organic community at various organic

10 conferences and meetings. I heard a call for a

11 food revolution. I understand that this is truly

12 an organic can of worms, but I have been listening

13 to my intuition, and my heart, and my gut, and my

14 head says that there's something more to be done.

15 I ask for alternatives to be

16 considered, regulations to be developed under the

17 NOP, maybe create a temporary moratorium if we

18 have to. I'd encourage different labeling, but

19 similar to current organic labels, but please, do

20 not close the door on alternative ways of raising

21 food organically. 

22 Let not those that are building the
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1 added sustenance for our ever-changing demand for

2 food have to tackle reinventing regulatory

3 standards for this viable method. It is easier to

4 only consider what we have known and want for

5 ourselves, babies, and grandbabies, but I'm asking

6 us to reach deeper, seven generations and beyond,

7 to simultaneously support our soil and build a

8 sound foundation for raising organic food in

9 radically changing environments. 

10 Don't let our fears immobilize us. 

11 With care and good sense, the time to act is now. 

12 If we even take baby steps, we will have the

13 opportunity to go forward in a safe and carefully

14 examined way towards solving our very real

15 upcoming food challenges. Thank you.

16 CHAIR CHAPMAN: Thank you. Any

17 questions? Thank you very much. Up next is

18 Michael Hasey, followed by Marco De Leonardo on

19 deck. Michael, if you can start with your name

20 and affiliation for the record?

21 MR. HASEY: Sure, I'm Michael Hasey

22 from The Farming Fish. It's a farm in southern
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1 Oregon. I'm also a member of the Recirculating

2 Farms Coalition. Thank you for your time. I

3 appreciate the opportunity to bend your ear. So,

4 The Farming Fish, you can learn more on Google,

5 Facebook, our website, thefarmingfish.com. 

6 We're a 40-acre certified organic farm

7 and a food processor. We've been certified for

8 six years now. Our journey was much like every

9 other family farm. We started out at the farmer's

10 market, grew, expanded, and now we sell wholesale. 

11 We're distributed amongst 30 grocery stores in the

12 Pacific Northwest. 

13 We are very compassionate to all

14 sustainable food production systems. We're very

15 passionate about those systems. We grow in the

16 earth as well as in our quarter-acre aquaponics

17 system. We're amongst the largest aquaponic

18 operation in the United States, perhaps the

19 largest certified organic aquaponic operation. 

20 In that aquaponic system, we grow

21 basil, watercress, lettuce, leafy greens, and of

22 course, fish. In the earth, we're growing
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1 potatoes, seasonal vegetables. We keep a flock of

2 laying hens, raise pork for our farm and our

3 employees' families. 

4 Our farm products are all certified

5 organic, but they're also certified Salmon-Safe

6 meaning no waste leaves our farm. It keeps our

7 waterways clean and the surrounding environments

8 clean and free from agricultural runoff. 

9 We have a very health work environment,

10 perfect conditions in what I call our controlled

11 organic agriculture system. That would be within

12 the greenhouse. It's a clean and comfortable

13 place for our workers. 

14 We practice natural pest management

15 practices, the use of beneficial insects. We

16 plant in an organic coco coir, a byproduct of the

17 coconut industry. We transplant into our living

18 organic water, and then we move our excessive

19 organic matter like any farm to compost. 

20 The aquaponics system, it does not harm

21 soil tilt in any way. In fact, it only

22 contributes to it. We could build or improve
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1 topsoil. We could build it from our aquaponics

2 system alone. In fact, we produce the nicest

3 compost in our valley. 

4 In addition to the organic matter

5 coming out of our aquaponics system, our fish

6 waste is an amazing organic resource as well. 

7 This builds our compost or it could be added

8 directly to our row crops. 

9 The native and tribal people understand

10 this, and they've been doing it for years. In

11 fact, we're helping two different tribal nations

12 get involved in aquaponics with their trout farms. 

13 Organic sustainable soil production,

14 soil fertility, soil microbiology, nitrate

15 fixation, the nitrate cycle, it's all the same

16 whether it's within the water, in the soil, or in

17 the water alone.

18 CHAIR CHAPMAN: Thank you. Questions?

19 MR. HASEY: Yes, please, any questions?

20 CHAIR CHAPMAN: I don't see any

21 questions. Thank you for your testimony.

22 MR. HASEY: All right.
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1 CHAIR CHAPMAN: Up next is Marco and on

2 deck is Johanna Mirenda. Marco, if you could

3 start with your name and your affiliation for the

4 record? 

5 MR. DE LEONARDIS: Good morning, my

6 name is Dr. Marco De Leonardis, and I'm the

7 research and development manager for Freeman Herbs

8 in Ontario, Canada. First, I would like to

9 support the concept that organic container grown

10 plants are legitimately organic. 

11 Organic agriculture is a sustainable

12 holistic production management system which

13 promotes and enhances agroecosystem health

14 including biodiversity, soil biological activity,

15 and recycling of material and resources to the

16 greatest extent possible with the intent of

17 protecting the environment, decreasing pollution,

18 and promoting a sound state of health. 

19 At Freeman Herbs, we grow plants in

20 pots using a solid substrate composed of peat moss

21 and turkey litter compost rich in microbes which

22 are responsible for the release of the nutrients
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1 to the plant. 

2 Therefore, I can confidently assert our

3 plants are grown in a healthy biological active

4 soil, not different at all from the biological

5 activity in the soil found in the crust of the

6 earth. By recycling our irrigation water in

7 today's environment, water conservation is a

8 matter of concern. 

9 We follow the principle of

10 sustainability and we need much less water to grow

11 our plants than if you were growing in the soil. 

12 Furthermore, nutrients are not leeched away and

13 pollute natural water systems as it often happens

14 in open fields.

15 Using several media and integrating

16 pest management program based on the release of

17 beneficial insects, we prevent pests and diseases

18 rather than react to them, creating an

19 ecologically sound environment where there is a

20 balance between predators and pests that's

21 promoting and preserving biodiversity.

22 I would like then to stress the
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1 benefits of growing plants in enclosures such as

2 greenhouses, or in case of sole source,

3 warehouses. Farmlands suitable for organic

4 agriculture is becoming scarce and more expensive,

5 and is getting further and further away from urban

6 dwellings, while greenhouses are often located at

7 the outskirts of them. If you consider that

8 already more than 40 percent of the organic

9 produce is greenhouse grown, it would be

10 impossible for field grown organic produce to meet

11 the increasing market demand. 

12 Operations set up to grow organic

13 plants in containers can be studied in small areas

14 like rooftops or recycled or reclaimed abandoned

15 building with very little investment creating

16 interesting opportunities for young entrepreneurs

17 during a time where unemployment is a matter of

18 concern.

19 A shorter distance from the city

20 markets means a lower carbon footprint to deliver

21 fresher product to the consumer for 12 months a

22 year, even in northern regions with prohibiting
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1 climates, following the organic approach of zero

2 kilometers.

3 I would like to thank the members of

4 the National Organic Standards Board Committee for

5 the opportunity to offer my opinions on such an

6 important matter. Any questions?

7 CHAIR CHAPMAN: Thank you. Any

8 questions for Marco? Steve?

9 MR. ELA: In your system, and I'm still

10 wrestling with, you know, I hear biological

11 activity, but I'm just going to come back to what

12 I asked earlier today about multiple trophic

13 levels of you know, nematodes, earthworms,

14 arthropods. I mean, it sounds like a container

15 system, but how do you incorporate multiple

16 biological levels?

17 MR. DE LEONARDIS: We apply nematodes

18 through balloons, and there is bacillus pumilus

19 added to the soil at the producer. We have

20 mycorrhizae in the soil, and I have been doing an

21 extensive research before choosing our media,

22 which is a proprietary mix. 
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1 And I have been analyzing for eight

2 months every week, analyzing the soil and see how

3 the soil changed so that I could add the right

4 amount of fertilizer in the soil and the plants

5 could get most of its nutrients from the soil. 

6 So I consider the pot as a

7 microenvironment that is very similar to what you

8 find in the field. It's just a microenvironment,

9 and once it's finished, it will go back to the

10 soil. 

11 So we are actually improving the soil

12 by when our pots either are transplanted in our

13 herbs or our vegetables which we grow for the

14 garden centers. They go back to the soil, so this

15 enriches the soil with all the organic matter that

16 we added to it, and the microbes, and the

17 beneficial.

18 CHAIR CHAPMAN: Thank you, Dave?

19 MR. MORTENSEN: Yeah, I was wondering

20 if you could speak to the assertion that we can't

21 meet the food demand if we don't have hydroponic,

22 and I ask that because, you know, all sorts of
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1 studies are out there that demonstrate that we're

2 using a lot of the land for biofuels, ethanol,

3 corn production. So where do you come up with the

4 assertion that we can't meet the vegetable demand

5 in the soil?

6 MR. DE LEONARDIS: Because there is not

7 enough available land in North American because of

8 the climate, so you can't grow year-round, so we

9 would have to import during the winter, for

10 example, in Canada, vegetables from Mexico or

11 other countries where they can grow it year-round. 

12 It's impossible to meet the demand

13 because there is not enough land available with

14 the right climate to grow those vegetables, or

15 those plants, or those herbs.

16 MR. MORTENSEN: Yeah, it would seem to

17 me that that's a choice more than it is a capacity

18 to produce, I would argue strongly, but I see what

19 you mean about land near urban centers. Thanks.

20 MR. DE LEONARDIS: Yes.

21 CHAIR CHAPMAN: Francis, and then we'll

22 cut it off there.
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1 DR. THICKE: So can you meet the new

2 organic, Canada's standards? Do you sell in

3 Canada? Can you meet Canada's container

4 standards?

5 MR. DE LEONARDIS: Yes, we do.

6 DR. THICKE: You have 70 liters per -

7 MR. DE LEONARDIS: Well, we grow in

8 pots, organic pots that are from rice husks which

9 are biodegradable, and there is not - it's not

10 like in containers like there is a certain amount

11 because you grow tomatoes. 

12 We sell live herbs and vegetables that

13 we grow for the garden centers, so they would be

14 transplanted, so those are actually considering

15 the recommendation would not fall under the matter

16 we're discussing today, but the herbs that we sell

17 as a live plant, it goes either, most of the time,

18 either the customer transplants it and then has

19 the herb, or during the winter, they can harvest

20 fresh herbs in their house. 

21 And as I said, after it's finished, we

22 can put the pot with the soil that we have in it
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1 in the ground because it's biodegradable, and it's

2 actually enriching the soil. So we are following

3 all organic directions, and it is allowed in

4 Canada, yes.

5 CHAIR CHAPMAN: Thank you. Thank you

6 for your testimony. Up next is Johanna, and on

7 deck is Jackie DeMinter. You can start with your

8 name and affiliation for the record.

9 MS. MIRENDA: Okay, hi, I'm Johanna

10 Mirenda, technical director of OMRI, the Organic

11 Materials Review Institute. 

12 First, some background information

13 about OMRI for the benefit of the new board

14 members, OMRI is a nonprofit organization that

15 provides expert, independent, and transparent

16 review of input materials used in certified

17 organic production and handling. 

18 We have reviewed and approved over

19 4,800 products all published in OMRI's well-known

20 OMRI Products List available to the public and

21 widely used by certifiers to determine compliance

22 of the operations they certify. 
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1 OMRI is a contractor for technical

2 evaluation reports, and over the past five years,

3 we've completed 37 technical reports on a wide

4 range of materials. We also provide educational

5 resources and training to certifiers on technical

6 material review. 

7 Since OMRI's founding in 1997 by a

8 partnership of certifiers, OMRI has been a

9 resource for material review information for NOSB

10 members and the greater organic committee.

11 To the crop subcommittee regarding the

12 proposal to change the annotation for

13 synthetically extracted aquatic plant products,

14 currently any aquatic plant is eligible for

15 synthetic extraction in accordance with 205-601J1. 

16 The subcommittee's proposal to add the

17 phrase, derived from brown seaweeds, would

18 prohibit other types of aquatic plants such as red

19 and green seaweeds from being synthetically

20 extracted. The rationale for this restriction is

21 unclear, and unclear why synthetically extracted

22 brown seaweeds would be compliant, but not red or
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1 green seaweeds.

2 Though OMRI does not take a position on

3 whether individual materials should or should not

4 be allowed, we do ask that board members justify

5 their recommendations with a citation from the

6 Organic Foods Production Act, the evaluation

7 criteria for exemptions for prohibited synthetic

8 substances which must be not harmful to human

9 health or the environment, necessary for

10 production because natural alternatives are not

11 available, and consistent with organic principles. 

12 Citing these OFPA criteria for each

13 vote on materials is important for organizations

14 like OMRI to communicate why certain synthetic

15 materials are granted an exception to be allowed. 

16 The justification that all synthetics on the

17 national list have been fully vetted to meet these

18 criteria is a key component of our messaging about

19 organic integrity of materials used in certified

20 organic production. 

21 And with extra time, I'll correct the

22 public record that OMRI has heavy metal testing
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1 requirements for most crop fertilizers, and OMRI

2 agrees that MROs like OMRI should be accredited by

3 the NOP.

4 CHAIR CHAPMAN: Thank you, questions? 

5 I see Emily. Emily, go ahead.

6 MS. OAKLEY: Hi, thank you. So could

7 you tell me, in your written comments, you

8 mentioned that you guys have some products that

9 contain red algae, but didn't specify exactly how

10 many, and I was wondering if you have that

11 information that you might be able to share with

12 us now?

13 MS. MIRENDA: Sure, thanks, Emily. We

14 did skim through the information we had available

15 to us on the taxonomic classifications of aquatic

16 plants in products that we have listed as

17 synthetically extracted. 

18 And the information available to us in

19 the short nine-day period allowed us to verify

20 that most of the products for which we do have

21 taxonomic information are from brown seaweeds, and

22 a handful, at least two, have red algae, but it
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1 would take more time to comb through all of the

2 products and potentially collect that information,

3 because it's not currently required for material

4 review, to see if other or more types of seaweeds

5 are used, plus other certifiers may be approving

6 other products.

7 MS. OAKLEY: Since he's not looking,

8 I'm just going to ask a follow up question. Do

9 you know any more detail on which red algaes are

10 used?

11 MS. MIRENDA: Yes, but I can't

12 pronounce it.

13 MS. OAKLEY: Is it that weird one,

14 Merell? I think it -

15 MS. MIRENDA: No, it's -

16 MS. OAKLEY: No, okay.

17 MS. MIRENDA: - gelidium?

18 CHAIR CHAPMAN: Thank you. Harriet?

19 MS. BEHAR: Would research on

20 sustainability of the harvest of inputs add a lot

21 of burden to the review that OMRI does of wild22 harvested materials like kelp and possibly fish? 
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1 And I haven't looked at the whole national list to

2 see what else might be effected.

3 MS. MIRENDA: Well, once a material is

4 considered approved under the regulations, whether

5 it's a nonsynthetic allowed because it's not on

6 602 like other aquatic plants that aren't

7 synthetically extracted, there isn't any need to

8 review the harvesting of that product because it's

9 an allowed nonsynthetic. 

10 Rather I think the review process of

11 the NOSB when considering materials in accordance

12 with the OFPA criteria should consider the depth

13 and the scope of the impact of that material on

14 the environment. 

15 Typically, you may just consider the

16 actual use of the material on an organic farm, but

17 looking back into the manufacturing process, and

18 in some cases, the production harvesting if it's

19 an agricultural input, would, yeah, add greater

20 integrity, and depth, and scope to your review.

21 MS. BEHAR: Just a little follow up, so

22 if we, let's say, had, you know, recommended
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1 guidance or something about the sustainable, turn

2 it off on the MROs again, that's what I'm

3 wondering, how much work it would be for you to -

4 you know, because we've heard that there are other

5 sustainable certifications out there that do

6 review the harvest.

7 MS. MIRENDA: Yes.

8 MS. BEHAR: I know there is for fish

9 and there is for kelp, and I'm just kind of

10 wondering how that would affect you?

11 MS. MIRENDA: Well, if it's a

12 regulatory requirement, we'll find a way to do it,

13 but material input manufacturers are somewhat

14 outside of the scope of required compliance. 

15 So OMRI has some ability to require

16 additional information from manufacturers because

17 they are choosing to apply to us and provide lots

18 of information that maybe a certifier who has a

19 farm or using a product is, you know, begging for

20 information from that manufacturer might have no

21 idea what organic is. So the feasibility and

22 practicality of getting more information about
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1 input materials is a question.

2 CHAIR CHAPMAN: Thank you. Thank you

3 very much. Up next is Jackie, and then following

4 Jackie is Ed Lehrburger from Pure Hemp. Sorry if

5 I butchered your name, Ed. Jackie, if you can

6 start with your name and affiliation?

7 MS. DeMINTER: Good morning, my name is

8 Jackie DeMinter. I'm a Certification Policy

9 Manager at MOSA. We certify approximately 2,000

10 operations throughout the United States, including

11 almost 900 livestock operations and 250 handlers. 

12 My comments today will address defining emergency

13 and ancillary substances in cellulose. Thank you

14 for the opportunity to comment on these topics. 

15 The NOSB is positioned to encourage and

16 embrace growth of the organic industry, and to

17 strengthen the organic seal. We encourage a

18 patient process for coming to final

19 recommendations. And since the comment period was

20 quite short for this meeting, we'd encourage

21 sending most proposals back to subcommittee and to

22 continue with the discussion documents at the fall
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1 meeting.

2 While we support the general direction

3 of the NOSB to further define the term emergency

4 with regard to materials used in livestock

5 production, we do not support an additional rule

6 change to section 205-238 in the standards. We

7 feel the new livestock rule addition of 238d

8 adequately addressed the needs identified with

9 regard to parasiticide use. 

10 Routine use of parasiticides is

11 defined, and it's logical that the term emergency

12 would also have a definition. However, any

13 definition should also consider other references

14 in the standards, and should not specifically

15 refer to parasiticides.

16 In addition to a definition, examples

17 related to organic livestock management would be

18 helpful. What types of situations qualify as an

19 emergency? We believe the NOP intended closer

20 attention be given to parasite control and

21 prevention, and we are revising our organic system

22 plan accordingly. Our intention is to better
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1 assess the plans for prevention already in place,

2 emergency measures planned in the event of an

3 outbreak, and why such a situation may arise. 

4 In our experience, an emergency would

5 occur when one or more animals are going to die,

6 or be permanently damaged, or are going to spread

7 the parasites to other animals if they do not

8 receive prompt treatment.

9 We have to be sure that adequate

10 prevention measures are built into the organic

11 management system, but even with these best

12 measures in place, parasites are adaptive and they

13 can appear quickly.

14 We would not, however, consider regular

15 outbreaks as a result of inadequate pasture

16 management to be an emergency. Definition and

17 examples of emergencies would help with certifier

18 consistency. 

19 Ancillary substances and cellulose,

20 only a few MOSA certified operations use

21 cellulose, but many ingredients we see have

22 ancillary ingredients, so we appreciate the
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1 ongoing consideration by the NOSB. This new part

2 of the sunset review process represents due

3 diligence and will provide needed clarification

4 regarding any substances that might be of concern. 

5 Assuming you have identified potential

6 concerns and found none, we'd see our review work

7 as redundant and burdensome. If there are

8 materials that are of concern, we'd appreciate

9 those concerns being called out in annotations. 

10 I do have additional thoughts on

11 planting stock if you'd like to ask me questions. 

12 Thank you for your work on these challenging and

13 precedent setting topics.

14 CHAIR CHAPMAN: Thank you. Any

15 additional questions? Scott and then Harriet. 

16 MR. RICE: I would love to hear more

17 about planting stock, Jackie.

18 CHAIR CHAPMAN: Briefly.

19 MR. RICE: Or how MOSA looks at it.

20 MS. DeMINTER: I'll keep it brief. At

21 the last meeting, I did make a comment on planting

22 stock. We believe that soil used in an organic
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1 container system must be free of prohibited

2 materials for 36 months prior to the harvest of

3 the crop, and that any other ingredients in the

4 media also be allowed. 

5 We feel that this should be true as

6 well for non-organic planting stock brought onto

7 the organic operation, yet we've been advised that

8 any media, as part of the non-organic production

9 system, does not require review. 

10 This presents a dilemma for certifiers

11 and it needs to be addressed and the exception

12 resolved. We should be looking at things in the

13 same manner whether it is on the organic operation

14 or being brought onto the organic operation from

15 a well-vetted process. 

16 You know, we have to verify that the

17 measures that they are taking using non-organic

18 planting stock, they're doing their due diligence

19 to try to find that organic planting stock, but if

20 we don't have to review that media or look deeper

21 into what is being brought onto the organic

22 operation, then we're sort of defeating that
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1 purpose, so we'd really advocate for that

2 exception to be resolved.

3 CHAIR CHAPMAN: Thank you. Harriet?

4 MS. BEHAR: So I'd like to go back to

5 emergency treatment. There's places in the rule

6 that kind of, that are a standard, and they have,

7 like in pest control, they have a hierarchy. 

8 And I know we've gotten some public

9 comment that the emergency treatment definition

10 would be tied to a hierarchy that would give a

11 roadmap basically to producers and certifiers of

12 what various things should have been done before

13 the resort was the synthetic parasiticides. 

14 And that's one of the reasons why we

15 didn't make emergency treatment a wider aspect

16 because, of course, when you're going to use

17 lidocaine or something, you know, that's a

18 different type of protocol that you would follow,

19 but if we ended up with something like that in the

20 rule, would you be supportive of that?

21 MS. DeMINTER: In the rule or as

22 guidance? I think that that's the
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1 differentiation. In the rule, I don't know that

2 I would - I don't know that we would support a

3 rule change. I feel that guidance can give a lot

4 of added examples and guidelines for certifiers to

5 follow. 

6 We follow lots of different guidance

7 and it's very helpful, and when you're looking at

8 a complex topic, you know, as emergency treatment

9 of parasiticides, guidance, in my opinion, might

10 be the better route than a rule change because of

11 the complexity of it, but we would definitely

12 support exactly what you're saying, that guidance

13 being in place. 

14 We have it with regard to facility pest

15 management and other things like that. What I was

16 saying with regard to incorporating the other

17 references in the rule is with the definition of

18 emergency. 

19 I totally support the idea of

20 additional guidance for parasiticide use and what

21 that step up treatment plan might be and what

22 measures need to be in place, but the definition
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1 of emergency, because it's used in direct

2 reference with at least two other materials on the

3 national list, poloxalene and xylazine, it needs

4 to be a broader definition because those are

5 emergency treatments also.

6 CHAIR CHAPMAN: Thank you. Ashley, and

7 we'll cut it off there.

8 MS. SWAFFAR: Sorry, guidance, do you

9 feel that guidance is not adequately enforced over

10 all certifiers? That's my concern with guidance. 

11 You probably won't see guidance coming out of

12 livestock. I'm just saying.

13 MS. DeMINTER: I'd leave that one to

14 the NOP to answer, I think. We follow guidance. 

15 MOSA takes guidance very seriously, and we

16 implement it when final guidance comes out, and we

17 do our best to follow that strictly as we would

18 the rule, and whether or not certifiers are

19 consistently applying guidance I feel would be the

20 NOP's responsibility through accreditation audits

21 to verify.

22 MR. McEVOY: Yeah, so we have a lot of
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1 guidance that's in the program handbook. Guidance

2 is interpretation, gives additional information on

3 how to comply with the regulations, that the

4 regulations are the things that are enforceable,

5 so guidance can be referenced in enforcement

6 actions, but the requirements are to comply with

7 the regulations. 

8 Guidance supplements the regulations,

9 but can't take the place of regulations. You

10 can't do regulations through guidance. So if it's

11 just to explain what the current regulations are,

12 then we can do a lot of things through guidance,

13 but we can't change the requirements through

14 guidance.

15 CHAIR CHAPMAN: Thank you. Thank you,

16 Jackie.

17 MS. DeMINTER: Thank you.

18 CHAIR CHAPMAN: Up next is Ed, and

19 following Ed is Nicole Dehne from Vermont Organic

20 Farms. Ed, you can start with your name and

21 affiliation for the record.

22 MR. LEHRBURGER: Thank you, Ed
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1 Lehrburger. I'm with Pure Vision Technology and

2 Pure Hemp Technology. We're a company that

3 processes biomass. 

4 Since the legalization of hemp, we

5 converted hemp stocks into pulp and paper. We

6 make paper products from Colorado grown hemp. We

7 take the flowers and we make dietary supplements,

8 and we take the sugars and make products like

9 Xylitol. 

10 So thank you for allowing public

11 comment on this extremely important topic of

12 organic certification of industrial hemp

13 production. 

14 As the CEO in the renewable biomass

15 industry for 20 years, I know it would be a net

16 benefit for domestic producers and consumers for

17 the USDA organic seal to be able to be applied to

18 all domestic hemp products produced from organic

19 certified land, not just those that fall under the

20 definition of hemp as articulated in the USDA,

21 FDA, DEA statement of principles on industrial

22 hemp. 
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1 As a processor speaking on behalf of

2 the hemp industry in Colorado and a growing number

3 of states in our country, we'd like really clear

4 communication about certified organic hemp growing

5 in organic soils and the use of those products so

6 we can label them properly for consumers. Thank

7 you.

8 CHAIR CHAPMAN: Thank you. Any

9 questions? Thank you very much.

10 MR. LEHRBURGER: You're welcome.

11 CHAIR CHAPMAN: Sorry, we do have a

12 question, Sue?

13 MS. BAIRD: Yes, you said organic hemp

14 grown in soils. What percentage is grown in soils

15 and what percentage is grown hydroponically?

16 MR. LEHRBURGER: I don't know the

17 answer to that, but I would say that as a

18 processor, we've never dealt with anyone growing

19 hemp hydroponically. It's all grown in soil.

20 CHAIR CHAPMAN: Thank you.

21 MR. LEHRBURGER: Thank you.

22 CHAIR CHAPMAN: Up next is Nicole,
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1 followed by Kyla Smith on deck. Nicole, if you

2 can start with your name and affiliation for the

3 record?

4 MS. DEHNE: Sure, that's Nicole Dehne. 

5 I don't mind that you - there's a lot of

6 butchering that happens with my name all the time,

7 so don't worry. I'm the Certification Director

8 for NOFA Vermont's organic certification program,

9 and that's Vermont Organic Farmers.

10 So VOF has been certifying organic

11 producers since 1985, and we currently certify

12 close to 700 organic producers in our state. I'd

13 like to thank the NOSB members today for their

14 hard work and their dedication, and also for the

15 opportunity to address the board. 

16 I am going to comment on three items. 

17 The first is the discussion document clarifying

18 emergency for the use of synthetic parasiticides. 

19 So the recommended annotation changes for

20 synthetic parasiticides will result in greater use

21 of these materials. So in preparation for that

22 increased use, we feel that further clarification
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1 of the term emergency will assist certifiers in

2 enforcing these regulations consistently. 

3 So we would support a definition of

4 emergency that clarifies the following, that the

5 procedure is not routine, that preventative

6 measures were established and have failed, that

7 identifies testing or procuring the recommendation

8 of a vet to determine infestation, whether the

9 animal's life or well-being is at risk, and that

10 requires that steps are taken to prevent a

11 reoccurrence.

12 So the second thing I'd like to comment

13 on is the sunset of biodegradable mulch. NOFA

14 Vermont and VOF frequently hear from our organic

15 producers about their desire to use biodegradable

16 bio-based mulch as an environmentally friendly or

17 alternative to plastic mulch. 

18 So the current NOP policy and memo, as

19 you know, requires that biodegradable mulches be

20 100 percent bio-based despite the fact that the

21 NOP rule does not specify this, and obviously the

22 problem with this interpretation is that there are
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1 no mulches available at this time or in the near

2 feature that could meet this 100 percent bio-based

3 requirement.

4 So we encourage the NOSB to find a

5 reasonable solution to this issue that allows

6 farmers to use a mulch film currently on the

7 market that's not 100 percent bio-based, while

8 creating a recommendation that could incentivize

9 production of biodegradable mulch with increased

10 bio-based content. So don't let the perfect be

11 the enemy of the good in that situation.

12 Then our third is just the discussion

13 document on aeroponics, hydroponics, and

14 aquaponics. The VOF believes that improving soil

15 health is the foundation of organic farming, and

16 therefore that those systems should not be

17 allowed. 

18 We support the regulation changes and

19 definitions of these systems as described in the

20 discussion document. We strongly encourage the

21 NOSB to limit container growing to transplants and

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1 We feel drawing a line in the sand to

2 determine how much soil is sufficient, how much

3 compost is required, how much fertilization is

4 allowed post-planting creates amongst growers a

5 feeling that the standards are arbitrary, and we

6 prefer the EU's simple approach that reflects the

7 principles of the organic movement.

8 CHAIR CHAPMAN: Thank you. Any

9 questions, Emily, Steve?

10 MS. OAKLEY: Hi, thank you. As a

11 farmer, I've heard from farmers about the

12 biodegradable bio-based mulch as well. A lot of

13 those farmers though aren't aware that such a high

14 percentage of the product is petroleum-based and

15 are surprised when they hear that, so I'm

16 wondering if the farmers that you're hearing from

17 are also aware of that content?

18 MS. DEHNE: I do, and I think it's this

19 balance of, you know, when I am on organic

20 vegetable farms, I'm often reaching down and

21 picking up little pieces of the black plastic just

22 as a habit, and so it's this balance of we're
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1 using a product that's unsustainable at the

2 moment. 

3 And you know, I think the material was

4 allowed on the national list knowing that it was

5 a synthetic material and that it had synthetic

6 polymers. So, you know, I'm wondering if there's

7 a balance that we can obtain.

8 MS. OAKLEY: Have you had a chance to

9 look at the TR and do you have any concerns about

10 soil accumulation or effects on the soil?

11 MS. DEHNE: Yes, I did read that and I

12 saw that accumulation piece, and yes, that does

13 make me pause, but again, I feel that there's a

14 balance and that's where I kind of came up with

15 this idea of, you know, you can't let the perfect

16 be the enemy of the good in this situation.

17 CHAIR CHAPMAN: Steve?

18 MR. ELA: So two questions, I mean,

19 following up on, we, you know, in general, don't

20 allow the application of petroleum products, I

21 mean, you know, because it's a slippery slope of

22 what, you know, and then is it fertilizer? You
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1 know, is that bio-based mulch acting as a

2 fertilizer? 

3 So I'm curious how you, you know,

4 resolve that? You know, we are still putting a

5 synthetic petroleum product on the soil. Even if

6 it breaks down, it's a synthetic additive that we

7 generally wouldn't allow.

8 And then my second question is on the

9 hydroponics or the containers. You know, not to

10 be too prescriptive, but to have an easy farmer to

11 understand thing, but what is that?

12 MS. DEHNE: Well, I guess for the

13 petroleum product question, we are using a

14 petroleum product right now. We're using massive

15 amounts of black plastic to grow organic crops, so

16 if we weren't allowing the use of black plastic

17 and then we were considering the use of

18 biodegradable bio-based mulch, that would feel

19 different to me, but we've already allowed a

20 petroleum product in and we're using it. We're

21 relying on it quite frequently, so, you know, how

22 do we balance that?
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1 The container question, you're

2 wondering whether VOF would support container

3 growing?

4 MR. ELA: Well, it's more you said, you

5 know, if we start talking about, you know, so much

6 soil, or so much compost, or a certain percentage

7 of nutrients, you know, you don't necessarily

8 support that, and I mean, maybe I misunderstood. 

9 At the end, you said you'd support an easy to

10 understand rule or whatever, and I mean, I think

11 that's what we're struggling with.

12 MS. DEHNE: Right.

13 MR. ELA: What is that?

14 MS. DEHNE: Right, I think, you know,

15 I mean, if pushed, I think it's possible to come

16 up with this definition of what it means to have

17 enough soil, and I would say that would be how

18 much compost, you know, how much fertilization,

19 how much volume of soil, maybe addressing

20 artificial lighting. 

21 It's just what worries me is this over22 complicates the issue. We have this really
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1 elegant simple approach that is if it's grown in

2 the soil, then that's allowed with limited

3 exceptions. 

4 And I think what happens, what I see

5 amongst our growers as, you know, a certifier who

6 has to regulate and convince people that these

7 standards make sense is that it starts to feel

8 arbitrary. So, Oh, you know, you need one more

9 teaspoon of soil in order to qualify with this,

10 and they look at me like, you know, like I'm

11 crazy, and that might happen enough anyway. 

12 So it just seems to me we do this a

13 lot. We over-complicate, and we could - we have

14 a solution that could be really simple that

15 everyone would understand that would be easy to

16 verify, so that's our preference.

17 CHAIR CHAPMAN: Scott, and we'll stop

18 it there.

19 MR. RICE: Just to put some context,

20 there's a lot of talk in the recent commentaries

21 and discussion with the board on the petroleum

22 issue, and I just for context wanted to point out
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1 the use of horticultural oils in a lot of the tree

2 fruit industry and elsewhere for the control of

3 pests. I appreciate the comments that you shared

4 of not letting the perfect be the enemy of the

5 good.

6 CHAIR CHAPMAN: Thank you.

7 MS. DEHNE: Okay, thank you.

8 CHAIR CHAPMAN: Up next is Kyla with

9 Garth Kahl on deck. I just want to quickly before

10 you start, Kyla, run through my current plan. 

11 We'll go until 12:15 where we'll break for lunch

12 and start back at 1:30. 

13 So what that means is in addition to

14 the names I've read before, Marty Mesh, Rodrigo

15 Ortega, Steve Rosse, Ian Justus, Ruth Watts, and

16 Jason Kamimoto will also happen after lunch. If

17 there's an issue with that, with your ability to

18 stay, please come talk to Michelle and we'll try

19 to rework the schedule. 

20 Kyla, can you start with your name and

21 affiliation? Thank you.

22 MS. SMITH: Good morning, my name is
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1 Kyla Smith. I'm the Certification Director at

2 Pennsylvania Certified Organic. I also serve as

3 the Chair of the Accredited Certifiers Association

4 Board of Directors. PCO certifies over 1,200

5 operations in the mid-Atlantic region of the U.S. 

6 PCO submitted written comments on

7 several topics. I'd like to reiterate a few

8 points from those comments regarding the crop

9 subcommittee's proposal for strengthening the use

10 of organic seed, as well as the livestock

11 subcommittee's discussion document for clarifying

12 the term emergency.

13 First, while PCO appreciates the

14 concept of continuous improvement, we are

15 concerned with the practical application of the

16 proposed regulatory change to 205-204. Without

17 further guidance, this idea of continuous

18 improvement has the potential to be inconsistently

19 implemented and enforced.

20 PCO identified several areas that

21 require further clarification in our written

22 comments, most importantly, what happens when an
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1 operator achieves full compliance with 205-204a by

2 using 100 percent organic seed as the proposed

3 language would be required, and then in a

4 subsequent year, must use non-organic seed for

5 some viable reason such as crop failure? Are they

6 now noncompliant because they didn't improve that

7 year, or would they be required to request a

8 temporary variance to stay compliant?

9 PCO also has concerns with the addition

10 to section 4.2.1 regarding record keeping and

11 recording the specific justification for each

12 variety of seed that a producer is using, and the

13 justification for each variety. 

14 The additional record keeping

15 requirements this will entail are significant. If

16 the expectation is for inspectors and certifiers

17 to verify for accuracy each justification listed

18 by an operation for each variety of seed used,

19 this will increase the time of the inspection and

20 review process, which will in turn increase fees

21 passed along to the operator.

22 Second, PCO supports the inclusion of
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1 a definition of emergency within the regulations. 

2 While the regulations currently outline the

3 parameters for parasiticide use and define routine

4 use of parasiticides, providing a definition that

5 all certifiers and organic livestock producers

6 could use to determine what constitutes an

7 emergency would further aid in the consistent

8 application of the annotated listing of

9 parasiticides, as well as other substances that

10 also contain the term emergency in their

11 annotations.

12 The definition of emergency has the

13 potential to be precedent setting if adopted into

14 the regulations, depending on the specifics of the

15 term defined. If simply defined as emergency

16 without specific context pertaining to

17 parasiticide use, this would also apply to other

18 substances listed at 205-603, namely poloxalene

19 and xylazine, as both annotations refer to the

20 term emergency. 

21 PCO would find this broader context

22 useful as most of the inquiries we receive
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1 regarding what constitutes an emergency are

2 pertaining to those listings as opposed to the

3 parasiticide listing. 

4 In addition, clarification through

5 guidance of examples of management practices would

6 also be helpful. Thank you.

7 CHAIR CHAPMAN: Thank you. Questions? 

8 Thank you, Kyla. Up next is Garth, and on deck is

9 Cori Skolaski. Garth, you can start with your

10 name and affiliation for the record.

11 MR. KAHL: Hi, my name is Garth Kahl. 

12 I'm with Common Treasury Farms, and I also run

13 Independent Organic Services. It's an inspecting

14 and consulting operation.

15 I want to thank the NOSB for taking the

16 time to also read my written comments. I know you

17 do read them. I really appreciate it. I get

18 emails sometimes from people at 4:00 in the

19 morning. I know it's an amazing amount of work

20 you do, so thanks for all that work.

21 I submitted written comments on a

22 number of topics, but I specifically want to talk
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1 about personal performance evaluations because

2 it's something near and dear to my heart. So in

3 general, I think the scope of the CACS in

4 attempting to wrestle with this problem, I think

5 you've done a good job. 

6 Nobody contests the fact that field

7 evaluation is beneficial to everyone involved,

8 inspectors, certifiers, and ultimately other

9 stakeholders. The NOP witness audits did reveal

10 that there is a wide discrepancy in competence and

11 skills of organic inspectors. 

12 At the same time, NOP has kind of

13 complicated the situation by continually revising

14 2027, and at times there has been some

15 contradictory statements. It's not advancing. 

16 There we go.

17 So I've been an organic inspector for

18 21 years, and I'm an IOIA accredited inspector in

19 all scopes. My main objection, and Scott

20 clarified this a little bit, but my main objection

21 has to do with part of the proposal that states

22 that witness audits should be conducted preferably
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1 by certifier staff. 

2 And I would like to propose instead the

3 language that witness audits should be conducted

4 by a senior qualified certifier staff member,

5 preferably one with experience performing organic

6 inspections, or by senior peer inspectors provided

7 that they have been properly trained in witness

8 audits.

9 Specifically, you know, this is a

10 specialized skill, and I don't like the idea that

11 someone who is not an inspector is preferable in

12 terms of doing that evaluation.

13 In talking with some of my colleagues,

14 I've heard some horror stories that people have

15 been sent out to do evaluations with very little -

16 you know, they've been evaluated by people with

17 very little experience. In short, at the same

18 time, yes, I'm hearing some really good positive

19 things. 

20 I really like the idea of an ACA/IOIA

21 task force to come up with training criteria, and

22 yes, yes, yes, Harriet's assertion, inspectors do
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1 make better reviewers, and I think vice versa, and

2 I think cross training in that area is a splendid

3 idea. You know, a lot of us do wear both hats,

4 and it's a good thing. So thank you very much for

5 your time, and I'll take any questions, and sorry

6 if I put anyone to sleep.

7 CHAIR CHAPMAN: Thank you very much. 

8 Any questions? Thank you. Oh, Harriet?

9 MS. BEHAR: Do we have your wording? 

10 Was that in a written comment too?

11 MR. KAHL: Yes, it's -

12 MS. BEHAR: Okay.

13 MR. KAHL: It's all in the written

14 comments. So I submitted two written comments,

15 one with general things, and one specifically on

16 the peer evaluation.

17 MS. BEHAR: Yes, I can't remember every

18 specific thing people wrote?

19 MR. KAHL: Really? I'm surprised.

20 CHAIR CHAPMAN: Thank you very much. 

21 Up next is Cori with Stephen Walker on deck.

22 MS. SKOLASKI: Good morning, my name is
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1 Cori Skolaski and I'm the Executive Director of

2 MOSA Certified Organic in Viroqua, Wisconsin. 

3 Thank you members of the National Organic

4 Standards Board for your good and hard work. It

5 does not go unnoticed.

6 Originally, I was going to come up here

7 today and talk about 2017. Specifically, I was

8 going to ask that there be clarification about

9 what constitutes ongoing training or education of

10 inspectors, but in their remarks, Jenny Cruse from

11 the Accredited Certifiers Association and Margaret

12 Scoles from IOIA spoke very well on this issue,

13 and most have submitted written comments, so I

14 feel I'm covered.

15 However, I will add that contrary to

16 what we heard earlier, MOSA has, in fact, received

17 a noncompliance based on guidance documents, and

18 it was regarding on site annual evaluation of

19 inspectors.

20 We agree that guidance should be

21 consistently applied among certifiers, but instead

22 of talking more about 2027, I would like to
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1 express gratitude. MOSA certifies over 2,000

2 operations in 22 states, and certifies more

3 livestock operations than any other agency. This

4 gives us a keen awareness of the challenges

5 related to organic certification of various

6 livestock species. 

7 And although we haven't discussed it

8 much at this meeting, I would like to express for

9 the record MOSA's appreciation of the work that

10 the NOSB and NOP have done on the organic

11 livestock and poultry practices rule. 

12 The rule provides a welcome level of

13 specificity that we believe will bring about

14 consistency in enforcement within the industry,

15 which in turn translates into a level playing

16 field for producers and greater consumer trust in

17 the organic seal. 

18 We have not heard many concerns about

19 the rule from MOSA's 900 or so livestock clients. 

20 In fact, the opposite is true. We've generally

21 been hearing support and appreciation that animal

22 welfare is being clarified. We sincerely hope
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1 that the rule will be implemented in a few weeks.

2 As I express support for the organic

3 livestock and poultry practices rule, I would also

4 like to voice support for the work of the National

5 Organic Program in general. 

6 The work done by the NOP and by the

7 members of the NOSB is of profound importance to

8 growers, to consumers, to our nation's economy, to

9 our planet, and for our grandchildren. Thank you

10 for your commitment to a program that is so

11 important to us all, and to your commitment to

12 organic integrity.

13 CHAIR CHAPMAN: Thank you. Questions? 

14 Thank you very much. Up next I have Stephen

15 Walker, and on deck, David Ferman. And if we are

16 ahead of schedule, I will still continue to call

17 you, so Marty Mesh, Rodrigo, you may go before

18 lunch.

19 MR. WALKER: Good morning.

20 CHAIR CHAPMAN: Start with your name

21 and affiliation.

22 MR. WALKER: I'm Steve Walker,
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1 Operations Manager at MOSA. Thank you for the

2 discussion on eliminating conversion of native

3 ecosystems to organic production. Over the years,

4 our certification work has assessed organic

5 operators' attention to conservation and

6 biodiversity protection with moderate success, but

7 now with some hindsight, we see we could have more

8 specifically addressed practices that precede

9 organic certification. We learn with continuous

10 improvement. It's time to do better.

11 Recently on many fronts, I'm giving a

12 lot of thought to deep organic values and the

13 challenges of setting boundaries. I'm inspired by

14 global organic principles as expressed by IFOAM

15 and by the NOSB. 

16 As a global organic community, we agree

17 that organic agriculture must consider how we

18 interact with living landscapes and relate to one

19 another, and organic ag should emulate and help

20 sustain living ecosystems, should ensure fairness

21 with regard to the common environment, and be

22 managed in a precautionary and responsible manner
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1 to protect the health and well-being of future

2 generations and the environment.

3 The NOSB's organic principles from 2001

4 stress that organic systems should be

5 ecologically, socially, and economically

6 sustainable. We are at odds with our principles

7 if we continue conversion of biologically valuable

8 lands to organic production. Our work should be

9 about improvement, about promoting new life, not

10 further agricultural destruction.

11 However, we know that by its very

12 nature, agriculture is destructive. To live,

13 we've got to eat something. Sometimes drawing

14 boundaries is hard, but as regulators, we're in

15 the business of drawing boundaries, and this

16 conversion issue is tough to regulate. Our

17 certification systems with their forms and

18 boundaries may not be the best method for

19 addressing this.

20 My friend, Dave Engel, gifted many of

21 us with his wisdom and wit. Early in my time

22 working with Dave, I remember he said, the biggest
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1 barrier to organic is the space between the ears. 

2 I think if people understand why organic and use

3 some discernment, then they work toward doing the

4 right thing, toward honoring deep organic

5 principles. 

6 Beyond that, we certifiers can regulate

7 if we have clear expectations that are practical

8 and enforceable. NOSB and NOP documents which

9 clarify expectations help to empower certifiers in

10 our enforcement.

11 Our written comments include more

12 detail on enforcement challenges, possible

13 sanctions and review tools, incentives, and

14 definitions. Thanks.

15 CHAIR CHAPMAN: Thank you. Harriet?

16 MS. BEHAR: Has MOSA seen the

17 conversion of native ecosystems in, you know, in

18 any of the operations that you've certified, new

19 people coming in and tearing up a native prairie,

20 or draining a wetland, or some - moving into an

21 area where there's been threatened or at-risk

22 species?
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1 MR. WALKER: Not to my knowledge, but

2 as we get older, we realize more and more what we

3 don't know, and we did send a village of us here

4 to help with some of these answers, but not to my

5 knowledge.

6 CHAIR CHAPMAN: Thank you very much. 

7 Up next is David Ferman with Marty Mesh on deck.

8 MR. FERMAN: Good morning. My name is

9 David Ferman representing NS Brands. So we

10 produced organic tomatoes employing several

11 hundred in Arizona. I want to thank you for your

12 time. I also realize that I am standing between

13 you and lunch, so we'll try to get you a little

14 time back.

15 We've heard some voices in this room

16 yesterday and today talking about what organic

17 means to farmers, to the soil, to plant biology. 

18 Thank you, but only scarcely have we really

19 discussed in-depth what it means to the consumer. 

20 We shared some information at the fall

21 NOSB meeting, and then there was a little

22 discussion yesterday, but I really want to delve
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1 a little deeper into the depth of that

2 conversation and, you know, communicate what the

3 consumer has said.

4 Last fall, we did a third-party survey

5 to understand consumers' thoughts on organic

6 issues. We didn't lead them. We asked for them

7 to lead us. I'd like to share their voices with

8 you now. The first question we asked them was for

9 their priorities in improving farming for organic

10 produce, and this was their answer. You know, the

11 top two items, reducing pesticides and

12 affordability. 

13 The second question really gets to the

14 heart of why they buy organic produce, and you'll

15 note that far down on the list, 10th out of 12,

16 was the consideration specific to soil. The fact

17 is that consumers make their purchase decisions

18 for organic based upon nutrition and health way

19 and far above the growing method.

20 The next thing we asked for the

21 consumer was what they think about their focus on

22 our efforts for improving organic produce, and on
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1 the far right, you see that 81 percent of these

2 consumers responded that they're in favor of

3 continuing to allow for container growing.

4 Now, only after we showed the consumers

5 these questions did we provide them a profile of

6 container growing. Yesterday there was some

7 discussion around what questions were led, so this

8 is where we provided the profile of container

9 growing to the consumer. Those other answers were

10 prior to this.

11 And then after we had this container

12 profile, we asked a similar question around if

13 they favor container growing. It actually moved

14 up from 81 percent to 91 percent in terms of their

15 favorability for continuing to allow containerized

16 growing methods.

17 Further, we asked the respondents how

18 their faith in the USDA would change if

19 containerized growing was banned, and you'll see

20 overwhelmingly that the faith in the USDA wouldn't

21 decrease significantly if we banned containerized

22 growing for organic producers.
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1 Then just to clarify in case there's

2 any additional questions or uncertainty, we had a

3 binary question for the consumer in terms of, you

4 know, what is organics about? And what you'll see

5 is that the consumer votes that organics is not

6 chiefly about improving the conditions of the

7 soil, but is about healthier products for them and

8 their families. Thank you.

9 CHAIR CHAPMAN: Thank you. Questions? 

10 Harriet?

11 MS. BEHAR: I know that surveys are

12 very much, it depends on the question that you're

13 asking, and so there was no question that asked,

14 do you support a system that does not promote -

15 does not offer pollinator health, or wildlife? 

16 I mean, you know, I mean, you could ask

17 a lot of different questions and skew, so I see a

18 few things missing in these questions that I don't

19 necessarily feel that really were reaching what

20 the consumers really want, because I think organic

21 consumers feel that organic farming is a place

22 where they can vote with their dollars for the
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1 improvement of the environment in an overall

2 sense.

3 MR. FERMAN: I understand, Harriet. 

4 There are some additional slides where the

5 consumer does break down how much the

6 environmental improvement weighs in on their

7 decision for purchase and for overall growth and

8 continued practices, and the consumer does want

9 the environment to be improved. 

10 Don't get me wrong. The consumer wants

11 improvement of the soil, overall reduction of

12 chemicals in run off. They want all of that, but

13 primarily their purchase decision is defined based

14 upon healthier products for them and their

15 families.

16 CHAIR CHAPMAN: Emily?

17 MS. OAKLEY: I just want to echo some

18 of what Harriet's saying because we've done

19 informal surveys with our CSA members about why

20 they purchase from us, and while health is a

21 concern, it's always bottom on their list, and top

22 on their list is environmental health and overall
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1 well-being of the world around them. So I think

2 it just depends on who you're asking, how you're

3 asking it, and the information that you're going

4 to get.

5 MR. FERMAN: Totally agree that there

6 is always or can be a sampling bias, so we tried

7 to be very unbiased in a general representation of

8 U.S. population of consumers aged 25 to 65, half

9 of which were under age 45, half of which over. 

10 This was all the screening criteria,

11 and that they had to have purchase decision for at

12 least half of the produce in their house. They

13 had to have purchased organic and planned to buy

14 organic again in the next 30 days, and that's

15 about it.

16 CHAIR CHAPMAN: Steve?

17 MR. BRADMAN: I was just going to ask -

18 oh, I'm sorry, Steve. You're next, okay. Just

19 it'd be interesting to see some narrative report

20 on this, and if you could post the questionnaire

21 and how it's organized and how the questions were

22 asked. I know you have them up there, but I'd
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1 like to actually see the paper. Was it done over

2 the phone?

3 MR. FERMAN: It was over the internet.

4 MR. BRADMAN: On the internet, so the

5 sample though could have been fairly random? I

6 mean, I'm sorry, not random. It would have been

7 kind of self-selected?

8 MR. FERMAN: I don't have all of the

9 details here. I do know that we did post the full

10 report in November, and I'm happy to send it out

11 again -

12 MR. BRADMAN: Okay.

13 MR. FERMAN: - so that you can see all

14 of the questions and screening criteria, and I

15 think it was like 1,750 consumers at random were

16 given the screening criteria, 500 of which

17 answered the survey that met the screening

18 criteria that I mentioned before, but happy to

19 post the full report.

20 MR. BRADMAN: Thanks.

21 MR. ELA: So I'm going to ask when you

22 buy a car, why do you buy a car? What do you look
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1 for in it? I know this sounds obtuse, but I'm

2 curious.

3 MR. FERMAN: For me, I mean, it's a

4 very personal decision, and so, and I've purchased

5 several cars. I have a family now, so that's

6 probably my primary consideration in terms of

7 space for my nine-year-old and, you know, her

8 friends and all of the gear. Prior to that, it

9 was probably horsepower.

10 MR. ELA: So, I mean, the problem I

11 have with questions like this is yes, only 20 or

12 14 percent of people say improving the soil. Your

13 answer, I mean, aren't you glad the car is

14 reliable? Aren't you glad it has a catalytic

15 converter and doesn't pollute? Aren't you glad it

16 has safety devices? 

17 I think these kinds of questions, we

18 tend to answer on kind of a top tier and we forget

19 all of the important aspects of a system, and so

20 I guess I'm having a hard time seeing, you know,

21 just seeing a survey I don't think often gets at

22 the real root of what we buy products for.
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1 MR. FERMAN: I mean, I understand that

2 there's obviously a long tail and it's impossible

3 to capture 100 percent of every consumer's - you

4 know, a census of every possible consideration. 

5 We tried to be broad-based with a lot

6 of the questions that we did ask, and not be

7 biased to afford the consumer the opportunity to

8 weigh in on multiple avenues and areas that

9 impacted their purchase decision, and you can see

10 that with many of the other slides like this and

11 other ones that we'll post. 

12 But, you know, the crux of - we wanted

13 to also not get down too much in the minutiae and

14 boil up to a 50,000 foot level so that we can

15 represent to you on a broad basis is it soil? Is

16 it health and nutrition? And between those two on

17 a binary perspective where they have to choose,

18 it's more health and nutrition, agreed that there

19 many other inputs.

20 CHAIR CHAPMAN: Thank you. Thank you

21 very much.

22 MR. FERMAN: Thank you.
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1 CHAIR CHAPMAN: Up next is Marty Mesh,

2 and that will be our last commenter before lunch.

3 MR. MESH: My name is Marty Mesh with

4 Florida Organic Growers and Quality Certification

5 Services. I actually wasn't going to comment to

6 help you get back on time, but because Tom

7 mandated that I be the last person, and I wanted

8 to bank my time for Jacksonville, and so I still

9 would like that request to be there so that I can 

10 have some more time in Florida.

11 CHAIR CHAPMAN: In proxies.

12 MR. MESH: And so then I thought, well,

13 maybe I should tell a joke. A hydroponic farmer,

14 a dirt farmer, and an aquaponic farmer all walk

15 into a bar, but then I thought, well, no, maybe

16 that wouldn't be appropriate.

17 So basically, I started farming in 1972

18 organically. For the new folks on the board, it's

19 a pleasure to be here. I think on behalf of the

20 community and the industry, we want to say thank

21 you for your volunteerism and agreement, and, you

22 know, they're not easy decisions. 
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1 You know, I don't know whether to stand

2 up here and say that as a dirt farmer, you know,

3 organic agriculture is about improving soil, but

4 then what about watercress? What about sprouts? 

5 What about this and how do you deal with stuff? 

6 I haven't read your recommendations,

7 but the questions aren't easy, and especially for

8 me having seen entities told by USDA that, you go

9 produce shrimp organically, and by God, put the

10 USDA logo on it and sell it, and they heard it

11 from Richard Matthews, the then-Acting Program

12 Director. They invested hundreds and hundreds of

13 thousands of dollars. 

14 We, the certifiers, made them feed only

15 100 percent organic feed, and then USDA changed it

16 and pulled the rug out from under them and told

17 them to get the logo off of the shrimp because of

18 the issues with salmon that were raised, and so

19 aquiculture was back to being decided upon later. 

20 Those companies went out of business. 

21 You know, and so I wrestled with

22 pulling the rug out from farmers that listened,
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1 that followed the regulations as they were

2 written, or that the industry had kind of gone

3 with that USDA's policies allowed, and then all of

4 a sudden saying, well, we changed our mind, or,

5 the community changed our mind. 

6 And so my focus has always been trying

7 to grow the pie instead of arguing about the

8 slice. I think that there's a market available to

9 nurture all types of farming operations. 

10 And we, as a certifier, we used to make

11 people, before the USDA entered into hydroponics,

12 is to say, you have to label it hydroponically

13 grown so that consumers have the knowledge and the

14 option to support dirt grown strawberries or

15 hydroponic grown.

16 But the decisions are really tough, and

17 I just want to say thanks, and why don't we go to

18 lunch and save the rest of my time to bank it for

19 Jacksonville if the Chair will so allow?

20 CHAIR CHAPMAN: Any questions for

21 Marty? You may still get questions. Okay, thank

22 you, everybody. Up after break will be Rodrigo
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1 first, followed by Steve Rosse. We will be

2 starting promptly at 1:30, so please be on time,

3 and we are in recess until then. Thank you.

4 (Whereupon, the above-entitled matter

5 went off the record at 12:14 a.m. and resumed at

6 1:31 p.m.) 

7 CHAIR CHAPMAN: All right, folks, we're

8 going to get started. If Board Members can take

9 their seats, and if the members of the public

10 could sit down, we'll be starting with Rodrigo

11 Ortega followed by Steve Rosse.

12 Rodrigo? It will be a moment, but I

13 just wanted to make sure you were here. So if

14 Board members could start taking their seats. 

15 Michelle, are you ready? Michelle, you're good? 

16 You're ready? Great.

17 All right, so we'll be starting with,

18 again, Rodrigo Ortega, on deck is Steve Rossi. 

19 Rodrigo, if you could start with your name and

20 affiliation for the record.

21 MR. ORTEGA: Good afternoon, my name is

22 Rodrigo Ortega, I'm a university professor in
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1 Chile. But today I'm acting as a consultant for

2 the company Green Health from Mexico.

3 A little bit of general context, we

4 have a growing work population, a reduced arable

5 land, climate change, degraded soils, loss of

6 biological diversity, contamination of soil,

7 water, and air, decrease in overall population,

8 growing market for healthy innocuous food.

9 Therefore, we need to look for new

10 sustainable site specific production alternatives

11 such as urban agriculture or hydroponics. If you

12 see the definition of organic agriculture, there

13 are many words in those definitions.

14 And I took some to highlight that in

15 order to show you some comments in favor of

16 organic hydroponics, first of all, hydroponics,

17 with or without substrate is an ecosystem itself.

18 There are cycles, ecological processes, and

19 biodiversity at the rhizosphere level.

20 There are plenty of evidence for that.

21 It is an innovative, site-specific way of

22 producing healthy food that responds to the
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1 current world's agricultural context. All

2 principles of organic agriculture, health,

3 ecology, fairness and care are met in that system.

4 It is more productive than soil based

5 organic agriculture, and the control condition. 

6 And there is an issue of organic matter here, but

7 many farmers are addressing that issue, applying

8 carbon in a liquid form as humic substances, for

9 example.

10 The usage of organic substrates such as

11 coconut coir or compost makes hydroponic even

12 closer to organic agriculture principles.

13 There is a little bit of information

14 there where you add organic matter, you put your

15 microbes and then you grade your biological

16 activity, the same way as if you do it in soil

17 based systems.

18 Regarding the use of liquid organic

19 fertilizer, it's not only an issue of hydroponics,

20 there are many intensive soil based organic

21 production systems in the world that rely on

22 organic sources, external, particularly liquid
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1 ones.

2 The biology of the system is not

3 affected by the source of organic fertilizer. It

4 can be either solid or liquid, and the effects are

5 going to be similar. And finally, there are many

6 organic nitrogen liquid sources available in the

7 market, widely used in organic agriculture.

8 As final comments, I would like to say

9 that the Board should stimulate inclusion of new

10 ways of producing healthy and innocuous food,

11 while preserving environment. It should look for

12 the nature and sustainability of each input

13 allowed in the system. For example, there is an

14 issue regarding humic substances derived from

15 leonardite or compost for example. Besides

16 they're innocutive, and -- that will be it.

17 CHAIR CHAPMAN: Thank you very much. 

18 Questions? Emily, Harriet.

19 MS. BEHAR: How is your system

20 different besides the inputs that you use from a

21 conventional hydroponic system?

22 MR. ORTEGA: Well, basically in Chile
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1 we have, and in Mexico we have different systems.

2 Some of them use substrate, and they use

3 containers where you put the solution into the

4 system. And the solution may have carbon,

5 nitrogen, and some other sources, some other

6 nutrients. But all of them are organic sources.

7 And on the other side you may have pure

8 hydroponics where you don't have substrate, for

9 example, and you are using about the same

10 principles.

11 MS. OAKLEY: You mentioned substrate of

12 coco coir or compost. As we discuss the potential

13 for some sort of compromise between the continuum

14 of growing only in the ground and no containers

15 whatsoever versus misting with aeroponics and

16 trying to maybe find some kind of middle ground,

17 how difficult would it be for current substrate

18 growers who are using just coco coir to include a

19 significant, let's say 50 percent or more

20 component in their containers to include compost?

21 MR. ORTEGA: Well, there are some

22 farmers that have included compost in their
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1 system, and they are doing mixtures, for example,

2 of soil and compost, and they have reached up to

3 50 percent of the total volume using compost. So

4 it's an issue that can be addressed, I think.

5 CHAIR CHAPMAN: Harriet? Sorry. A6 Dae.

7 MS. ROMERO-BRIONES: So you had a

8 sentence in your presentation about cycles,

9 ecological processes, and biodiversity in the

10 rhizosphere.

11 MR. ORTEGA: Yes.

12 MS. ROMERO-BRIONES: And we've heard

13 several comments prior to your presentation, and

14 it says plenty of evidence. Can you explain

15 plenty of evidence?

16 MR. ORTEGA: Yes. Actually, I have

17 worked in this area for 20 years. And I did a

18 quick literary review on this subject before

19 coming here, and I found out that there are many,

20 many papers showing that there is a lot of

21 biological activity, measured --- and somatic

22 activity in pure hydroponic systems. So that is
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1 why I'm referring to that.

2 MS. ROMERO-BRIONES: So your plenty of

3 evidence refers to your literature review?

4 MR. ORTEGA: Yes.

5 MS. ROMERO-BRIONES: Okay, and where

6 can we find that?

7 MR. ORTEGA: Well, I can send you the

8 information. I just found, for example, some

9 information from Sweden where they have done some

10 work. In Chile we have done some work also with

11 some companies, you know, measuring biological

12 activity under hydroponic systems. And it shows

13 that it's very similar to what you would find in

14 soils.

15 CHAIR CHAPMAN: If you could send that

16 research through Michelle or through the Open

17 Docket, it would be much appreciated.

18 MR. ORTEGA: Okay, I will send it.

19 CHAIR CHAPMAN: Any additional

20 questions? Thank you.

21 MR. ORTEGA: Okay, thanks.

22 CHAIR CHAPMAN: Up next is Steve Rosse
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1 followed by Ian Justus.

2 MR. ROSSE: Hello. My name is Steve

3 Rosse. I am the President of the Biodegradable

4 Products Institute Board of Directors. We

5 appreciate the NOSB's dedication to ensuring the

6 integrity of the organics industry.

7 You have heard from BPI many times over

8 the past few years when we have petitioned to have

9 biodegradable mulch films added to the national

10 list. The NOSB approved biodegradable mulch film

11 back in 2014 confirming that it met criteria set

12 out by the organics industry as a tool in the

13 toolkit for farmers.

14 But an amendment calling for the

15 material to also be bio-based has caused

16 significant confusion. Bio-based content has no

17 impact on biodegradability, whether that's a mulch

18 film or compostable products.

19 The NOP policy memo after the fact

20 stated that the mulch film must be 100 percent

21 bio-based which an OMRI report said does not

22 currently exist. We are asking for your help in
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1 addressing this amendment.

2 Our preference would be to remove the

3 requirement to test for bio-based content

4 altogether, as it isn't necessary for

5 biodegradability, or at least to clarify the

6 amendment specifying that bio-based content be

7 tested without a minimum.

8 If a minimum needs to be set, make it

9 reasonable based on OMRI reports. Again, the bio10 based content in mulch film or compostable

11 products does not impact any aspect of the

12 biodegradation process or the quality of the soil. 

13 Please act to change this amendment. Thank you.

14 CHAIR CHAPMAN: Thank you. Any

15 questions? Harriet?

16 MS. BEHAR: Do you think that the

17 biodegradable mulch needs any bio-based

18 ingredients?

19 MR. ROSSE: I'm not sure of the

20 specific chemistry of the mulch. I think our

21 members who will probably be up soon can have

22 probably a more detailed explanation. I'm not
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1 sure of the exact percentage.

2 MS. BEHAR: It's just a question of,

3 you know, if it's biodegradable, but still from

4 petroleum, is that okay with you or do you want to

5 see a biological component in the product?

6 MR. ROSSE: Yes, since the focus is

7 really, you know, bio-degradation right at the

8 point that it's the beginning of life source I

9 don't think really is pertinent. Right? We're

10 just looking at the degradation in the soil.

11 CHAIR CHAPMAN: Joelle?

12 MS. MOSSO: Just a quick question.

13 CHAIR CHAPMAN: Over -- I'm sorry.

14 MS. MOSSO: Yes. Regarding the

15 petroleum based inputs that are the substrate for

16 making it, is that process to make it --- do you

17 create more petroleum based substances, or are you

18 recycling some already made petroleum based

19 substances to make your mulch?

20 MR. ROSSE: Again, I'm not specific on

21 that.

22 MS. MOSSO: You're not the guy.
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1 MR. ROSSE: Our members will have that

2 information.

3 CHAIR CHAPMAN: Thank you very much.

4 MR. ROSSE: Thanks.

5 CHAIR CHAPMAN: Next up is Ian Justus

6 with Ruth Watts on deck. Ian, if you could start

7 with your name and affiliation for the record.

8 MR. JUSTUS: Hello. I'm Ian Justus and

9 I work with Driscoll's. Thank you for the

10 opportunity to provide public comment on the

11 container production discussion document.

12 I would like to talk about the

13 definitions in particular. This new definition of

14 the term recalcitrant is being misinterpreted. 

15 Coco, peat, and wood fiber are all colonized and

16 broken down by microbial organisms.

17 The composition of lignans and

18 cellulars are the primary drivers of how much can

19 be broken down -- please don't take my photo -- in

20 the container production with solid substrate.

21 This stable organic matter is serving

22 as the structure, veracity, microbial surface
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1 area, and nutrient holding capacity. With this

2 definition, you can say that a large percentage of

3 soil components are biologically calcitrant.

4 But this stable organic matter serves

5 critical functions in soil and container systems.

6 Container and soil growers are adding additional,

7 non-stable organic matter to serve as a continual

8 source of nutrition.

9 The definition of annual and perennials

10 is not adequate. This definition overlaps for all

11 of Driscoll's crops. It seems there are a lot of

12 questions that are off topic and looking for

13 alternative reasons to disallow.

14 We need to answer and focus on

15 questions about the roots of the dynamics, as this

16 is a large task. There needs to be clear,

17 separate classifications of systems that grow in

18 liquid substrates versus solid substrates.

19 Many of these solid substrates mixes

20 contain all the components to be classified as a

21 soil and can satisfy OFPA. I do not believe it is

22 the right direction to mandate additional inputs
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1 to any grower that is not necessary for producing

2 healthy crops. We should all strive to reduce

3 inputs, as all inputs have environmental impact.

4 We need a definition for inputs, as

5 there seems to be confusion around this. We

6 absolutely need a better definition of compost. 

7 We need to clarify the definitions for nutrient

8 solution, recalcitrant, and soil especially.

9 The NOP cannot easily regulate or rule

10 make off the current definitions or

11 recommendations. To determine and enforce this 20

12 percent rule, you have to know how much of it was

13 applied, the composition and amounts of every soil

14 input for every acre, and do the math.

15 Who will do this? Our over-audited

16 growers, our overburdened certification agencies,

17 or our poorly funded government agencies? 

18 Limiting to a percentage is also likely to

19 encourage over-application of fertilizer.

20 It is clear to me that a key question

21 is missing. Does the biology, nutrient

22 availability, and plant uptake work the same way
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1 in organic soil and container systems? Do we all

2 realize that no matter what starting source of

3 fertility system, soil, container, or hydroponics,

4 the vast majority of nutrition ends up taken

5 through liquid?

6 Controlling the allowed inputs is the

7 way to regulate how quickly nutrients become

8 available. Everyone wants specifics on container

9 practices. The reality is that these systems are

10 in their infancy of the understanding.

11 No one knows with certainty what is the

12 right rate of compost, how much of each type,

13 solid or liquid, nutrition is right for their

14 crop. Soil growers still struggle with these

15 questions every day, and it's different for every

16 site and situation.

17 As the leader of research and

18 development in soil and container systems, I can

19 tell you that container production is the first

20 significant advancement that's allowed us to

21 reduce inputs without harming crop quality.

22 CHAIR CHAPMAN: Thank you. Thank you,
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1 Ian. So questions, I have Francis, then Emily.

2 DR. THICKE: Thank you. Can you help

3 us understand a little better how the Driscoll

4 system works? In particular, do 100 percent of

5 the nutrients come from liquid form in these

6 container systems, and does any of it come from

7 the soil media? And what is the makeup of the

8 nutrient liquid, liquid nutrient?

9 MR. JUSTUS: I would be happy to help

10 with that. So one key designation is that

11 Driscoll's is not the fruit producer. We have a

12 network of independent growers that run their own

13 businesses. And actually there's many different

14 growers. And growers kind of always choose their

15 own path.

16 DR. THICKE: Does Driscoll's grow any

17 at all themselves?

18 MR. JUSTUS: We only grow the nursery

19 plants. Driscoll's does not produce the fruit

20 production. What I do is I work directly with the

21 growers in our research and development and

22 agronomic standpoint. So I've seen actually every
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1 single container operation that's certified

2 organic within our network.

3 I can tell you that they're all

4 currently in salt substrate, and that's pretty

5 much the plan. The grower practices I wish were

6 less narrow, or excuse me, more narrow because

7 it's a big variance.

8 But pretty much majority of everyone's

9 using blends of mixes rather than sole sources. 

10 They're using composts, they're using top dressing

11 pelleted. They're injecting, you know, liquids

12 depending on the operation how much and what it

13 needs.

14 DR. THICKE: What are they made out of,

15 these pellets and liquids?

16 MR. JUSTUS: Feather meal, bonemeal,

17 whatever is allowed on the list. You know, the

18 growers have enough to really handle. How can

19 they possibly navigate what product is more

20 organic versus another when everything is on the

21 list and looked at in a similar way.

22 They're kind of looking at the best
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1 option, the best economic option and trying to

2 figure out how to grow the best crop that they

3 can. That is their focus, not to really, like,

4 navigate the politics of this source is better

5 than that one.

6 MS. OAKLEY: So, Rodrigo Ortega who was

7 just up here was talking about a substrate of coco

8 coir and compost as well. And you also just

9 mentioned compost in the containers.

10 So can I ask you the same question, how

11 difficult would it be to require a 50 percent or

12 greater compost component within the containers if

13 we were able to find some kind of compromise,

14 like, middle ground in this continuous dialogue

15 for your producers to enact. And then I have a

16 follow up after that.

17 MR. JUSTUS: Okay, great. Yes, as I

18 mentioned in the comment, we really need a better

19 definition of what is considered compost. That

20 would be a big driver and determiner because right

21 now it's actually really vague and you could

22 compost coco coir, you could argue peat moss is
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1 composted, any number of wood fibers are composted

2 products. And is that the same thing as others

3 because that all fits under the definition

4 currently as we understand it.

5 Fifty percent is a very extreme rate of

6 compost I would say if that's readily break down

7 compost because when you break down, you lose

8 structure. You lose oxygen, you lose veracity. 

9 And that's not the way to make a healthy crop.

10 And I also think it's important that we

11 separate soil from fertility program because those

12 are two independent things, right? The substrate

13 blend is the soil mixture. The compost and the

14 other adjustments are the fertility program

15 associated with it.

16 And you know, it's all input driven. 

17 Like, people have talked about building soils and

18 things like that, but they are building with

19 inputs.

20 MS. OAKLEY: So just to clarify, are

21 you -- I couldn't totally understand. Are you

22 saying that if we had, for example, a definition
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1 that was understood and known and agreed upon

2 about compost, for example, and made the

3 requirement of 50 percent within a container,

4 would that be something that was feasible?

5 MR. JUSTUS: I can tell you that 50

6 percent is too high for what I think the Board

7 thinks is compost of, like, a fertilizer source of

8 nutrition solely rather than a structural piece

9 because then basically you're going to lose 50

10 percent of your structure within a short amount of

11 time.

12 And also it's really best, you know,

13 I've done a lot of work on nutrient uptake studies

14 on when the plans actually need fertility, and

15 it's not up front when they're young, it's more

16 towards maturity.

17 And so putting all of it up front is

18 not the best way, especially since we're all

19 perennial crops, it's better to distribute that

20 more out evenly. We prefer a much smaller

21 percentage in some sort of top dressing regime or

22 something to be more practical and better for the
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1 environment and for the plants.

2 MS. OAKLEY: So then my second question

3 was I think I remember from the webinar that 14

4 percent of Driscoll's production is organic. 

5 Could you tell me what percentage of that is in

6 ground versus container grown?

7 MR. JUSTUS: In container grown, it's

8 got to be less than one or less than half a

9 percent. These systems are relatively new and

10 small in our overall scheme. And it's really, the

11 majority of it is actually blueberries that's in

12 containers currently.

13 And of our total pool of fully

14 organics, that's actually a really small -- all of

15 our strawberries currently are in soil and that's

16 one of our biggest organic crops as well as

17 raspberries. And there are some container

18 raspberries, but relatively small in the scheme,

19 less than half a percent I would estimate.

20 CHAIR CHAPMAN: Harriet?

21 MS. BEHAR: So getting away from soil

22 that the plants are growing in, I've been to some
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1 of the Driscoll, some eco farm tours and things

2 like that. And I've noticed that there's a lot of

3 use of landscape cloth, that the containers are

4 sitting on the landscape cloth.

5 And many times too there's hoops where

6 there's plastic over the blueberries as well. And

7 so is that landscape cloth ever picked up? I mean

8 it's obviously probably not picked up at the end

9 of the growing season.

10 And is there any way to prevent it

11 from, you know, UV degradation and kind of having

12 pieces of that all over the field, as well as the

13 plastic that is used for the hoops, how is that

14 managed because I've seen some things that are a

15 little concerning there as well.

16 MR. JUSTUS: Yes, and these two things

17 I think are actually independent of the container

18 issue specifically because if you're growing,

19 let's say, organic blueberries in the soil you

20 will have landscape fabric and you will probably

21 have tunnels.

22 It really depends on the area you're
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1 growing in. But in a lot of California areas you

2 will have tunnels. It's kind of a standard

3 production system that has just kind of come to

4 fruition.

5 For example, we're, like, the biggest

6 fresh raspberry producer and they're 100 percent

7 under hoops. It's just how the production system

8 has evolved, no matter how you're growing it. 

9 Otherwise you're pretty much out of business.

10 So the landscape mat in particular is,

11 depending on the product, a five to ten year

12 lifespan in full sun. And actually, that plastic

13 blocks UV light. So the lifespan is significant,

14 and the grower always removes it from site if he's

15 going to move.

16 And of course, blueberries is a

17 perennial crop, so that container is there for

18 many, many years. And that landscape fabric is

19 significant, you know, because blueberries are

20 shallow rooted so you would have it for soil just

21 for weed protection or you damage your roots just

22 doing hoeing and things like that.
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1 Or, it's also to block the weeds coming

2 up from around the containers. And that also

3 allows for actually interaction with the soil

4 biology below because there's water coming out of

5 the pots, there's organic matter coming out of the

6 pots.

7 That's actually, there's microbe

8 populations present below that. Tons of different

9 organisms living under that mat. And then it

10 also, in many cases we have an open soil area

11 there where we can put our pruning, because all

12 perennial plants are pruned annually at least, and

13 you need to incorporate that. So then they'll

14 incorporate it into the soil.

15 CHAIR CHAPMAN: Any other questions? 

16 Asa?

17 MR. BRADMAN: Yes, you mentioned that

18 container systems was one of the first methods,

19 I'm not quite sure how you put it, at the table

20 that allowed you to reduce inputs for production.

21 And so my question, I have two questions related

22 to that.
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1 One, are you using different inputs for

2 in-ground production. And then two, again if you

3 could clarify what you meant by the container

4 growing allowed you to reduce inputs. Was that

5 compared to soil or what?

6 MR. JUSTUS: Yes, thank you for that

7 kind of got cut off. You know, I've been doing

8 research for both soil and then we also started

9 doing containers. It's kind of the natural

10 progression of research, it's just, it made sense

11 as a question to ask and it was allowed.

12 And so when we made big breakthroughs

13 in soil, that actually made a significant

14 difference across many operations. It usually

15 involves increasing inputs over the total system.

16 Anaerobic soil disinfestation for

17 example is a method that a lot of growers uptook.

18 But you're talking about a significant amount of

19 additional carbon added, a significant amount more

20 water added, things like that. That's what it

21 took to make the difference.

22 In this case, many of our growers
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1 actually pretty much have soil and container

2 production organics. That's actually very, very

3 common. And many of them actually choose to use

4 similar products they're comfortable with.

5 The big, big in particular decrease is

6 water, and then in many cases overall tons of

7 input applied, however you want to look at that,

8 compost, fertility, everything is decreased in the

9 systems as well, container.

10 CHAIR CHAPMAN: Steve?

11 MR. ELA: Would you be willing to

12 submit to us, I mean, Emily was kind of, you know,

13 you said 50 percent compost was probably too much.

14 I mean, could Driscoll's submit in public comment

15 or the open docket what you would feel comfortable

16 with for a soil/compost mix?

17 I mean, you're talking about some kind

18 of structural component. Just so that we would

19 have something. I mean, we're obviously struggling

20 with what works for the industry. And I think

21 unless -- instead of us shooting a dart at the

22 board, have the industry actually tell us yes,
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1 this would be a livable mix, would be very useful.

2 MR. JUSTUS: Yes, so this is something

3 we've actually talked about with our growers. 

4 We're very engaged with our growers on all these

5 issues. We're making a lot of efforts to be

6 aggressive and look at these different blends. So

7 we're already testing different rates of compost

8 and things like that, different types of compost.

9 As I asked before, really I think the

10 most important thing is a real solid definition of

11 what can be considered compost because there's

12 always a stable and unstable fraction of this. 

13 And the more unstable fraction, the lower

14 percentage we're going to need to impart.

15 And so, and the number keeps going up.

16 There's another thing that's kind of perplexing to

17 us because ten percent was kind of the first

18 number thrown out. Then I heard 20, but now I'm

19 hearing 50. And so those are kind of like, the

20 numbers just, as I understand it, keep kind of

21 going up.

22 We're kind of working on assumptions of
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1 a ten to twenty percent of an unstable type

2 compost that are going to break down fairly

3 rapidly. And I can tell you that in these

4 container systems, I mean, it's a warm

5 environment.

6 It's high oxygen, there's water

7 availability, there's actually really good

8 temperature. So these processes actually happen

9 really fast. And we can actually already see in

10 the tests, like, basically just the decrease of

11 the volume which tells us we're getting compaction

12 and things like that.

13 So we would have to top dress and do

14 things like that over time because you can have

15 composts that have a lot of structural integrity

16 or don't, but I really don't think that's what you

17 guys mean by compost, because you could just

18 compost coco coir, you could compost peat moss. 

19 But I don't think you would find that acceptable

20 either.

21 So we kind of need clarity on what you

22 mean on compost specifically.
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1 MR. ELA: I mean, I guess if you could

2 submit to us so we're not -- we're trying to

3 understand. So anything you could submit to us in

4 that topic I think could be useful.

5 MR. JUSTUS: Yes, we would be happy to

6 do that because the definition I read is, you

7 know, you have to apply nitrogen to a plant based,

8 and you have to turn it, you have to maintain a

9 turning temperature for a certain amount of time.

10 And, like, that plant based matter is really

11 broad. So I think we can try to work on that

12 together. I would be happy to do that.

13 CHAIR CHAPMAN: Thank you very much.

14 MR. JUSTUS: And I sent my comment to

15 Michelle and ask her to email it to all of you.

16 And it includes my contact information. So if you

17 want to reach out.

18 CHAIR CHAPMAN: Thank you, thank you

19 again. Yes. We have that in the docket as well,

20 so thank you. Up next is Ruth Watts and on deck

21 is Jason Kamimoto.

22 MS. WATTS: Good afternoon. My name is
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1 Ruth Watts and I work for BASF Biopolymers

2 Business. I would like to thank the Board for

3 this opportunity to comment on the biodegradable

4 mulch films.

5 BASF Biopolymers makes polymers which

6 are fully compostable by microbes. We therefore

7 serve markets such as composting and agriculture

8 where this end of life makes sense. We thank you

9 for your questions today. In our minds, you are

10 asking the most important questions regarding soil

11 health and stewardship.

12 Today I would like to address the use

13 of the word petroleum. Over the years we've used

14 this word incorrectly in informal uses of language

15 because in the past it was often indeed the case

16 that commercial materials made from fossil sources

17 were not fully biodegradable.

18 We understand that there are

19 restrictions on the use of certain materials in

20 organic farming because it is not always clear

21 what impact some materials might have on the

22 environment.
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1 However, the case of biodegradable

2 mulch film is different. In this case, there are

3 clear standards which demonstrate full

4 biodegradation. These are the first two testing

5 requirements which are readily included in the

6 regulation under 2205.2.

7 We thank the Board for considering this

8 important science as the foundation for approval

9 of mulch films, as it ensures the integrity of

10 biodegradable farm inputs. As an example, Dr.

11 Schlegel this morning mentioned bio-based

12 polyethylene. It is not biodegradable. It would

13 therefore not pass these test requirements.

14 Secondly, I would like to address the

15 topic of accumulation cited in the OMRY technical

16 evaluation report. This topic was misunderstood

17 in the TER, and we have addressed this fully in

18 our public comment 1760.

19 We request that you please revisit this

20 document and review sections beginning at Line 29,

21 86, 124, and 152. As with other production aid,

22 we encourage farmers to test these products to see
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1 if it adds value to their crops, taking into

2 account their existing production tools and soil

3 conditions.

4 This is already required in the

5 regulation under 205.203, and organic farmers are

6 already managing soil fertility and crop

7 nutritions under this practice standard.

8 Regarding residents' time in the soil,

9 one of our references from an external

10 organization called OWS which is the Organic Waste

11 System, they're out of Belgium, shows that

12 biodegradable mulch films can degrade more rapidly

13 than straw.

14 In fact, in many cases, the film is

15 already highly fragmented and visibly

16 disintegrating, which is the picture, I don't know

17 if you can see it, by the end of the growing

18 season.

19 Once it is tilled into the soil, the

20 biodegradation proceeds much more quickly. Proper

21 use of this film includes optimizing film

22 thickness to ensure field performance and timely
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1 biodegradation.

2 Ultimately, we are stewards of the

3 soil. We are stewards of our technology, ensuring

4 it finds applications such as mulch film where

5 technology adds value to the farmer. What cannot

6 be separated from this performance in the field is

7 the ability of the polymer to biodegrade in field.

8 We cannot compromise on performance, nor end of

9 life. Thank you.

10 CHAIR CHAPMAN: Thank you. Questions? 

11 Asa?

12 MR. BRADMAN: I have two questions. 

13 One, is it possible to manufacture a bio-based

14 film -- one thing that wasn't clear to me from an

15 earlier presenter was why do we need, you know,

16 why is there such a large proportion of petroleum

17 based material.

18 MS. WATTS: Petroleum? That's a very

19 good question.

20 MR. BRADMAN: Is it a texture thing or

21 flexing?

22 MS. WATTS: Yes, very good question. 
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1 So ultimately when you talk about mulch film, it's

2 got to be able to hug the soil, they've got to be

3 able to apply it, certain of the bio-based

4 polymers that are added to it can add structure to

5 it and it can add also some mechanical properties.

6 So it's a combination of how the

7 farmers apply it, that it stays in place. And so

8 the petroleum base material, which by the way, the

9 answer to your question, Harriet, you can use 100

10 percent petroleum based material that will meet

11 those requirements, 100 percent biodegradable in

12 the soil.

13 In fact, the first biodegradable

14 polymer in 1997 was 100 percent petroleum based.

15 So you need different additives to provide certain

16 functionalities to the film so that it will, one,

17 it can be applied, it can last long enough to

18 provide the weed barrier technology, and then at

19 the end, ultimately biodegrade into the field.

20 So it's a combination of different

21 things, and that's really what differentiates the

22 different competitors as to what they add, and in
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1 the aspect of the performance, the functionality.

2 But all of them will biodegrade.

3 CHAIR CHAPMAN: Dave?

4 MR. BRADMAN: I have one more question

5 if that's okay?

6 CHAIR CHAPMAN: Briefly.

7 MR. BRADMAN: Second question is so

8 right now in this stage, and earlier, you had the

9 material that was intact.

10 MS. WATTS: That was what? I'm sorry.

11 MR. BRADMAN: The material was intact.

12 MS. WATTS: Yes.

13 MR. BRADMAN: I mean, in that picture

14 it's breaking down. In terms of rain or runoff,

15 are there any water soluble components that could

16 be washed off the field, particles, or anything

17 that's water soluble and carried into surface

18 water and things like that?

19 MS. WATTS: No. Good question. It is

20 not water soluble. However, it is through

21 hydrolysis that helps enact the beginning of the

22 biodegradation. Just like us, we need water, we
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1 need temperature, we need enzymes, we need things

2 to help start that biodegradation. So water is

3 important, but there's no runoff. It helps the

4 microorganism to begin to basally eat that and

5 then start digesting it.

6 MR. BRADMAN: Okay, so there's no water

7 soluble components?

8 MS. WATTS: No there is not. No there

9 is not.

10 MR. BRADMAN: Do you know what the KOW

11 is of any of the --

12 MS. WATTS: The what?

13 MR. BRADMAN: The KOW, the optimal

14 water coefficient.

15 MS. WATTS: I would defer that to Dr.

16 Schlegel at some point afterwards.

17 MR. BRADMAN: Thank you.

18 CHAIR CHAPMAN: Thank you, Asa. Dave?

19 MR. MORTENSEN: Ruth, I was curious,

20 what's known about impurities in the synthesis of

21 the film, impurities, that would be not carbon or

22 oxygen?
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1 MS. WATTS: Again, if I can defer that

2 maybe to Dr. Schlegel, she's the microbiologist.

3 But we do not have any impurities in the process,

4 even in the master batch of the carbon black for

5 instance with our particular material.

6 You know, carbon black may have some

7 hydrocarbon leftover. But we do not do that, we

8 actually filter that out to make sure it's in the

9 purest form. In fact, the material that we use is

10 FDA approved.

11 CHAIR CHAPMAN: Thank you very much. 

12 And if you can either use Michelle or the Open

13 Docket to get us those answers, that would be

14 greatly appreciated. We do need to move on at

15 this time, so thank you very much.

16 MS. WATTS: Okay, thank you very much.

17 And please, we'll be available and look forward to

18 your questions.

19 CHAIR CHAPMAN: Next up is Jason with

20 Tracy Favre on deck.

21 MR. KAMIMOTO: Good afternoon, Board.

22 My name is Jason Kamimoto, I'm the Vice President
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1 of Sales and Marketing at Rocket Farms, and I

2 thank you for this opportunity to share my

3 comments.

4 At Rocket Farms we grow organic potted

5 living herbs, and have a long history of growing

6 on the northern California coast with a strong

7 commitment to sustainable growing practices,

8 resource conservation, and our local community.

9 Today, I'm here to voice our belief

10 that our potted organic living herbs are in fact

11 legitimately organic, and ask you to consider our

12 product separately and independently from the

13 aeroponic, hydroponic, and aquaponic product

14 discussion.

15 Firstly, what is an organic potted

16 living herb? I brought a sample, an example today

17 of what we grow and ship. This living basil plant

18 is one of many organic living herb products we

19 produce and ship year round.

20 We start this plant from organic, non

21 GMO seeds, plant, germinate it in plug trays, and

22 then finally transplant it into its final
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1 container, or pot.

2 We grow this plant in an organic peat

3 moss based media, medium, and irrigate with

4 organic fertilizer. Environmental controls,

5 release of biological insects, and scouting are

6 all part of our integrated pest management

7 program.

8 When needed, organically certified

9 fertilizers are used to control disease and pests.

10 Therefore, we've fulfilled the original intent of

11 the organic movement, and meet all requirements of

12 organic certification.

13 This organic potted living herb is

14 grown and packed at our facility and shipped to

15 our customers. Over the years we have developed

16 a very large following of consumers who are very

17 passionate about our products.

18 From seed to table, we are providing

19 them living, organic, edible plants they can

20 display on their kitchen counter and enjoy over

21 the course of time, and even plant outside in

22 their gardens.
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1 Our product is unique and special. 

2 Organic living potted herbs are better for the

3 environment, consumers, and employees, due the

4 absence of synthetic chemicals. We're growing a

5 living herb in a pot that cannot be grown in the

6 Earth's crust, and therefore should not be

7 confused with field, aeroponic, hydroponic, or

8 aquaponic grown products.

9 Our potted living plant gives consumers

10 access to an organically grown living plant they

11 can enjoy over time. Thank you for your

12 consideration.

13 CHAIR CHAPMAN: Thank you. Questions? 

14 Asa and then Steve.

15 MR. BRADMAN: I have kind of two

16 questions, one with respect to -- I should

17 disclose that I buy those.

18 MR. KAMIMOTO: Oh, thank you.

19 MR. BRADMAN: We use them at our house.

20 We make salads from them. You consider that

21 organic. If you were to cut the basil off at the

22 base and put it into a plastic or paper, other
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1 packaging and sold it separated from the soil,

2 would you also consider it organic?

3 MR. KAMIMOTO: We do have a sister

4 company, a fresh cut herb company, Rocket Farms

5 Herbs that does follow that protocol. It's an

6 organically grown plant and then cut and packaged

7 in a clamshell or a bag.

8 MR. BRADMAN: Okay, thank you.

9 CHAIR CHAPMAN: Steve?

10 MR. ELA: Just to be clear, so I mean,

11 you're separating yourself from pure hydroponic

12 system, I mean, into some sort of container?

13 MR. KAMIMOTO: Yes, because it's a soil

14 based medium.

15 MR. ELA: Do you have any sense, I

16 mean, you've heard the previous discussion of what

17 -- where would we draw a line as a board between

18 hydroponic and container?

19 MR. KAMIMOTO: It's a good question,

20 and I don't -- it's a good question. You know,

21 really all I'm prepared to discuss here today is

22 just really to call out the protocols and
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1 practices we're using to grow in a soil based

2 medium and not necessarily get into a conversation

3 about how it stands up next to hydroponics or

4 aeroponics.

5 CHAIR CHAPMAN: Thank you very much. 

6 We have one more question. Harriet?

7 MS. BEHAR: How do you think your

8 customers would react if the label on your product

9 would be hydroponic, grown with organic inputs?

10 MR. KAMIMOTO: I'm sorry, could you

11 repeat that?

12 MS. BEHAR: So instead of the label

13 saying organic basil, it would say basil, or

14 hydroponic basil grown with organic inputs?

15 MR. KAMIMOTO: That's another great

16 question. I would almost point to maybe some of

17 the survey that was reviewed earlier before lunch

18 by Mr. Ferman. At least his consumer survey noted

19 that consumers are interested in organics, and I

20 don't know if they had yet a clear distinction

21 between hydroponic or soil based. So I don't know

22 how they would react.
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1 CHAIR CHAPMAN: Thank you. Thank you

2 very much for your comments.

3 MR. KAMIMOTO: Thank you.

4 CHAIR CHAPMAN: Up next is Tracy

5 followed by Stanley Edwards. Tracy, I don't know

6 if we've met you before, but if you could state

7 your name and affiliation for the record.

8 MS. FAVRE: Hello everyone. I'm Tracy

9 Favre, I'm the Director of Certification Services

10 for Quality Assurance International. I just want

11 to say what an absolute pleasure it is today to

12 speak to you from this side of the rope.

13 I'm here speaking today on the

14 discussion document for clarifying the term of

15 emergency use in parasiticides. Specifically I

16 want to answer the four questions posed in the

17 livestock subcommittee's discussion document.

18 On the screen here you're going to see

19 a dung beetle that's in my pasture, busy doing its

20 work. So first of all, the first question was

21 does the term emergency need to be defined.

22 QAI does agree that the definition of
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1 the term emergency would help certifiers more

2 uniformly assess when conditions exist that

3 warrant emergency measures. I think you're pretty

4 much consistently hearing that from certifiers

5 across the board.

6 Second question was if so, how should

7 the term emergency be defined. So I thought it

8 would be useful for us to look at how other

9 organizations define the term emergency, including

10 the AAFCO, the American Feed Control Officials

11 association. And this is a voluntary membership

12 of local, state, and federal agencies that are

13 charged by law to regulate food and drugs for

14 animals.

15 And this actually was some of the

16 information that we used largely to help set some

17 of the withholding periods when we did make the

18 modifications for the parasiticides originally.

19 So the AAFCO definitely for emergency,

20 and this actually specifically applies to feed but

21 I think we could take some lessons for it here for

22 parasiticides, is to provide a coordinated and
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1 consistent approach, I'm paraphrasing, and using

2 emergency as defined as unforeseen or sudden

3 occurrence requiring immediate action to protect

4 against substantial risk to animal or public

5 health.

6 And it goes on to speak about for food

7 and public safety and things like that. But

8 there's two key points here that I think warrant

9 discussion here for emergencies for parasiticides,

10 and maybe even more broadly in organic, and that

11 is unforeseen or sudden.

12 So one of the challenges, now that I

13 have to wear a certifier hat, is there's all these

14 circumstances across the country in a variety of

15 different operations, and it's almost impossible

16 for you as a Board or for the Organic Program to

17 try to assess and codify, in guidance or

18 annotations, how we might address those.

19 So as long as we have some parameters

20 around what emergency is, being unforeseen and

21 sudden, meaning it could be something that could

22 be preventable doesn't qualify. I think that
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1 gives us some framework to talk about.

2 So first of all, as we all would agree

3 I think, prevention is best. And I agree with the

4 earlier comments made by some of the other

5 certifiers that prevention is the first place that

6 we start as certifiers to look at preventing

7 emergencies.

8 So everything from grazing planting,

9 breed selection, et cetera, would be what we want

10 to look at. And I'm happy to answer any

11 questions.

12 CHAIR CHAPMAN: Thank you, Tracy. 

13 Those three minutes sneak up on you, don't they?

14 MS. FAVRE: They did.

15 CHAIR CHAPMAN: Harriet, Ashley, A-Dae.

16 MS. BEHAR: So beyond the definition

17 that's with AAFCO, wouldn't that, for organic

18 since we're so systems based, wouldn't something,

19 an addition to that there was a, that the system

20 in place failed or something like that, besides it

21 just being unforeseen or sudden.

22 We really want people to be building
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1 those systems in place and relying on the systems

2 for parasite control. And that the emergency is

3 when that would have failed due to whatever, you

4 know, climate condition, you know, whatever.

5 MS. FAVRE: I don't think the emergency

6 definition should be considered in a vacuum. 

7 You're already going to have an organic systems

8 plan that's agreed to between the operator and the

9 certifier that would address, for instance, an

10 escalation of application of different measures.

11 And so I think this is just an extra

12 layer of clarification on top of that. I think

13 those things that you're talking about, having the

14 system plan already in place, there's already

15 measures for that to allow within the organic

16 systems plan. But yes, I would agree that you

17 have to have both.

18 CHAIR CHAPMAN: Ashley?

19 MS. SWAFFAR: So I would just like to

20 say bless your heart, those three minutes go

21 really fast --- 

22 MS. FAVRE: They do.
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1 MS. SWAFFAR: -- when you're limited.

2 But so on that definition, that AFCO definition,

3 do you feel like that's the best definition for

4 emergency, or do you think it needs more finessing

5 than what you've showed on the screen?

6 MS. FAVRE: Well, as I mentioned and I

7 think as many of the other certifiers have said,

8 you know, there are a variety of production

9 systems out there. And to try to give examples,

10 what's going to immediately happen is you're going

11 to have exceptions to those examples, you're going

12 to have exceptions or extreme circumstances that

13 don't fit into that.

14 And then you're forcing the certifiers

15 to once again make judgement calls based on their

16 own experience, and that sort of introduces

17 inconsistency when your intent was to put

18 consistency into it anyway.

19 So certainly, you know, this Board is

20 famous for wordsmithing, and I'm quite certain

21 that you can take a broad framework and make it

22 better. But my suggestion is to keep it broad
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1 enough but with some parameters around it so that

2 it's as any logical, reasonable certifier would

3 look at it could make a determination whether or

4 not that would constitute emergency.

5 And I would also like to say it's

6 important from an operator's standpoint that they

7 have the ability to respond rapidly. So, you

8 know, there were comments earlier about under a

9 veterinary's recommendation and things like that.

10 There's some operators that either don't have

11 access to or don't have access to timely

12 veterinary care that could put their operation in

13 jeopardy. 

14 CHAIR CHAPMAN: Thank you. A-Dae?

15 MS. ROMERO-BRIONES: So you gave us a

16 definition and you called out unforeseen and

17 sudden. But I was more interested in how we would

18 measure substantial risk, and if you have any

19 suggestions I would love to hear that.

20 And my second question is your point on

21 prevention is well taken, and how do you suggest

22 we incorporate this in the definition?
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1 MS. FAVRE: Well, for livestock,

2 substantial risk is probably going to surround

3 either the animal's health being permanently

4 impacted or the animal dying, or production being

5 significantly impacted to the point where the

6 operation is no longer sustainable. That's how I

7 would define it.

8 MS. ROMERO-BRIONES: Great, thank you.

9 And for the second, can you answer the second one?

10 Prevention is well taken, and how do you suggest

11 we incorporate that into the definition?

12 MS. FAVRE: Well, the organic system

13 plan actually would encompass that in large part.

14 I mean, an operator with a livestock operation

15 already has to have a pasture plan if it's a

16 grazing animal, or access to the outdoors if it's

17 poultry.

18 The issues around breed selection and

19 things like that, that is going to be more a

20 negotiated discussion between the operator and the

21 certifier.

22 CHAIR CHAPMAN: Thank you very much,
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1 Tracy.

2 MS. FAVRE: Thanks.

3 CHAIR CHAPMAN: Up next is Stanley and

4 on deck is Gwendolyn Wyard. Stanley, if you could

5 start with your name and affiliation.

6 MR. EDWARDS: My name is Stanley

7 Edwards, I'm a senior reviewer with QAI. I come

8 from 20 years of living out of a suitcase as an

9 independent contract inspector. I was an IOA

10 trainer and consultant.

11 At QAI we're pleased with the outcome

12 of instruction 2027 and look forward to this

13 year's peer reviews to continue improving our

14 certification program.

15 We agree with the five recommendations

16 outlined in the CACS proposal. The committee work

17 is an opportunity for us to further the discussion

18 on continuing education requirements. These are

19 outlined in the 2011 NOSB recommendation but not

20 yet implemented in the NOP program handbook.

21 As the recommendation describes, QAI

22 provides three hour annual guidance sessions that
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1 include technical topics. Also, we've opened

2 communication channels with inspectors and offer

3 in-the-field support when needed.

4 Our inspector pool is diverse. We have

5 independent inspectors with various academic and

6 industry backgrounds, auditors coming from the

7 food safety industry as well as rabbis with

8 extensive industry and audit experience.

9 The 2011 recommendation recognizes that

10 inspectors have to be general practitioners. I

11 agree with that. To be successful, inspectors

12 must be curious, passionate, be pragmatic,

13 excellent communicators.

14 Inspectors must accommodate the

15 unfamiliar and react to the unexpected. But

16 that's not enough. We expect our inspectors to be

17 proficient in the certification scope, and we

18 recognize that continuing education is essential

19 to bolster auditor competency.

20 However, we do not need to reinvent the

21 wheel in order to come up with practical,

22 continuing education requirements. For obvious
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1 reasons, continuing education is also an important

2 topic for the food safety and quality auditors.

3 The Safe Quality Food Institute's,

4 quote, criteria for SQF auditors, auditor

5 competency, and registration is a good reference

6 for our industry. For example, they require 15

7 hours annually from short course participation,

8 in-house course and workshop participation,

9 conference and seminar attendance, professional

10 body or association meeting attendance, relevant

11 committee and working group meeting attendance,

12 preparation and public presentation of papers,

13 preparation and publication of articles.

14 Aside from the 15 hours, these

15 requirements really are not that much different

16 from what I experienced when I was an independent

17 contractor. The minimum hourly requirement may

18 have to be scope specific, and for an inspector

19 working in all scopes, this might be challenging.

20 The specific areas where we see ongoing

21 continuing education needs -- you're not going to

22 get the list now.
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1 CHAIR CHAPMAN: Thank you, Stanley. 

2 Any questions for Stanley? Scott and then Sue.

3 MR. RICE: I'm curious to hear your

4 list, if you would please. Thanks.

5 MR. EDWARDS: So the list I have, and

6 I didn't put it in order, but the first thing I

7 have is the art of in and out balances, so I can

8 see a lot of training opportunities there; doing

9 risk assessment in an operation; natural resources

10 and biodiversity I think is going to be an ongoing

11 area where we need to train inspectors; the

12 livestock animal welfare rule; international

13 issues; and then managing electronic files and

14 improving efficiency, so this is more of the

15 mechanics of doing inspection with paperless

16 systems.

17 CHAIR CHAPMAN: Thank you, Sue? Oh,

18 same question. Thank you very much, Stanley.

19 MR. EDWARDS: You're welcome.

20 CHAIR CHAPMAN: Up next is Gwen and on

21 deck is Pat Kerrigan. Gwen, if you can start with

22 your name and affiliation.
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1 MS. WYARD: Gwendolyn Wyard with the

2 Organic Trade Association. Good afternoon, NOSB

3 members and NOP staff. I work as the Vice

4 President of Regulatory and Technical Affairs for

5 the Organic Trade Association. I want to extend

6 a warm welcome to the new NOSB members and take a

7 moment to first share a little bit about my

8 background.

9 My hands-on education is in organic

10 farming, but my formal education is in food

11 science and chemistry. I've been working as a

12 technical expert in organic processing

13 certification and policy for just over 20 years.

14 I've been an NOSB groupie since 2003,

15 and I've never missed a single show. And I co16 chaired the industry working group that helped

17 inform the recommendation on the classification of

18 materials, so synthetic versus non-synthetic,

19 agricultural versus non-agricultural, and as well

20 as the 2013 recommendation on ancillary substances

21 formerly known as the other ingredients.

22 In other words, I'm a fun date. And
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1 I'm available to help fit the puzzle pieces

2 together on some of the more hairy topics that you

3 face.

4 All right, so you have our written

5 comments and I'm going to do my best to offer up

6 the money line on a few select topics, and then

7 hopefully answer your questions.

8 Tocopherols, yes. Pass the proposal at

9 this meeting to revise the annotation to require

10 natural and organic forms of tocopherols when

11 they're commercially available. This decision

12 will move the needle in the continuous improvement

13 direction and support the development of organic

14 alternatives.

15 Organic seed usage, almost, not quite.

16 We support most but not all. So we're

17 respectfully asking that the subcommittee take

18 this proposal back for further work.

19 We do support the proposed regulatory

20 change as written because it inserts a greatly and

21 long time needed requirement for measured

22 continuous improvement in the regulation while
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1 still retaining commercial availability.

2 On the proposal for improved guidance,

3 there's a few revisions that we've suggested in

4 our written comments. But primarily, we would

5 like to see the guidance reiterate the regulatory

6 requirement that non-organic seed must be non-GMO.

7 Currently the guidance is silent on that front.

8 Further guidance on non-GMO

9 contamination prevention and seed purity we

10 believe should be developed and maintained in

11 separate comprehensive guidance and referenced so

12 that bits and pieces are not taken out of context.

13 BPA in packaging, I'm just going to say

14 it, this is a can of worms and honestly from a

15 regulatory perspective it's daunting to think

16 about. Let me be perfectly clear, OTA is not

17 opposed to the prohibition of BPA in organic

18 packaging, used in organic foods, but we believe

19 that it will require a regulatory change, and the

20 implications this may have on the review of

21 literally thousands of food contact substances in

22 general should not be taken lightly.
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1 Given the short comment period, we were

2 not able to convene a task force and carry out our

3 usual member feedback process, so we're requesting

4 that the discussion document be released for the

5 fall 2017 meeting when the technical review is

6 available and stakeholders have more time to weigh

7 in. Thank you.

8 CHAIR CHAPMAN: Thank you. Any

9 questions for Gwen? Thank you very much. Up next

10 is Pat, and on deck is Ann Marie Hourigan. Pat,

11 if you can start with your name and affiliation.

12 MR. KERRIGAN: Sure. Hi, I'm Pat

13 Kerrigan with Organic Consumers Association. Dear

14 NOSB members and NOP staff, the Organic Food

15 Production Act states that organic agriculture is

16 an ecological production management system that

17 promotes and enhances biodiversity of the

18 agricultural system and the surrounding

19 environment, biological cycles, and soil and

20 biological activity.

21 What an awesome goal that hopefully we

22 all can agree on. Organic consumers expect that
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1 with the premium price they choose to pay for

2 organic foods, that the farmers they are

3 supporting are actively enhancing biodiversity on

4 their farm as well as helping preserve

5 biodiversity of the surrounding environment.

6 This includes honoring the intrinsic

7 value and multiple ecosystem services such as soil

8 carbon sequestration, drought and flood

9 resilience, water filtration, and wildlife habitat

10 of the ever dwindling pristine/fragile lands of

11 the US.

12 Native ecosystems are much more than

13 wild spaces. Allowing and incentivizing the

14 conversation of native ecosystems to organic

15 production with no waiting period and no

16 ecological restrictions is certainly not within

17 the letter, nor the spirit, of the organic law.

18 An OP regulation state organic

19 production is a system that fosters cycling of

20 resources, promotes ecological bounds, and

21 conserves biodiversity.

22 How is agriculturally transforming
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1 these lands, these critically important lands

2 restoring, maintaining, and enhancing the

3 ecological harmony and balance?

4 As the discussion document noted, 1.6

5 million acres of grassland were converted

6 primarily for crop production between 2008 and

7 2012. As the carbon sequestration value and other

8 soil help benefits of native grasslands becomes

9 more clear and more critically important over

10 time, it is essential that we protect the

11 grasslands and other fragile/native habitats that

12 are still intact.

13 These lands should be designated as

14 high conservation value areas. Organic Consumer's

15 Association strongly supports wild farm alliance's

16 proposal that the NOSB recommend to the NOP a new

17 inclusive and comprehensive biodiversity standards

18 rule defining HCVAs based on WFA's four point

19 criteria.

20 OCA also strongly supports the wild

21 farm alliances recommendation that a rule change

22 be made in which HCVAs would not be eligible for
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1 transition to organic production for five years.

2 As the NOSB discussion document states,

3 agriculture by its very nature reduces

4 biodiversity and fragments ecosystems.

5 Shouldn't converting the 99 percent of

6 chemically based industrial agriculture to organic

7 production acreage be our focus rather than

8 converting HCVA lands into production?

9 Finally, 13 organic labels and 11 eco

10 labels internationally do not allow the

11 conversation of HCVA or native ecosystems for

12 agricultural production. So why shouldn't our

13 country be one of the global leaders in protecting

14 and promoting biodiversity of our natural

15 ecosystems. Thank you for your time and your

16 service.

17 CHAIR CHAPMAN: Thank you, Pat. 

18 Questions for Pat? Thank you. Up next is Ann

19 Marie followed by Mike Molina on deck. Ann, if

20 you can start with your name and affiliation.

21 MS. HOURIGAN: Good afternoon. My name

22 is Ann Marie Hourigan with Danone Wave. I'd like
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1 to take a moment to thank both the National

2 Organic Standards Board and the National Organic

3 Program for the important work that you do. I'd

4 also like to welcome new members to the Board.

5 Today I'm commenting on behalf of our

6 new sister company, Nurture Inc., dba Happy Family

7 or Happy Family Brands. Happy Family was founded

8 in 2003, launching its first organic baby food

9 products in 2006. Since this time, the company

10 has grown into a leader in the US organic baby

11 food sector. In 2013, Happy Family was purchased

12 by Groupe Danone, a global leader in infant

13 nutrition.

14 Happy Family is pleased to have the

15 opportunity to comment at the spring 2017 NOSB

16 meeting and supports the NOP's efforts to

17 continuously review and amend the National List of

18 Allowed and Prohibited Substances and to remove

19 substances as they become no longer essential for

20 organic handling and processing.

21 We understand that the NOSB has already

22 made a recommendation on inulin-oligofructose
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1 enriched at the October 2015 meeting. But Happy

2 Family would like to go on record that we do not

3 want the item removed the National List. We

4 believe that this ingredient is essential in

5 organic infant formula.

6 Our parent company has done a lot of

7 research over the past four years, so we have

8 worked to deeply understand the current organic

9 infant formula market with the hope of offering

10 the very best possible to the very smallest of

11 organic consumers.

12 Because human milk differs from the

13 base materials for infant formula, such as cow's

14 milk, extensive efforts to understand the

15 composition of human milk has been made,

16 especially through analysis to identify relevant

17 bioactive molecules.

18 Prebiotics are important nutrients that

19 are present in breast milk at approximately eight

20 to nine percent of the composition and currently

21 not prominent in organic infant formula.

22 Due to this ingredient's prebiotic
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1 function, which has been extensively studied, we

2 believe it benefits the organic consumer by

3 creating products that are inspired by human milk.

4 We understand the decision to remove

5 this substance was partially based on the lack of

6 public comment coupled with the misunderstanding

7 that inulin-oligofructose enriched could be

8 produced from multiple sources, including

9 Jerusalem artichokes, agave, and other plants.

10 Additionally, there is misinformation

11 that the separate listing for

12 fructooligosaccharides, FOS on the National List,

13 is interchangeable with inulin-oligofructose

14 enriched and that ample supply of organic inulin

15 is available.

16 But due to the unique properties of

17 inulin-oligofructose enriched, this substance must

18 be made from chicory root which provides the

19 functionality and differentiates it significantly

20 from FOS. Because inulin-oligofructose enriched

21 -- thank you.

22 MR. CHAPMAN: Thank you. Questions
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1 for Ann?

2 MS. HOURIGAN: Thank you for your time.

3 CHAIR CHAPMAN: I actually have

4 questions for you. I was just looking at the

5 other people. So inulin, you know, has a broad

6 set of chains, encompasses oligofructose and FOS. 

7 It's generally -- oligofructose and FOS are

8 generally interchangeable terms, smaller set of

9 carbohydrate chains. So FOS remained on the list. 

10 Inulin itself is widely available and organic.

11 MS. HOURIGAN: Yes.

12 CHAIR CHAPMAN: Why is using a

13 combination of the two substances insufficient?

14 MS. HOURIGAN: I would have to --

15 thanks for your question, Tom. I would have to

16 get back to our team at Happy Family to get you an

17 accurate and thorough response. Would you like me

18 to email that directly to you or through Michelle?

19 CHAIR CHAPMAN: Through Michelle.

20 MS. HOURIGAN: Okay, great. Thank you.

21 CHAIR CHAPMAN: Thank you. So up next

22 we have Michael Molina. And then on deck is John
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1 Ashby. Michael, if you could start, Mike, if you

2 could start with your name and affiliation?

3 MR. MOLINA: Michael Molina, Applied

4 DNA Sciences. So it is our position that the use

5 of Short DNA Tracers does not interfere with the

6 growth, development, or production of organic

7 products. Additionally, it does not accurately

8 fit the description of the excluded method as

9 defined in section 205.2.

10 To quote from the excluded methods, "A

11 variety of methods used to genetically modify

12 organisms or influence their growth and

13 development by means that are not possible under

14 natural conditions or processes.

15 "Short DNA Tracers do not fit this

16 description as they are not modifying organisms or

17 influencing their growth and development at any

18 stage of the life cycle.

19 "As stated in the safe trace petition,

20 fragments smaller than 150 base pairs lack the

21 regulatory elements to code for biological

22 functions and code for proteins.
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1 "Methods that are not included under

2 the excluded methods are tradition breeding,

3 fermentation, and in vitro fertilization."

4 I'd like to point out that in vitro

5 fertilization is reproducing a biological function

6 in the same way that in vitro polymerase chain

7 reaction does. It is simply mimicking the

8 biological process using the same fundamental

9 elements required by nature while not affecting

10 the growth, development, or the product.

11 We feel that the statement on modern

12 biotechnology involving in vitro nucleic acid

13 techniques is simply referring to the use of

14 nucleic acid techniques for the implementation of

15 genes into a product.

16 Additionally, there are a few examples

17 included in the methods that have synonymous

18 processes with the excluded methods. As an

19 example, in vitro fertilization involves cell

20 fusion of gametes to produce embryos that would

21 not occur otherwise in nature.

22 Likewise, cell fusion has been a part
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1 of the traditional breeding process for years

2 without being considered genetic engineering. 

3 Cell fusion is listed as an excluded method unless

4 the cells fall within the same taxonomic family.

5 Despite this in vitro cell fusion, the

6 in vitro cell fusion process is accepted. Because

7 it does not affect the development or compromise

8 the plant's true genetic makeup.

9 Similarly to the in vitro PCR

10 techniques utilized by this DNA technology, the

11 DNA tracers that are used will not affect the

12 growth, development, or genetic makeup of the

13 product and therefore should be accepted as a

14 viable method of protecting the organic integrity.

15 The counterfeiting industry has become

16 a $650 billion problem. The US Government has

17 been using Applied DNA's technology, because as

18 the tech world advances so does the counterfeiting

19 industry.

20 We would argue for the essentiality of

21 DNA Tracers, because the sophistication of

22 counterfeiters is beyond the paper trail. And the
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1 US Government, along with other industries

2 including cotton and pharmaceuticals, have

3 realized that.

4 As part of the millennial generation,

5 we as a society are becoming increasingly aware of

6 the need for sustainability and the importance of

7 organic products. With the organic industry

8 growing over 13 percent in the last year, it is

9 only a matter of time before we start seeing more

10 and more adulteration of these products. It is

11 not a matter of if, it's when. And quite frankly,

12 it's happening every day.

13 The problem experienced in Turkey and

14 Ukraine are minimal in comparison to problems that

15 will be encountered in the future. The Board is

16 already struggling to investigate half the claims

17 that are made every year.

18 Not only will DNA technology provide a

19 deterrent factor that will minimize these claims,

20 but utilizing a third party for testing will help

21 lighten the load that is becoming increasingly

22 heavy.
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1 MR. CHAPMAN: Thank you.

2 MR. MOLINA: Thank you.

3 MR. CHAPMAN: Questions for Mike? 

4 Thank you. Dan?

5 DR. SEITZ: Thanks. It's the same

6 question I asked someone earlier. In order for

7 this system to be in place, it seems to me that we

8 would have to require producers, or handlers, or

9 someone along the line to actually use your

10 technology as opposed to using a paper-based

11 system.

12 So I'm just kind of curious. Are you

13 advocating that we would move from this record14 based system to one where producers or handlers

15 are required to use this technology?

16 MR. MOLINA: Well, I think the paper17 based can be used in parallel with this DNA

18 technology. I think it's just up to the, you

19 know, manufacturer whether they want to utilize

20 this technology. I mean, they can certainly be

21 used in parallel. What I'm saying is that we

22 don't believe the paper trail's enough anymore. 
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1 Does that answer your question?

2 DR. SEITZ: Yes.

3 CHAIR CHAPMAN: Thank you very much. 

4 I'm batting last, John Ashby. John, if you could

5 start with your name and affiliation.

6 MR. ASHBY: I'm John Ashby, citizen of

7 the not yet enough organic universe. I want to

8 give an appropriate thank you to the NOSB, given

9 this very auspicious date --

10 (Laughter)

11 MR. ASHBY: Wow, I love you, man. I

12 love you. Organic friend, to wit, oh, what a

13 wicked web we weave when first we practice to

14 conceive of how to make a national list without

15 which organics would be missed.

16 In the list, organics would disappear,

17 evaporate, no longer here. It gives us tools to

18 make our food, it's fun, it's great, it's really

19 good. To talk this way can make me pay, but I

20 don't care, I will anyway.

21 It probably won't bring me luck, in

22 fact I probably will be criticized very heavily. 
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1 To speak warmly of the National List, can get a

2 bunch of people pissed. Some want to make it

3 teeny tiny, which makes me really mad and whiny.

4 We need this stuff, we need these

5 tools. We need them to grow our organic fuel. To

6 lose them would make Monsanto's day, because

7 organic's threat would float away.

8 The biggest threat to my sweet, cute

9 list, I want you to know, don't want it missed. 

10 Come closer now and listen intensely of the

11 devilish trap that threatens us gravely. And what

12 can this threat possibly be? It's essentiality.

13 It gets misused, used as a weapon, by

14 those who mistakenly choose to weaken. It's not

15 essential, or so they opined, and infant formula

16 was fatally maligned. It will be gone when the

17 time runs out. They killed it dead, they sent it

18 out.

19 The items were needed by infants, yes,

20 without them the children will not be blessed by

21 the nutrition they need to grow their best. The

22 option to eat their meals organic is gone, kaput. 
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1 It makes me mad to have this happen again, to lose

2 sight of the better, the good, the essentials.

3 So don't be fooled when you hear non4 essential. Ask those who are doing it, who make

5 it, they know what it takes to make organic grow. 

6 The infants can be lost, it can happen again,

7 don't let your guard down. Be organics' friend.

8 My example was completely coincidental,

9 because that was a classic case where there are

10 three different and contradictory definitions of

11 what essential is with respect to organic infant

12 formula.

13 And actually, the leading scientist in

14 the world doing the work on carbohydrates in

15 breast milk is a friend of mine. And she's

16 absolutely right. There is life and death

17 difference between one carbohydrate use and

18 another. They're actually not interchangeable.

19 I had nothing to do with her. I had no

20 idea -- that's my barking dog to keep me on time

21 -- I had no idea she was going to be going on

22 before me. But they are not interchangeable.
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1 CHAIR CHAPMAN: Thank you. Questions

2 for John, and just a note --

3 (Applause)

4 CHAIR CHAPMAN: Thank you. Questions

5 for John, and just a note, answers to the

6 questions will need to be in rhyme.

7 (Laughter)

8 CHAIR CHAPMAN: Yes, go for it.

9 MS. SWAFFAR: I'd just like to know how

10 long it takes you to put your comments together.

11 MR. ASHBY: I never start them until

12 after the first day of comments and see what I

13 want to get across.

14 MS. SWAFFAR: That's really important.

15 CHAIR CHAPMAN: Thank you, John.

16 MR. ASHBY: Thank you.

17 CHAIR CHAPMAN: Thank you, everybody. 

18 All right. That concludes public comments. And

19 we are just a mere hour and a half behind

20 schedule. However, I do believe we can make that

21 up. I am optimistic.

22 So this now starts our subcommittee and
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1 Board deliberation portion of the meeting. In a

2 moment, I will be handing the meeting over to Lisa

3 De Lima, Chairperson of the Handling Subcommittee,

4 and we'll begin through that agenda.

5 Just to note, we went through conflicts

6 of interest earlier yesterday. And there were

7 none noted, so we will not be going through

8 conflicts of interest at the beginning of every

9 subcommittee. Lisa, if you're ready, the seat is

10 yours.

11 MS. DE LIMA: All right. So we're

12 going to start with the 2019 Sunset Materials. 

13 And just a reminder to everybody on the Board,

14 this is the first listing. So this is just a

15 discussion of the materials. And we'll be voting

16 on whether to retain them on the list or not in

17 the fall meeting. So we're just going to jump

18 right into it. The first up is attapulgite. Dr.

19 Brines?

20 DR. BRINES: Thank you. I'll just be

21 introducing each Sunsetter Petition material

22 before turning it over to the full Board for
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1 discussion. So we'll start with Section 205.605

2 of the National List. That's the non3 agricultural, non-organic substances allowed as

4 ingredients in or on processed products labeled as

5 organic or made with organic specified ingredients

6 or food groups.

7 We're under Paragraph A, non-synthetics

8 allowed. And the first listing is attapulgite,

9 listed at 205.605a as attapulgite, sorry, as a

10 processing aid in the handling of plant and animal

11 oils. Thank you.

12 MS. DE LIMA: Thank you. Joelle?

13 MS. MOSSO: All right. So attapulgite

14 is a natural clay with highly absorptive

15 properties due to the open channel structure

16 created from a complex of magnesium aluminum

17 silicates.

18 This structure creates a large surface

19 area that can adsorb, absorb, and filter

20 substances to remove colors and other impurities. 

21 And that's primarily in oils, as it's listed on

22 the National List. It is labeled as grass and
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1 created from open pit mining activities followed

2 by drying and milling.

3 It was added in 2011 and was voted to

4 remain on the list in 2015 with three votes to

5 remove and 11 to maintain.

6 In this round of Sunset, we received

7 seven comments, five directly to this material,

8 three votes of support for re-listing with two

9 certified clients noted for using it for oil

10 filtration, two comments to remove due to lack of

11 support and not meeting essentiality requirements,

12 and two certifiers who reported no one used within

13 their client base.

14 MS. DE LIMA: Are there any questions

15 or discussion? All right, seeing none, we'll move

16 on to the next material, bentonite. Dr. Brines?

17 DR. BRINES: Thank you. We're in the

18 same section, same paragraph, and the listing is

19 bentonite. Thanks.

20 MS. DE LIMA: Joelle?

21 MS. MOSSO: All right, second play. So

22 bentonite is a natural clay composed of alumina,
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1 silica, and water derived from tuff or volcanic

2 ash. It is a clay that has functional properties

3 of adsorption, absorption and filtering

4 properties.

5 Bentonite is used to remove proteins

6 and impurities in wine and the oil industry. It

7 is manufactured by open pit mining followed by

8 drying and milling.

9 It was reviewed in 2015 with no

10 opposition to re-listing, and it also labeled as

11 grass. During the 2017 review process, so far

12 we've received 14 comments, 11 supporting re13 listing and that bentonite is critical to their

14 products. This is especially noted in the wine

15 industry.

16 Two comments requested further review

17 to examine the mining activities and alternatives.

18 However, no new information on those concerns was

19 given. And one certifier reported no one used

20 while two others certifiers listed 36 clients that

21 use it.

22 MS. DE LIMA: Thank you. Any questions
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1 or discussion? All right, seeing none, we'll move

2 on to nitrogen. Dr. Brines?

3 MR. CHAPMAN: DE, diatomaceous earth.

4 MS. DE LIMA: Oh, I missed one. Sorry. 

5 Yes, diatomaceous earth.

6 DR. BRINES: I wasn't going to let you

7 skip it. All right. The next item on the list,

8 I'm continuing in the same section, is

9 diatomaceous earth. And the listing reads,

10 "Diatomaceous earth, food filtering aid only." 

11 Thanks.

12 MS. MOSSO: All right. Diatomaceous is

13 comprised of accumulated shells of silica secreted

14 by diatoms that are used as a filter aid for

15 syrups, juices, beer, and other beverages and food

16 products. It is not present in finished products

17 and is classified as a processing aid. The

18 material is produced through mining.

19 Diatomaceous earth was most recently

20 reviewed in 2015. And so far this year, we've

21 received 16 total comments, 14 with comments to

22 re-list and two comments to review the mining
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1 practices and environmental concerns, and

2 alternatives with no new information presented.

3 Again, strong support from the wine

4 industry as well as the oil and flavor processing

5 industry.

6 MS. DE LIMA: Thank you. Any questions

7 from the Board? Seeing none, we'll move on to

8 nitrogen. Dr. Brines?

9 DR. BRINES: Continuing in the same

10 section, the listing is nitrogen, oil-free grades.

11 Thanks.

12 MS. DE LIMA: All right, this one is

13 mine. So nitrogen is used to displace oxygen and

14 reduce oxidation of product during processing,

15 storage, and packaging. It can be used in the

16 flash freezing of foods. It also functions as a

17 propellant when it's used under pressure and

18 doesn't have ozone-depleting properties.

19 There were a large number of public

20 comments submitted in support of nitrogen

21 remaining on the list, none in opposition. The

22 material was reviewed by the Board in 2015, and
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1 the Board voted unanimously to continue its

2 listing. Any questions, discussion?

3 All right. Seeing none, we'll move on

4 to sodium carbonate. Dr. Brines?

5 DR. BRINES: All right. Continuing in

6 the same section, the listing is sodium carbonate. 

7 Thanks.

8 MS. DE LIMA: All right, that's mine

9 too. So sodium carbonate, used as a leavening

10 agent, anti-caking agent, acidity regulator,

11 stabilizer, also a neutralizer for dairy products

12 like butter, cream, milk, and ice cream.

13 Public comment also pointed out that

14 it's used as a pH adjuster for organic laundry

15 detergents, used in soy base extraction, and to

16 clean fruit and remove mold.

17 It's produced in North America from

18 natural deposits of trona ore which is heated and

19 mixed with water to dissolve the soda ash and

20 separate out any impurities. And the solution's

21 then concentrated by evaporation to

22 crystallization. And it could also be produced
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1 using a similar method originating from natural

2 brine.

3 Public comment mostly supported the

4 continued listing of this material. One commenter

5 requested a TR to evaluate possible impacts from

6 its production. And another organization

7 requested clarification regarding which

8 manufacturing processes are permitted under the

9 listing at 605a.

10 This material was also reviewed by the

11 NOSB in 2015. And the Board voted unanimously to

12 continue its listing. Questions, discussion?

13 Seeing none, next up, acidified sodium

14 chlorite. Dr. Brines?

15 DR. BRINES: Thank you. Continuing

16 under Section 205.605, moving to Paragraph B,

17 synthetics allowed, the listing is acidified

18 sodium chlorite, secondary direct microbial food

19 treatment and indirect food contact surface

20 sanitizing. Acidified with citric acid only. 

21 Thanks.

22 MS. DE LIMA: Ashley?
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1 MS. SWAFFAR: So acidified sodium

2 chlorite is used as a processing aid in wash and

3 rinse water. There were several comments in

4 support of re-listing stating that it is a

5 critical, essential tool in the fight against

6 foodborne pathogens.

7 And there were comments that requested

8 we do a comprehensive review of sanitizers. But

9 as we stated in the document, the subcommittee

10 felt that a review of all sanitizers is beyond the

11 scope of the Sunset process.

12 MS. DE LIMA: Any questions or

13 discussion from the Board?

14 All right. Seeing none, we'll move on

15 to carbon dioxide, no, is that it? Yes, carbon

16 dioxide. Dr. Brines?

17 DR. BRINES: Thank you. Continuing

18 under the same section, the listing reads as, 

19 "Carbon dioxide." Thanks.

20 MS. DE LIMA: So carbon dioxide is used

21 in modified atmospheric packaging and storage, 

22 the freezing of foods, beverage carbonation. It's
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1 used as an extracting agent, a processing aid, and

2 also for pest control in grain and produce

3 storage.

4 All public comment received was in

5 favor of retaining it on the National List. And

6 this material too was reviewed by the NOSB in 2015

7 and voted unanimously to continue its listing.

8 Questions, discussion?

9 Seeing none, chlorine materials. Dr.

10 Brines?

11 DR. BRINES: Thank you. So continuing

12 under 205.605b, the listing reads as, "Chlorine

13 materials, disinfecting and sanitizing food

14 contact surfaces, except that residual chlorine

15 levels in the water shall not exceed the maximum

16 residual disinfectant limit under the Safe

17 Drinking Water Act." Then in parentheses,

18 ("Calcium hypochlorite, chlorine dioxide, and

19 sodium hypochlorite.") Thanks.

20 MS. DE LIMA: Ashley?

21 MS. SWAFFAR: So chlorine materials are

22 used for disinfecting and sanitizing facilities
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1 and equipment. It has a wide variety of use. We

2 had broad support from handlers requesting to re3 list chlorine material, stating -- one stating

4 that it used as their primary sanitizer, kills a

5 wide range of pathogenic organisms and is vital

6 for food safety. We heard that various different

7 ways at several times.

8 And once again, there were comments

9 saying that they requested we do a comprehensive

10 review of sanitizers. And as we wrote, the

11 subcommittee felt that this was beyond the scope

12 of the Sunset process.

13 MS. DE LIMA: Questions, Emily?

14 MS. OAKLEY: Do you think it might be

15 appropriate for the Material Subcommittee to do a 

16 review of the sanitizers outside of the Sunset

17 process if there's a need for that?

18 MS. SWAFFAR: Yes. I think, because we

19 heard that in Handling, Livestock everywhere. So

20 I think that's not just individual committees. 

21 It's a broad look.

22 MS. DE LIMA: Any other questions,
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1 discussion? All right. Seeing none, we'll move

2 on to magnesium chloride. Dr. Brines?

3 DR. BRINES: Thank you. Continuing on,

4 this listing reads as, "Magnesium chloride,

5 derived from seawater." And of note, the

6 committee did request an updated technical report

7 in support of the review of this material. And

8 that report was published in 2016. Thanks.

9 MS. DE LIMA: Thank you. So magnesium

10 chloride is used as a coagulant in tofu production

11 as well as in certified organic dietary

12 supplements and infant formula.

13 Following the 2015 Sunset review, we

14 did recommend the continued listing. But issues

15 to classification were raised, and so we requested

16 a technical report which we received and was

17 utilized in this Sunset review.

18 So during the initial 2015 review, we

19 requested public comment on whether or not the

20 material should be reclassified as non-synthetic,

21 because it's derived from seawater by brine drying

22 and had no ancillary substances. The public
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1 comment supported that the material should be

2 reclassified as non-synthetic and moved from

3 205.605b to 605a.

4 However, once we got the TR, we learned

5 that the material can be produced both

6 synthetically and non-synthetically. And the

7 annotation derived from seawater can apply to both

8 versions.

9 So we did pose three questions to the

10 public, and we got answers on other uses of

11 magnesium chloride in processing and handling, in

12 addition to just a coagulant for tofu. And it

13 looks like we still need to have some discussion

14 at the subcommittee level to figure out what the

15 impact would be if the material was reclassified

16 at 605a. Tom?

17 MR. CHAPMAN: Were there any comments

18 about the impact of reclassifying to 605a?

19 MS. DE LIMA: No. There's more

20 comments saying we should clarify what would be

21 allowed, and what wouldn't be allowed, and put it

22 out there so that we could get more public comment
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1 back. Any other questions?

2 All right, moving on to potassium acid

3 tartrate. Dr. Brines?

4 DR. BRINES: Thank you. In the same

5 section, this listing reads, "Potassium acid

6 tartrate."

7 And in support of the review, the

8 subcommittee did request the development of an

9 updated technical report. And that report was

10 posted on the NOP website in January earlier this

11 year. Thanks.

12 MS. DE LIMA: Steve?

13 MR. ELA: Potassium acid tartrate is a

14 byproduct of wine making. It's commonly known as

15 Cream of Tartar. It is used in baked goods, a

16 component of baking powder, and can be used to

17 stabilize egg whites and other food uses.

18 In the review of 2015, no public

19 comment opposing the continued listing was

20 received. The current public comments were all in

21 favor of continuing this listing. Although a

22 couple of people made the comments that we should
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1 encourage that the potassium acid tartrate is made

2 only from organic grades. It's derived as a

3 byproduct of the wine making process.

4 The real question came up through all

5 this of whether the material should be

6 reclassified as an agricultural or non-synthetic

7 since it is a byproduct of winemaking which is

8 agricultural, and then there are no synthetic

9 processes used to make it.

10 Right now, it's classified as non-ag,

11 synthetic. So basically, the public comment is to

12 re-list it. And then separately, most public

13 comments were in favor of re-listing it into an

14 ag, non-organic, agriculturally produced

15 substance.

16 MS. DE LIMA: Thank you, Steve. Any

17 questions? Tom?

18 MR. CHAPMAN: Did the 2017 TR point to

19 synthetic manufacturing processes?

20 MR. ELA: It's basically taken out by

21 hot water extraction. So it really becomes a

22 question of whether it's coming from non-organic
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1 grapes or organic grapes.

2 MS. DE LIMA: Any other discussion? 

3 All right. Seeing none, moving on to sodium

4 phosphates. Dr. Brines?

5 DR. BRINES: Thank you. In the same

6 section, this listing reads as, "Sodium Phosphates

7 for use only in dairy foods."

8 There was an updated technical report

9 completed in 2016 as a follow-up to the last

10 Sunset cycle. The scope of that report was for

11 phosphates, so that included calcium phosphate,

12 potassium phosphate, sodium acid pyrophosphate,

13 and also this listing, sodium phosphate. Thanks.

14 MS. DE LIMA: All right. So sodium

15 phosphates, while they do have a variety of uses,

16 it is currently annotated to dairy use only. The

17 material is derived from phosphoric acid.

18 Public comment was pretty split on this

19 listing. On one end, you've got commenters

20 supporting the listing of this material,

21 especially as an emulsifier in cheese production

22 where it's considered essential, also considered
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1 essential in making beverages like high protein

2 smoothies, for stabilizing the texture of the

3 product.

4 Other commenters would like to see the

5 material removed based on the lack of essentiality

6 and human health impacts. And there are five

7 phosphates on the National List, and there's no

8 single phosphate food additive or ingredient that

9 can be implicated as an isolated risk factor. 

10 Concerns arise from the increase in cumulative use

11 of phosphates and possible health effects on the

12 general population.

13 Since the last Sunset review, which was

14 in 2015, we did -- given the new information and

15 research since the last Sunset review, the

16 Handling Subcommittee did request a technical

17 report which we received last year.

18 The TR indicated that small amounts of

19 sodium phosphate may not cause human health

20 problems, but the long term cumulative impacts are

21 not fully understood.

22 Questions, discussion? Emily and then
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1 Harriet.

2 MS. OAKLEY: Given the disagreement

3 within the stakeholder community about what to do

4 with this substance, does the Handling

5 Subcommittee have a sense of where it might be

6 going with this material?

7 MS. DE LIMA: Tom, you have any

8 thoughts as the co-lead?

9 MR. CHAPMAN: No, not yet, I don't

10 think. I don't think there was a definitive

11 opinion to put out there. I have a personal

12 opinion, but I don't know. It doesn't speak for

13 the subcommittee.

14 MS. DE LIMA: Harriet and then -- or is

15 it a follow-up, Emily? Emily?

16 MS. OAKLEY: So I'm not an expert,

17 obviously, in handling issues. So what

18 information or discussion amongst the committee

19 will occur that will help decide this issue? And

20 should I listen in on those calls if I have

21 questions about where I might be headed in my vote

22 with this?
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1 MR. CHAPMAN: Yes. I mean, I think we

2 received a significant amount of public comment

3 this time, especially in response to the technical

4 review. There was also a supply shortfall, and 

5 so I think reviewing that and having those

6 discussions will enlighten.

7 You know, I anticipate a robust Sunset

8 review document for the second round. But you're

9 always welcome to join in. I mean, joining the --

10 or listening in to the conversation gives you the

11 most, you know, context for how people decided

12 what they did.

13 MS. DE LIMA: Harriet?

14 MS. BEHAR: So I might have actually

15 been somewhat responsible for getting this on the

16 list. Because I worked for Organic Valley back in

17 the day when the first organic dry cheese powder

18 was made.

19 And there was a discussion I had with

20 a scientist at the Center for Dairy Research in

21 Wisconsin. And he brought up that sodium

22 phosphate would bind the calcium and make it less
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1 available to the people consuming the cheese

2 powder. And we then went and used sodium citrate

3 instead.

4 But since then, since that was in the

5 last century, it seems like there's been some

6 other science that's come forward. And just doing

7 a little bit of Googling last night, it didn't

8 seem that there was clarity. You know, and this

9 was just me just looking, Googling.

10 You know, some of it was the issue

11 could be that it's the sodium that actually causes

12 the problem, not so much the phosphorus. And so

13 I think we need to look at this a little bit

14 closer.

15 But I know that Organic Valley did make

16 dry cheese powder with sodium citrate successfully

17 for many years. But then they're no longer doing

18 it. They now kind of have -- someone else does

19 it, and they're not sure what additive they're

20 using. But there needs to be some kind of

21 emulsifier used in order for the cheese powder to,

22 you know, keep its integrity.
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1 So I think we should, you know, be

2 looking at this product and especially make sure

3 that the information that we have is current. 

4 Because it seems to be somewhat changing.

5 MS. DE LIMA: Joelle?

6 MS. MOSSO: You know, in just thinking

7 about kind of the comments that are made about a

8 material that -- and cumulative can have effect,

9 it makes me think about other things that have the

10 same sort of effect.

11 We know that caffeine is calcium12 binding. We know that butter is not good in

13 excess. So I do get a little bit concerned when

14 we fixate on some health implications that are not

15 at a realistic consumption rate. It obviously

16 does have functional properties in food.

17 MS. DE LIMA: Tom?

18 MR. CHAPMAN: Yes, that is a concern

19 of mine too. One of the studies that has been

20 cited to support the accumulated impact, the

21 recommendation by the study partner was that a

22 warning system is used similar to sodium contents. 
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1 It wasn't a prohibition on the content but rather

2 just raising awareness of it.

3 But the other item I think we should

4 keep in mind is that we did receive public comment

5 this time about the glut of organic milk that's

6 currently on the market and the depressed dairy

7 prices in the organic market. So is now also the

8 right time to be considering limiting organic

9 dairy process products?

10 MS. DE LIMA: Francis?

11 DR. THICKE: Well, I'm not a food

12 nutritionist, but on our small dairy on-farm

13 processing plant we make cheese. And I kind of

14 devised the recipes, and they usually have a lot

15 of ingredients that we don't use. Our yogurt is

16 just milk and culture. Our cheeses, we threw out

17 the phosphorous. And people love our cheese.

18 But it's just one little example to

19 point out that sometimes these things are just put

20 in the recipes, and they may not be quite as

21 essential as we thought. But again, this is my

22 own little cheese. And there are a lot of cheeses
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1 out there.

2 MR. CHAPMAN: Can I ask a clarifying

3 question?

4 MS. DE LIMA: Sure.

5 MR. CHAPMAN: But not cheese powders,

6 or shelf-stable cheese sauces, or anything like

7 that.

8 MS. DE LIMA: Any other discussion? 

9 All right, seeing none, moving on to casings. Dr.

10 Brines?

11 DR. BRINES: All right. Thank you. We

12 are in a new section of the National List. And

13 that section is 205.606, "Non-organically produced

14 agricultural products allowed as ingredients in or

15 on processed products labeled as organic."

16 And as a reminder, items in this

17 section of the National List are subject to a

18 requirement that they are only allowed when the

19 product is not commercially available in organic

20 form.

21 And the first listing under

22 consideration on this section is casings from
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1 processed intestines. Thanks.

2 MS. DE LIMA: Thank you. Asa?

3 CHAIR CHAPMAN: Microphone.

4 MR. BRADMAN: So casings, as we know,

5 are intestines of beef, lamb, and pork and used to

6 make natural casings for sausages. The

7 alternative material for casing is synthetic

8 cellulose or synthetic collagen.

9 We've heard a little bit about this

10 this morning. Intestines are washed in pure water

11 with no chemicals. They're salted with sodium

12 chloride. No other ingredients or processing aids

13 are used. Animal intestines may come from organic

14 or non-organic animals.

15 In terms of the public comments, there

16 were really very few this time around. I have

17 maybe five or six comments. Pretty much all of

18 them were supportive and were similar to the

19 comment earlier today that there really is no

20 source of organic casings for sausage production.

21 There was one comment though that

22 expressed frustration that there had been no
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1 technical report or TAP. And that there really

2 was not any careful evaluation of the fact that if

3 we're using non-organic animals they may be eating

4 GMO or other foods that -- They could be GMO or

5 eating foods that had been treated with pesticides

6 or other excluded materials and that there should

7 be an evaluation of the implications of that on

8 the casing product and the implications of using

9 that for organic sausage production.

10 So I don't know if any discussion or

11 comment is related to that. But that's really the

12 thrust of the comments.

13 MS. DE LIMA: Thank you, Asa. Dan?

14 MR. MORTENSEN: I have the impression

15 that there's really no good solution here in that

16 potentially there are lots of, as Asa was saying,

17 factory-farmed animals or animals that have been

18 fed GMOs. Their intestines are in this mix.

19 With cellulose you have the question of

20 some suspect ancillary ingredients. So I was

21 wondering, and I don't know anything about the

22 collagen, synthetic collagen as an option, but did
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1 the subcommittee feel there was any good approach

2 here for casings for sausage, or we have a

3 situation where we have to just pick among several

4 things that are perhaps not ideal from our

5 standpoint?

6 MR. BRADMAN: There wasn't that much

7 discussion in the subcommittee. I think the

8 feeling was that this is -- there were comments in

9 2015, and this is a material that's kind of needed

10 by the, you know, the organic community, the

11 stakeholder community, and that we didn't see, you

12 know, many alternatives.

13 MS. DE LIMA: Tom?

14 CHAIR CHAPMAN: And I think one of the

15 best solutions is growing the organic meat market

16 so that there's a greater amount of meat processed

17 and an economically viable method to segregate

18 organic intestines. But that's a long term fix. 

19 It's not short term.

20 MR. BRADMAN: I think this is an

21 opportunity where we can somehow perhaps

22 incentivize, you know, production of organic
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1 casings. Then there'll be a market for it.

2 MR. CHAPMAN: Well, yes. As a 606

3 item though, if it is available, they must use it. 

4 That is a requirement.

5 MS. DE LIMA: Dave?

6 MR. MORTENSEN: Yes. As a newcomer to

7 this process, we're looking at a number of cases

8 where there's a difficulty in having critical mass

9 of a non-organically produced substrate that's

10 then going to be processed, whether it's citrus

11 peels, or casings, or in just the previous example

12 of the wine processing.

13 I was just curious. How do we

14 determine when critical mass is reached and we're

15 not just using the excuse that, you know, it's

16 convenient to use something that, from a

17 processing point of view, just as a point of order

18 and --

19 MS. DE LIMA: Tom?

20 MR. MORTENSEN: It seems to me, for

21 example, it would be easier. I have friends that

22 are in the organic meat business in the northeast. 
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1 Casings seem more challenging to me than grapes

2 from a vineyard that's organically certified, for

3 example.

4 MR. CHAPMAN: Yes. I mean, there's --

5 in looking at how items have been removed or

6 recommended to be removed from 606 in particular,

7 there's been a variety of means.

8 Some companies who have a vested

9 economic interest in promoting the organic version

10 of it have petitioned. And that's generally, I

11 think, in my personal opinion, the most effective

12 way of removing items.

13 However, at Sunset review there's been,

14 you know, we have the Organic Integrity Database

15 now that gives some sense of at least operations

16 handling these products and comments from those

17 companies as well as the public about its

18 continued usage in the last -- in the 2017 Sunset

19 review.

20 I don't have the numbers off the top of

21 my head. But I feel like we made recommendations

22 to remove about a dozen items from 606. So it
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1 does happen. But it's generally through comments

2 from handlers, comments from the public, and

3 generally the most effective way is that discreet

4 economic interest who, you know, comes up with the

5 first organic casing and then makes everyone buy

6 it.

7 MR. MORTENSEN: Okay, good.

8 MS. DE LIMA: Harriet?

9 MS. BEHAR: Well, this just brings up

10 a little bit of a bigger issue, just in 606, in

11 having maybe some different questions and maybe

12 even considering doing TRs on some items in 606 so

13 we have a better idea of what the barriers are to

14 the production of these items.

15 As we learned from hops, which was

16 awhile ago, that there were no organic hops,

17 because all hops are pre-contracted. So until we

18 could actually start encouraging people to pre19 contract for organic hops, you were not going to

20 just go out and find organic hops.

21 And so I don't know, like, you know,

22 your question about what is the critical mass, we
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1 don't know how many tons of these intestines, or

2 what meat, or what facilities.

3 It could also be how perishable the

4 product is. So if you're trying to consolidate it

5 from a variety of different smaller houses, is

6 that the issue? Where are the issues? But it's

7 not something that we, as a Board, could do.

8 But I don't think we've ever actually

9 done a TR on 606. But that could be a project to

10 kind of think of what kind of questions would need

11 to be asked. And then we could try to see -- have

12 a little better understanding of why they're on

13 606, and what are the barriers, and possibly how

14 quickly they could come off.

15 MS. DE LIMA: Tom?

16 MR. CHAPMAN: Yes. So on the hops

17 example, the way that came off the list was the

18 group of hops producers got together, formed an

19 organic hop consortium, and again, an industry20 interested group got it off the list through the

21 Sunset process.

22 In terms of a key owner for 606 items,
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1 a commercial availability, my day job, when I'm

2 not up here telling you guys about how much time

3 we have left on the agenda, is a sourcing manager

4 for organic ingredients for a large company, large

5 organic company anyway. And so in a sense, that's

6 what I do in my day job.

7 It's not something that can easily be

8 doled out to a technical resource to try to assess

9 what all those barriers are, what's available, as

10 well as assess the true demand in the marketplace. 

11 That's an extremely hard thing to assess.

12 And I can tell from my own personal

13 experience, when we launch new products with a

14 team of experts, I would say, that we have made

15 mistakes in mis-assessing the market and

16 availability of products. It happens quite

17 frequently, oddly enough, and, you know, being

18 unable to support purchasing an organic item

19 because of quick or rapid changes in the

20 marketplace.

21 So I just -- I would like more

22 resources on it. I don't know if the technical --
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1 technical reports can't solve all of our problems. 

2 And I don't know if that's going to be a viable

3 place to find those solutions. And lastly, I

4 don't think our current pool of contracted TR

5 organizations are qualified to answer these

6 questions.

7 MS. DE LIMA: Harriet?

8 MS. BEHAR: Perhaps though, when 606

9 items are first put on the list and being

10 petitioned, we could maybe look at better

11 questions there, at that time, to find out what

12 are the manufacturing constraints and, you know,

13 especially when a petitioner comes, why, you know,

14 why can't you find it organically?

15 We had the same issue with okra, for

16 those of us in the audience that remember that,

17 which never got on the list. Because it was just

18 like, well, I can't find it. But it's like, you

19 know, well, there's lots of growers growing okra

20 within range of the facility that you're currently

21 using for your IQF production.

22 So I think that the 606 could be,
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1 somewhat, and would also be good for petitioners

2 when they petition, you know, to get some of that

3 information up front so we're not just kind of

4 blind about how this has happened. We have a

5 better idea of, yes, this is really a problem, and

6 we're still waiting for that critical mass to get

7 it as organic.

8 MS. DE LIMA: Any other discussion? 

9 All right, seeing none, moving on to konjac flour. 

10 Dr. Brines?

11 DR. BRINES: Thank you. In the same

12 section, this listing reads as, "Konjac flour, CAS

13 Number 37220-17-0." Thanks.

14 MS. DE LIMA: Scott?

15 MR. RICE: Thank you. Konjac flour is

16 derived from tubers of the elephant yam,

17 Amorphophallus konjac. And it's primarily grown

18 in tropical and subtropical regions of Asia. It's

19 also called glucomannan. It's a soluble fiber, a

20 dietary fiber that's been used in traditional

21 foods in Asia such as the shirataki noodles and

22 konjac curd, also known as konnyaku.
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1 Shirataki noodles are marketed in the

2 West as a zero calorie, zero carbohydrate

3 alternative to pasta and rice. It's also used as

4 a binder, gelling agent, thickener, and

5 stabilizer. It is unique in its ability to absorb

6 up to 50 times its weight in water. Don't eat too

7 much at one time.

8 (Laughter)

9 MR. RICE: And for that reason, a quick

10 side note, there is some concern regarding its

11 potential in capsule supplements or noodles to

12 block the esophagus. However, it appears this is

13 largely avoided by consuming those capsules with

14 plenty of water and the sufficient chewing of the

15 noodles.

16 An Internet search found several

17 commercially available organic konjac products,

18 including alternatives to rice and several forms

19 of pasta, such as spaghetti and fettuccine, made

20 from organic konjac flour.

21 This was last reviewed at the fall 2015

22 meeting when nine voted to re-list and five to
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1 remove. At that time, no public comment was

2 received, no new information regarding the

3 criteria and sources of organic konjac flour were

4 identified in public comment.

5 There appears to be increased

6 availability of konjac sources, particularly for

7 gluten free alternatives to pasta and rice

8 products. During this first round, we asked if

9 there were sources of konjac sufficient to provide

10 manufacturers with the form and function required

11 for other organic products noted as using konjac,

12 such as sausages, fruit gels, and supplement

13 powders.

14 So in the comments this time around, we

15 heard from three certifiers indicating none of

16 their certified operations used this in its Sunset

17 surveys. The Organic Trade Association did not

18 receive any indications of its use.

19 We had, in support of its re-listing,

20 we had a food additives trade organization support

21 the re-listing citing uncertainty of quality,

22 consistency, and abundance of supply and also
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1 questioning the ability of organic claims on

2 international sources.

3 One public commenter supported the re4 listing. And, as I said, other than the trade

5 organization, no organic processor submitted

6 comments in support of this.

7 In terms of comments against re8 listing, we heard concerns that there could be GE

9 sources of konjac in the market and that these not

10 be used in organic production.

11 Other commenters cited concerns around

12 the hazards of pesticides used in its culture in

13 conventional production and citing availability of

14 organic konjac flour.

15 One comment further noted pesticides

16 associated with the conventional konjac production

17 and notes that any consideration should

18 acknowledge the negative factors of this use when

19 choosing to re-list.

20 MS. DE LIMA: Thank you, Scott. Tom,

21 and then Emily.

22 MR. CHAPMAN: So in terms of reaching
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1 that, like, consensus or ability to say there is

2 supply or not, this is one where I do have

3 questions around, and I would like more input from

4 the community where possible.

5 You know, the Organic Integrity

6 Database lists several konjac suppliers. So it is

7 available in some form in some quantity. And I

8 have also seen konjac products on the shelf that

9 were certified organic. And so again, that's

10 showing that there's an availability and a

11 quantity of it.

12 So, you know, I'd really like to get

13 more information as to what's constraining the use

14 of that. And there's others, some concerns around

15 origin. And I'd, you know, like to get some more

16 concrete detail about that as well.

17 MS. DE LIMA: Emily?

18 MS. OAKLEY: And so based on that and

19 on what Scott summarized, I know this is probably

20 premature as well, but is there any indication

21 from the Handling Subcommittee about where they

22 might head with this or you might head with this?
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1 MR. RICE: I would echo Tom's comments

2 that we're looking for more support for this or

3 more indication that it's still needed. Judging

4 from the last review, there were similar concerns

5 that -- or questions whether the supply has become

6 prevalent enough to support at Sunset.

7 MS. DE LIMA: Steve?

8 MR. ELA: To me, this is one that --

9 the public comment in the fall, if there's nobody

10 that steps forward and says we absolutely need

11 this, it's going to be pretty hard to support re12 listing, given that there're alternatives

13 available.

14 I mean, I guess if there are companies

15 out there, not just trade organizations, that say

16 we need this, then I think they should step up and

17 note that. Otherwise, it's pretty hard to

18 support.

19 MS. DE LIMA: And I will say I haven't

20 seen it. We sell organic konjac noodles, and I

21 see other products with non-organic konjac in it.

22 But they're not certified organic products. So to
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1 echo the sentiment, yes, we need to see some

2 manufacturers step forward and explain why they

3 need it, non-organically. Harriet?

4 MS. BEHAR: So this is another area

5 where we perhaps don't know. And I'm not even

6 sure. I don't know what kind of pesticides are

7 being used on konjac.

8 And there's sometimes, especially in

9 Third World countries where it's not so much the

10 pesticides, not that they can't use them, but this

11 organic certification is not necessarily always

12 something that's being done if it's the small

13 farmers and whatever.

14 So I don't know. It would be nice to

15 know how conventional konjac flour is grown and

16 perhaps even how close those producers might be to

17 just getting certified. I mean, it may not just

18 -- it might not be that it's conventionally

19 produced but that it's just not certified.

20 MS. DE LIMA: All right, any other

21 discussion? Seeing none, we will move on to

22 pectin. Dr. Brines?
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1 DR. BRINES: Thank you. And this is

2 the last substance on the handling list of Sunset

3 materials. And continuing under 205.606, the

4 listing reads as, pectin non-amidated forms only. 

5 Thank you.

6 MS. DE LIMA: Tom?

7 MR. CHAPMAN: Pectin is used as a

8 gelling agent in jams, preserves, fillings and

9 other products. The most common production of

10 non-amidated pectin is through the treatment of

11 pectin-containing byproducts like palm fruit cores

12 or citrus peels with acidified water. The

13 insoluble materials are filtered and removed, and

14 pectin is participated out with alcohol.

15 International standards generally all

16 allow pectin with various restrictions. Public

17 comments received by organic manufacturers, trade

18 associations, material suppliers and certifiers

19 spoke extensively to the use of pectin and its

20 essentiality in organic products.

21 A comment received about organic

22 pectins listed on the Organic Integrity Database
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1 were in part or all for use as a dietary

2 supplement but not as a gelling agent.

3 Comments from the trade association

4 representing the pectin industry spoke to

5 constraints in commercializing organic pectins due

6 to commingled raw materials. And additionally,

7 they spoke to its unavailability of organic

8 pectin.

9 One comment received from an interest

10 group stated that pectin should be limited to high

11 methoxyl pectin extracted form citrus peel and

12 apple pomace. And I also wanted to note an

13 evaluation of the pesticides used on those

14 conventional non-organic raw materials.

15 MS. DE LIMA: Thank you, Tom. Any

16 questions or discussion from the Board? Steve?

17 MR. ELA: I just noticed any -- it used

18 to be we, NOSB, characterized high methoxy and low

19 methoxy pectins. And since we've switched to

20 amidated and non-amidated, I noticed a couple of

21 the comments still were referring to high methoxy,

22 low methoxy which now don't have a correlation
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1 within the rules.

2 So I would encourage people making

3 comments to try and address to what the current

4 listing is. Because, at least as a non-chemist

5 member who uses pectin, I don't always know those

6 associations.

7 MS. DE LIMA: Asa and then Harriet.

8 MR. BRADMAN: Tom, I just wanted to ask

9 for a clarification in your last statement. You

10 said that there's concern about pesticide residues

11 in the pomace or peels?

12 MR. CHAPMAN: No. I think the concern

13 was around, similar to other comments on 606

14 items, just there should be evaluation of the

15 impact of conventional agricultural production

16 inputs in apples and citrus in general as part of

17 the review of a conventional item.

18 MR. BRADMAN: So not as a residue in

19 the material that's being processed?

20 MR. CHAPMAN: That's not how I took

21 it, no.

22 MR. BRADMAN: Okay. I mean, certainly
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1 there are a lot of, you know, synthetic excluded

2 materials that are used on citrus and apples. You

3 know, we've seen, for example, relationships

4 between intake of non-organic apple juice and, you

5 know, higher metabolite and pesticide metabolite

6 levels in urine. And it's clear that there's a

7 lot of materials used on those products.

8 MS. DE LIMA: Harriet?

9 MS. BEHAR: Again, I wish I knew more

10 about the constraints other than it's difficult to

11 separate, as we did ask one of the public

12 commenters. And as someone who has extracted

13 pectin in my own kitchen and made jelly, it

14 doesn't seem like that difficult of a process.

15 But again, I don't know how large the

16 facilities are that are making pectin and what the

17 critical mass is to obtain enough organic. But

18 I'm sure there's a lot. I've been to processing

19 facilities where there's a lot of peels and cores.

20 So again, I feel a little bit like we

21 don't have the information of what the constraints

22 are. And we're just kind of hoping that the
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1 industry will come in, and see this need, and fill

2 it. But, you know, it's a little bit hard for me

3 to just, like, vote for something without knowing

4 why it's not there.

5 MS. DE LIMA: Steve?

6 MR. ELA: And in part, an answer to

7 that, I mean, I think it is -- still there's a lot

8 of pectin used in this nation. And so I think it

9 still comes back to supply. And I think that's

10 where the comments went.

11 I know, in our own situation with our

12 jams, you know, we've talked to our supplier, and

13 they're very aware that people want an organic

14 pectin. Because we asked the question. And

15 they're, like, oh, yes, that's not the first time

16 we've been asked.

17 So I think there is some awareness in

18 the pectin industry that there should be or wants

19 to be an organic alternative. And my sense is the

20 supply just still isn't there.

21 MS. DE LIMA: Tom?

22 MR. CHAPMAN: Yes. And there was
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1 actually, I believe a global shortage of

2 conventional pectin in 2015. So, yes, there's a

3 lot of pectin in use.

4 And then, you know, the opposite side

5 of that need is that sounds like an excellent

6 economic opportunity for someone to start an

7 organic pectin operation and charge whatever they

8 want.

9 MS. BEHAR: In my kitchen.

10 MR. CHAPMAN: In your kitchen.

11 (Laughter.)

12 MR. CHAPMAN: Just remember FSMA.

13 MS. DE LIMA: All right, any other

14 discussion on pectin?

15 All right, seeing none, that concludes

16 the Sunset. So we're going to move on to

17 proposals, starting with L-Methionine. Ashley?

18 DR. BRINES: All right. So I'll go

19 ahead and introduce it and then turn it over to

20 Ashley --

21 MS. DE LIMA: Oh, sorry, Dr. Brines.

22 DR. BRINES: -- as the lead. Thank
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1 you. So this material, L-Methionine, was

2 petitioned by Nature's One, Incorporated, and the

3 petition was received on August 3rd, 2016. The

4 petition requests the addition of L-Methionine to

5 Section 205.605(b) of the National List as an

6 ingredient for organic products.

7 There was a technical report developed

8 in support of the review of this substance from

9 the last time the Board reviewed it. The

10 technical report is dated 2012 and is available on

11 the NOP website. And this is the first meeting at

12 which this particular petition is being reviewed

13 by the Board. Thanks.

14 MS. DE LIMA: Ashley?

15 MS. SWAFFAR: Okay. So, L-Methionine

16 has been petitioned to be added to 605.205(b),

17 allowed in or on nutritionally complete enteral

18 pediatric formulas labeled organic or made with

19 organic, with the annotation, for use in

20 nutritionally complete pediatric enteral formulas

21 based on soy protein.

22 Methionine is an amino acid essential
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1 for humans and poultry alike.

2 L-Methionine exists in a category where

3 there has been much controversy. In 1995, the

4 NOSB made the following recommendation.

5 The use of nutritional supplementation

6 in organic foods, upon implementation of the

7 National Organic Program, the use of synthetic

8 vitamins, minerals and/or accessory nutrients in

9 products labeled as organic, must be limited to

10 that which is required by regulation or a

11 recommendation for enrichment and fortification by

12 the Independent Professional Association.

13 Since that recommendation, the NOP

14 published a proposed rule that clarifies a

15 previous reference to FDA's 21 CFR 104.20, for

16 nutrient vitamins and minerals, which indicates

17 that L-Methionine would not be allowed under that

18 provision. Hence the separate petition for its

19 inclusion on the national list.

20 Like I said, L-Methionine is petitioned

21 with a very narrow annotation. This would be

22 added to organic soy-based enteral products, so
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1 that they would meet the nutritional requirements

2 for a protein.

3 We did get several comments on this. 

4 Several on the pro side say that they support this

5 specific listing and soy protein diets are

6 inadequate without L-Methionine.

7 The comment against it said that they

8 believe that infant and pediatric enteral formulas

9 do not meet the compatibility criteria for listing

10 materials on the national list for products

11 labeled organic or 100 percent organic.

12 For those cases in which such a formula

13 is necessary, they do support high quality formula

14 labeled made with organic.

15 And I do want to clarify, this is just

16 for pediatric enteral formulas, not for all infant

17 formulas. So that's a quick summary.

18 MS. DE LIMA: Tom.

19 CHAIR CHAPMAN: I'd like to add a

20 couple more points on that. So in 2012 -- it

21 could be 2011, I could be a year off -- the Board

22 passed a different proposal related to vitamins
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1 and minerals that were waiting for the program to

2 rule make against, and in addition to that,

3 reviewed several proposals related, or petitions

4 related, to various ancillary nutrients and

5 minerals and other items.

6 One of those was L-Methionine for an

7 infant formula. And the NOSB, at that time,

8 approved and passed that. So there is a sitting

9 recommendation already from the NOSB to list L10 Methionine for an infant formula. So this

11 expansion is just to take that and apply it to

12 pediatric enteral formulas.

13 Another one of the comments that spoke

14 to supporting it only in a listing for made with

15 organic, I want to dig into that one a little bit. 

16 Their concerns seem to be focused around soy

17 protein isolate.

18 Which soy protein isolate, as an

19 industry term, is generally a soy protein that's

20 been purified to 80 percent or greater. Soy

21 protein isolate is generally produced today using

22 hexane extraction.
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1 The use of hexane is not allowed in

2 organic products, and soy protein isolate is not

3 listed on 606. So in theory, soy protein isolate

4 is not available in organic product and could not

5 be used in an organic product. Ninety-five

6 percent or higher.

7 However, the hexane acts on the oil

8 portion of the soy, and so the protein is just

9 naturally there. It gets purified out. It would

10 be considered agricultural under our decision tree

11 and so could be used in a made with organic

12 products.

13 So if you're opposed to the use of soy

14 protein isolate listing L-Methionine, for made

15 with organic products only, it would actually open

16 the door for the use of soy protein isolates in

17 these products. Or allowing its usage in organic

18 products would not allow that in an organic

19 product and restrict substances like soy protein

20 concentrate, which is generally a lower fraction

21 of protein, and produced through organic and

22 physical means.
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1 So if your concern is with soy protein

2 isolate, I don't see that as a relevant concern to

3 the listing of L-Methionine.

4 MS. DE LIMA: Is there any other

5 questions from the Board? Just a reminder for

6 folks, this is a proposal so we are going to be

7 voting, once on a classification and then whether

8 to list or not list. Emily and then A-Dae.

9 MS. OAKLEY: Yes, I just wanted to say

10 that that clarification is very helpful for me. 

11 Thank you.

12 MS. DE LIMA: A-Dae.

13 MS. ROMERO-BRIONES: I just have a

14 question. So enteral formulas, can you define

15 that for me just so I am clear about what that is?

16 MS. SWAFFAR: Enteral formulas are

17 feeding tubes. The commenter yesterday, I

18 believe, you go through the nose, down in the

19 throat, some in the stomach. Yes, Tom, you got --

20 MS. ROMERO-BRIONES: And then my second

21 question is, so, these formulas are not typically

22 sold on the market? Or are they sold on the
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1 market or primarily used in hospitals?

2 CHAIR CHAPMAN: So, a couple things. 

3 One thing I should, it's a personal item, like I

4 said, we'll disclose it for the record. My

5 daughter has an enteral feeding tube and we use it

6 from time to time to provide her with complete

7 nutrition.

8 So enteral feeding products are

9 classified and coded under the Medicare

10 classifications. However, not everyone has

11 medical insurance, so they are available for both

12 personal purchasing as well as through insurance

13 potentially.

14 However, they are, enteral formulas

15 will be marketed as enteral formulas and they'll

16 have that Medicare designation on them.

17 MS. ROMERO-BRIONES: So you can buy

18 those -- so where do you buy these products?

19 CHAIR CHAPMAN: I don't know,

20 everywhere. You can buy it on Amazon, I'm sure

21 you can but it from the company itself directly.

22 MS. ROMERO-BRIONES: Okay. That was my
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1 question.

2 CHAIR CHAPMAN: Potentially.

3 MS. DE LIMA: Harriet.

4 MS. BEHAR: Well, if we vote for the L5 Methionine, it would open the door to people who

6 use these products to have an organic version,

7 which would mean they wouldn't have to use a

8 conventional version, which would have had soy

9 protein isolate that could have been extracted by

10 hexane.

11 I'm seeing people shaking their head

12 yes.

13 MS. DE LIMA: Tom.

14 CHAIR CHAPMAN: Yes, I mean these

15 products are marketed towards the most fragile

16 populations out there. Kids with very advanced

17 medical issues. So people you'd want to have

18 access to organic products.

19 MS. DE LIMA: Any other discussion from

20 the Board? Okay, so seeing none, we're going to

21 move to a vote.

22 So first it's going to be the
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1 classification vote. So this comes from the

2 subcommittee as a classification motion to

3 classify L-Methionine as non-agricultural

4 synthetic. Tom.

5 CHAIR CHAPMAN: Oh yes, I am running

6 the votes.

7 MS. DE LIMA: Yes.

8 CHAIR CHAPMAN: That's correct. So we

9 will start the voting with A-Dae.

10 This is a motion that comes seconded. 

11 A motion to classify L-Methionine as petitioned as

12 non-agricultural synthetic.

13 It came motioned by Tracy Favre, when

14 she was on the board and seconded by Harold

15 Austin, while he was on the board. Now, the vote

16 threshold for this is two-thirds and we'll start

17 with A-Dae.

18 MS. ROMERO-BRIONES: Just to clarify,

19 we're voting on the classification --

20 CHAIR CHAPMAN: Classification.

21 MS. DE LIMA: Correct.

22 CHAIR CHAPMAN: A yes vote is to
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1 classify as the synthetic.

2 MS. ROMERO-BRIONES: Yes.

3 MS. DE LIMA: Yes.

4 MR. BRADMAN: Yes.

5 MS. MOSSO: Yes.

6 MR. ELA: Yes.

7 MR. MORTENSEN: Yes.

8 MS. DE LIMA: Jesse?

9 MR. BUIE: Yes.

10 MS. SWAFFAR: Yes.

11 DR. SEITZ: Yes.

12 MR. RICE: Yes.

13 MS. BAIRD: Yes.

14 MS. BEHAR: Yes.

15 MS. OAKLEY: Yes.

16 DR. THICKE: Yes.

17 CHAIR CHAPMAN: Chair votes Yes.

18 MS. DE LIMA: We should probably go a

19 little slower when we're doing the next votes for

20 Michelle, right? That was a little fast. She

21 warned us to go slow.

22 CHAIR CHAPMAN: Yes. 15 yes, zero no. 
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1 The motion passes.

2 The next motion is a motion to add L3 Methionine, as petitioned, to 205.605(b). It

4 comes as a seconded motion from the subcommittee.

5 It was made by Tracy Favre and seconded

6 by Jean Richardson, both while on the board. This

7 also requires a two-thirds vote.

8 And we'll start the vote with Lisa and

9 a yes vote is to list this material. This will

10 recommend listing of this material. Lisa?

11 MS. DE LIMA: Yes.

12 MR. BRADMAN: Yes.

13 MS. MOSSO: Yes.

14 MR. ELA: Yes.

15 MR. MORTENSEN: Yes.

16 MR. BUIE: Yes.

17 MS. SWAFFAR: Yes.

18 DR. SEITZ: Yes.

19 MR. RICE: Yes.

20 MS. BAIRD: Yes.

21 MS. BEHAR: Yes.

22 MS. OAKLEY: Yes.
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1 DR. THICKE: Yes.

2 MS. ROMERO-BRIONES: Yes.

3 CHAIR CHAPMAN: Chair votes yes. 15

4 yes, zero no. The motion passes.

5 MS. DE LIMA: All right. Moving on to

6 the next petition, which is Short DNA Tracers, Dr.

7 Brines.

8 DR. BRINES: Thank you. This petition

9 was received on October 14th, 2016. Was submitted

10 by Safe Traces, Inc.

11 The petition requests the addition of

12 short DNA tracers to Section 205.605 of the

13 national list. There was an addendum to the

14 petition that was submitted, and is also posted

15 alongside the petition on the NOP website. And

16 that addendum was submitted on February 10th,

17 2017.

18 And there is no technical report

19 requested or developed in support of the

20 subcommittee's review of this material. And this

21 is the first meeting at which this petition

22 material has been discussed. Thanks.
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1 MS. DE LIMA: Thank you. So short DNA

2 tracers, the petitioner states that the inclusion

3 of short DNA tracers in organics would be an

4 improved method for traceability. And that

5 current record keeping practices could be

6 simplified and/or supplemented by using short DNA

7 tracers.

8 An advantage pointed out by the

9 petition is that since short DNA tracers are added

10 directly to the food and not to the packaging, it

11 cannot be separated from the food, either

12 accidentally or intentionally. And additionally,

13 short DNA tracers do not affect appearance,

14 flavor, aroma or nutritional values, of these

15 foods.

16 The short DNA tracers could be added by

17 processors to wax or other coatings used in fresh

18 fruits and vegetables. They can also be added to

19 dried products in powder form, encapsulated in

20 various materials that are certified organic or

21 currently included on 205.605 or 606. Such as

22 maltodextrin, agar-agar, et cetera.
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1 They also can be added directly in

2 liquid form to liquid products, such as wine,

3 olive oil or honey.

4 To obtain maximum sensitivity

5 producers, it's recommended that producers include

6 short DNA tracers and food at levels around 1

7 milligram per ton.

8 The addition of a distinct short DNA

9 tracer would be distinguishable through testing at

10 different points in the supply chain. So it would

11 be basically tracing the movement and the

12 authenticity of the food or the ingredient, which

13 contained the short DNA tracer.

14 Basically, the Handling Subcommittee

15 talked about this and voted not to list. We just

16 didn't think that the use of short DNA tracers

17 could be considered essential for the handling of

18 organic products.

19 You know, production and sale of

20 organic products is established and continues to

21 grow without the use of something similar to a

22 short DNA tracer.
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1 And public comment also pointed out

2 that the production method of short DNA tracers

3 falls within the excluded methods terminology. 

4 Where the term modern biotechnology is defined in

5 part as the application of in vitro nucleic acid

6 technologies.

7 And the petitioner's use of PCR

8 technology to create the large number of copies of

9 a specific short DNA sequence, would qualify under

10 that definition as an excluded method.

11 Public comment was largely against

12 adding this material to the national list.

13 There were two comments in favor. One

14 from the petitioner and one from a cotton textile

15 manufacturer, who did not state whether they are

16 currently engaged in organic cotton production or

17 trade.

18 So with that, I'm going to open it up

19 to the Board. Discussion, questions? Harriet.

20 MS. BEHAR: So, are you saying this

21 material falls under our excluded method

22 definition? Just clarifying or --
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1 MS. DE LIMA: Yes.

2 MS. BEHAR: Okay. And the other thing

3 that I was wondering too, just about the

4 technology and it seems to be tied to one company,

5 and kind of needing, you know, that people would

6 need to be then purchasing the technology from

7 them to do the tracing and it was somewhat of a

8 marketing, you know, kind of a monopoly marketing

9 also. It seemed like, really that much like a

10 generic material to me. It was like a proprietary

11 material.

12 MS. DE LIMA: Any other discussion

13 before we vote? Steve.

14 MR. ELA: I'll just say, I think the

15 other thing in traceability is that it can be used

16 to trace a product back to its name for food

17 safety, but it wouldn't refer to if an organic

18 product was added to by a conventional product. 

19 So it only does one side of the traceability

20 thing.

21 I mean, if you're going to dilute

22 organic product with a conventional, then the
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1 tracer is still in there, from the organic

2 product, and it doesn't really address that. So

3 I'm not even sure if fully addresses the

4 traceability issue.

5 MS. DE LIMA: All right. Steve.

6 MR. MORTENSEN: And during the course

7 of the public comment on, last week, on Thursday

8 and yesterday and today, there were a number of

9 times it was alluded to the fact that we are going

10 to be tracing grain movement from Turkey and the

11 Ukraine more effectively. And there may be some

12 truth in that.

13 But it seems to me that that's a boots

14 on the ground problem. The actual documentation

15 of what's going on at the source.

16 I've been in some of those places and

17 visited some of the farms where we would be

18 discussing methods of production, and I think that

19 is an integral part of solving the problem where

20 we heard about grain coming. Where there was

21 concern about sufficient documentation of the

22 production methods.
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1 MS. DE LIMA: Francis.

2 DR. THICKE: It seems to me that this

3 is a solution looking for a problem.

4 MS. DE LIMA: All right, I don't see

5 any more discussion, so we're going to move ahead,

6 first with the classification vote. Tom.

7 CHAIR CHAPMAN: Thank you. So, the

8 motion is to classify short DNA tracers as non9 agricultural synthetic.

10 The motion was made by Lisa De Lima and

11 seconded by Scott Rice. This comes as a seconded

12 motion from the Subcommittee.

13 The voting will start with Asa. A yes

14 vote on this is to classify it as synthetic. Asa?

15 MR. BRADMAN: Yes.

16 MS. MOSSO: Yes.

17 MR. ELA: Yes.

18 MR. MORTENSEN: Yes.

19 MR. BUIE: Yes.

20 MS. SWAFFAR: Yes.

21 DR. SEITZ: Yes.

22 MR. RICE: Yes.
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1 MS. BAIRD: Yes.

2 MS. BEHAR: Yes.

3 MS. OAKLEY: Yes

4 DR. THICKE: Yes.

5 MS. ROMERO-BRIONES: Yes.

6 MS. DE LIMA: Yes.

7 CHAIR CHAPMAN: Chair votes yes. 15

8 yes, zero no, the motion passes.

9 Scroll down, Michelle.

10 All right, the next motion is a motion

11 to list, or a motion to add, short DNA tracers as

12 petitioned, at 205.605(b).

13 This is a motion made by Lisa De Lima

14 and seconded by Asa Bradman. It was not

15 recommended by the Subcommittee, as you can by the

16 vote there, zero yes and 6 no.

17 But a yes vote on this motion is to

18 list the item, a no vote is to not list the item. 

19 Voting will start with Joelle. And it takes a

20 two-thirds threshold.

21 MS. MOSSO: No.

22 MR. ELA: No.
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1 MR. MORTENSEN: No.

2 MR. BUIE: No.

3 MS. SWAFFAR: No.

4 DR. SEITZ: No.

5 MR. RICE: No.

6 MS. BAIRD: No.

7 MS. BEHAR: Nope.

8 MS. OAKLEY: No.

9 DR. THICKE: No.

10 MS. ROMERO-BRIONES: No.

11 MS. DE LIMA: No.

12 MR. BRADMAN: No.

13 CHAIR CHAPMAN: Jesse, I'm just going

14 to ask you to say your vote again, because I don't

15 think your mic was on. So was it recorded? Can

16 you just say your vote again?

17 MR. BUIE: No.

18 CHAIR CHAPMAN: Thank you. And the

19 chair votes no.

20 The vote is zero yes, 15 no. The

21 motion fails.

22 MS. DE LIMA: All right, moving on to
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1 tocopherols. Dr. Brines.

2 DR. BRINES: Thank you. For the rest

3 of the items on the handling agenda for today,

4 since they weren't a result of the petitioner,

5 Sunset, I'll defer to the Board to take those

6 away.

7 MS. DE LIMA: Okay.

8 DR. BRINES: Thanks.

9 MS. DE LIMA: Tom.

10 CHAIR CHAPMAN: Okay. Tocopherols, let

11 me pull it up. I will make this brief.

12 The point of this proposal was to

13 encourage the use of nonsynthetic agricultural

14 organic forms of tocopherols. And this was in

15 related to public comment that we had received.

16 The 2017 Sunset Review, so that was in

17 2015, about availability to some degree of

18 nonsynthetic versions of tocopherols and that we

19 should be encouraging the use of nonsynthetics.

20 I'm going to make a general industry

21 point and then get into the public comment. I do

22 want to point out that in the industry,
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1 tocopherols synthetic versus nonsynthetic are used

2 differently than in the organic industry, where we

3 have a different synthetic versus nonsynthetic

4 definition.

5 In the industry, a synthetic version is

6 derived from a petrochemical or something like

7 that. A nonsynthetic is derived from an animal or

8 a vegetable source.

9 The annotation, as it lists now, limits

10 is to a vegetable source or vegetable oil. And so

11 that may be a source of some confusion and why we

12 get such a mix message on availability on the

13 substance.

14 All right, moving on to the public

15 comment about our proposal. Sorry, I just need to

16 pull up my notes.

17 The tocopherol proposal received mixed

18 comments from the community, from comments stating

19 they did not have enough time to review the

20 proposal to some recommending holding off on this

21 proposal until it was listed on 205.605(a).

22 Some commented on the confusion and/or
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1 if it was sensible to have certifiers digging into

2 synthetic versus nonsynthetic inputs, if it was

3 listed on the synthetic list.

4 Other commenters pointed out this

5 proposal, without listing on 606, would prohibit

6 agricultural, conventional agricultural forms of

7 this substance. So it would allow nonsynthetic

8 and organic, but not conventional agricultural

9 forms.

10 And some also recommended changes to

11 the annotation wording.

12 Finally, others just supported the

13 proposal as is.

14 Most commenters supported prioritizing

15 organic forms first, then agricultural forms, then

16 nonagricultural natural forms and finally,

17 synthetic forms.

18 Concerns around GMOs in the raw

19 materials was also raised. However, the program

20 also stated, for the record, that excluded methods

21 prohibition applied to both 605 and 606 materials.

22 Given the comments received and the
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1 variety of input, I do think, as the lead on this

2 item, that it is prudent for us to take this back

3 to the subcommittee at this time, for further

4 consideration. But I would now open it up for

5 questions and dialogue from the Board.

6 MS. DE LIMA: Dan and then Harriet.

7 DR. SEITZ: I'm still a little confused

8 about whether you could use synthetic solvents

9 with the vegetable oil.

10 So I understand you couldn't use

11 genetically modified vegetable oils, but I was

12 reading what our regs say about the use of, say

13 hexane or whatever, a volatile solvent. Would

14 that be allowed, potentially, if you, with the

15 wording as is, or not?

16 CHAIR CHAPMAN: With the wording as is,

17 I believe hexane extraction of the vegetable oil

18 would be an allowable process. Yes.

19 DR. SEITZ: And did the subcommittee

20 see that as an issue, based on the public comments

21 on that?

22 CHAIR CHAPMAN: Assessed out of the
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1 scope of what we were reviewing. We were

2 reviewing the listing of how it was, that would

3 have been reviewed at Sunset Review. So I don't

4 think we've taken that into deep consideration.

5 MS. DE LIMA: Harriet.

6 MS. BEHAR: Would material review

7 organizations be asking for a non-GMO affidavit on

8 this product?

9 CHAIR CHAPMAN: I can refer to the

10 certifier on the Board. That's a good question,

11 but I don't know if I can answer it at this time.

12 However, I do want to note that our

13 listing of this was to review the annotation and

14 whether it should be on A or B, not its actual

15 presence on the list.

16 MS. DE LIMA: Scott.

17 CHAIR CHAPMAN: Scott's got something.

18 MR. RICE: The question was whether you

19 look for a GMO affidavit on any material for

20 consideration.

21 MS. BEHAR: When this is being proposed

22 to be put in an organic product, would they
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1 request a non-GMO affidavit for it? Like they do

2 for yeast or they do for a variety of other

3 products.

4 MR. RICE: I'd have to double check on

5 that.

6 CHAIR CHAPMAN: I can speak as a

7 purchaser of tocopherol as non-GMO tocopherols are

8 available on the market and marketed as such. 

9 Through from like IP, IP oil materials.

10 MS. BEHAR: But as listed, it doesn't

11 say non-GMO.

12 CHAIR CHAPMAN: Yes. It didn't fully

13 answer your question, but I guess was getting at

14 it.

15 MS. BEHAR: Right.

16 CHAIR CHAPMAN: But I know there is an

17 availability and supply of the non-GMO products.

18 MS. BEHAR: Right. But I know there

19 are numerous products that non-GMO affidavits,

20 having been a reviewer, are asked for, for a

21 variety of different products, just to make sure

22 that the source wasn't. And I don't remember if
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1 tocopherols was one of those products.

2 I don't know if we want to ask someone. 

3 If OMRI does that or --

4 CHAIR CHAPMAN: I mean, at this point,

5 it's beyond the scope of what this listing is on

6 our work agenda.

7 MR. RICE: I would clarify, yes, we

8 would look for that, but just to echo Tom, that's

9 beyond the scope here.

10 MS. DE LIMA: So right now we're just

11 discussing whether we want to reclassify, from B

12 to A.

13 Asa, did you have a question? No. 

14 Harriet.

15 MS. BEHAR: Just would be more

16 comfortable knowing whether or not this was one of

17 the items as reviewed for non-GMO, that's all.

18 I'm not saying that it should change

19 the annotation. I don't know what the typical

20 activity is in the certification world. For

21 what's currently being used in the market.

22 Because, couldn't tocopherols be made
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1 from soy?

2 CHAIR CHAPMAN: Yes. Yes, they can be. 

3 And I think that's a question that we should take

4 back. We can have that discussion on the

5 Subcommittee and we can utilize the open docket to

6 get comments from the community.

7 And Miles wants to say something.

8 MR. MCEVOY: Yes. Well, it's a very

9 interesting question about, what do the MROs do,

10 what's an affidavit, because there's different

11 types of affidavits.

12 So, it seems like it's a very good

13 question that maybe should go back to a

14 subcommittee and should be discussed about what is

15 the verification method for determining that

16 excluded methods aren't used in 605 materials or,

17 605 materials I guess is where you're at right

18 now.

19 So, it seems like that would be a good

20 question to ask the community, what are they

21 doing, what are certifiers doing, what are MROs

22 doing, what does the affidavit mean, right?
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1 Because you could have an affidavit

2 that says, no presence of GMO material is in the

3 final product versus no GMO substrate was used in

4 the production.

5 So how you write that affidavit, is it

6 an affidavit that's provided and they sign or is

7 it an affidavit that you're asking them to provide

8 and they put it in their own words? So that's a

9 good question, but it's a complicated subject.

10 MS. DE LIMA: Thank you, Miles. Tom.

11 CHAIR CHAPMAN: And larger than just

12 the tocopherol issue. It applies to probably

13 several substances on the list.

14 MS. DE LIMA: Ashley.

15 MS. SWAFFAR: So, I would like to move

16 to refer the proposal on tocopherols back to the

17 Handling Subcommittee.

18 CHAIR CHAPMAN: So there's a motion, is

19 there a second?

20 MS. ROMERO-BRIONES: I second.

21 CHAIR CHAPMAN: Okay.

22 MS. DE LIMA: So A-Dae --
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1 CHAIR CHAPMAN: That was --

2 MS. DE LIMA: Oh.

3 CHAIR CHAPMAN: -- A-Dae. Okay. It

4 was A-Dae, was it?

5 MS. DE LIMA: A-Dae.

6 CHAIR CHAPMAN: Yes. Okay. So we have

7 a motion to refer back to subcommittee, by Ashley,

8 and a second by A-Dae.

9 This only requires a majority to

10 approve this motion. And the voting will start

11 with Steve. A yes vote is to send this back to

12 subcommittee.

13 MR. ELA: Yes.

14 MR. MORTENSEN: Yes.

15 MR. BUIE: Yes.

16 MS. SWAFFAR: Yes.

17 DR. SEITZ: Yes.

18 MR. RICE: Yes.

19 MS. BAIRD: Yes.

20 MS. BEHAR: Yes.

21 MS. OAKLEY: Yes.

22 DR. THICKE: Yes.
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1 MS. ROMERO-BRIONES: Yes.

2 MS. DE LIMA: Yes.

3 MR. BRADMAN: Yes.

4 MS. MOSSO: Yes.

5 CHAIR CHAPMAN: Chair votes yes. 15

6 yes, zero no. The item is refereed back to

7 subcommittee.

8 MS. DE LIMA: All right, moving on to

9 marine algae listings. Scott.

10 MR. RICE: Thank you. During its five11 year Sunset Review, excuse me one second. We're

12 having technical issues over here.

13 During its five-year Sunset Review of

14 almost 200 materials, the NOSB and public comment

15 noted that the listings of the nine marine

16 materials on the national list includes overlap in

17 species and a lack of scientific clarity.

18 A discussion document was posted and

19 substantive public comment received in the fall of

20 2016. Based on public comment from a broad cross

21 section of stakeholders, this proposal recommends

22 that the marine algae materials be annotated with
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1 Latin binomials where possible, or by class. And

2 that the NOP review the word kelp as used in

3 organic production and clarify if marine materials

4 on the list should be classified as agricultural

5 or non-agricultural.

6 There are nine separate listings for

7 marine materials on the national list, which are

8 the subject of the documents. And important to

9 point out that there is an identical proposal also

10 brought forward by the Crop Subcommittee.

11 There's a number of public comments on

12 this. Commenters cautioned against too narrowly

13 defining or identifying species used, noting that

14 narrow definitions may exclude what is currently

15 being used in products or inputs.

16 Commenters also pointed to the illogic

17 of allowing the synthetic extraction of a brown

18 seaweed but not a red or a green one.

19 Commenters also noted the importance of

20 including genus, particularly for the agar-agar,

21 as a lack of genus may lead to the use of inputs,

22 such as carrageenan, which the Board recently
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1 voted to allow to Sunset.

2 One comment noted Latin binomials are

3 not static and many species have traditional and

4 modern Latin names, noting both should be listed. 

5 Other commenters were unclear on how the

6 Subcommittee determined the class and species

7 proposed, asking if this was because those noted

8 were from a sustainable source or simply commonly

9 used by industry.

10 Commenters noted that the goal of our

11 subcommittee's investigation should be to amend

12 the national list to identify with those Latin

13 binomials either specific species that are allowed

14 in organic or those that are prohibited due to

15 ecological impact concerns.

16 In terms of sustainability, one

17 commenter noted further guidance is needed to

18 restrict wild crop harvests to those that meet the

19 regulations.

20 To address the sustainability,

21 commenters said the focus and first step should be

22 on sourcing a certified organic source first.
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1 Another commenter pointed to marine

2 algae harvest should be added to eliminating the

3 incentive to convert native ecosystems as, with

4 the point that, to that discussion document,

5 citing conversion is also happening at intertidal

6 lands.

7 A number of commenters, as we've heard,

8 noted they did not have adequate time for review

9 and requested that the Subcommittee refer this

10 back for further consideration, until fall 2017 to

11 allow for full public engagement.

12 I wanted to be really clear that the

13 issue of sustainability was considered to a great

14 degree. Our recent Board Member, Jean Richardson,

15 who is the lead on this, invested a great deal of

16 time and energy into investigating harvest

17 practices of these materials and their sustainable

18 -- the sustainability of that harvest.

19 As you can imagine, she found an

20 immense amount of information on that. And in the

21 absence of clear and consistent definitions of

22 sustainable, as well as a numerous patchwork of
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1 standards around the globe addressing sustainable

2 harvest, the Subcommittee did not feel it could

3 address sustainability in a real hand-able way in

4 this proposal. However, we did want to move

5 forward with an effort to clarify and make

6 consistent listings of the marine algaes on the

7 national list.

8 I guess I would, Emily was the lead on

9 the crop side of this, so I would just invite her

10 to comment on anything that I didn't touch on here

11 or elaborate.

12 MS. OAKLEY: I'll just elaborate in

13 detail on the crops document and our discussion. 

14 But I do just want to add that, I want to echo

15 about the sustainability issue.

16 And that Dr. Richardson, when she wrote

17 this document in its first iteration through the

18 Subcommittees, did try to address the

19 sustainability issue. And the challenge right now

20 is defining that and measuring it.

21 So I would just ask, and put a plea out

22 there, for assistance from the stakeholders in
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1 helping us identify how we can measure and define

2 sustainable harvest in these materials.

3 MR. RICE: I'll open it up to further

4 discussion.

5 MS. DE LIMA: Thanks, Scott. 

6 Questions? Steve.

7 MR. MORTENSEN: I --

8 MS. DE LIMA: Oh, sorry, Dave.

9 MR. MORTENSEN: That's fine. So not

10 anything like critical, but I would just say,

11 reading this draft, I was really impressed with

12 like the detail in this draft and the specificity

13 in the draft.

14 It was clear that a great deal of time

15 went into figuring out what species were aligning

16 with what methods, et cetera. And I was just

17 really struck by that when I read through it.

18 MS. DE LIMA: Emily.

19 MS. OAKLEY: Yes, I want to echo that. 

20 And that's all Dr. Richardson's work. So, we are

21 grateful to her, for that.

22 And I know that there was some public
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1 comment over concern over how these listings got

2 made. And I think, I just want to refer people

3 back to the discussion document last fall and the

4 TR, to note that this is where Dr. Richardson came

5 up with these materials and classification of

6 Latin binomials.

7 And I think some of that is identified

8 in the background. And that was sort of the

9 expectation for identifying where these things

10 came from.

11 MR. MORTENSEN: I would also, the

12 fellow, David Hiltz, spoke to this briefly,

13 earlier, when I asked a question about it.

14 But I would find it really helpful, and

15 I'm happy to spend some time on it, but just to

16 understand better how this actually works in

17 practice, because a long time ago, I did graduate

18 work in this area where we would actually go out

19 and do the sampling and surveying and monitoring

20 of these populations and I'm still struggling to

21 see how the harvest works, where you're getting

22 mostly one species at a time or that you're
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1 sorting the species if you're getting five or ten

2 species in a cut. So any help on that, from the

3 commercial side, would be appreciated.

4 MS. DE LIMA: Ashley.

5 MS. SWAFFAR: So I move to refer the

6 handling proposal on marine algaes back to the

7 Handling Subcommittee.

8 CHAIR CHAPMAN: I have a motion, is

9 there a second?

10 MS. OAKLEY: I'll second.

11 CHAIR CHAPMAN: Okay. So, I have a

12 motion from Ashley and a second from Emily. The

13 motion is to refer the handling proposal on marine

14 algae listings back to the Handling Subcommittee.

15 A yes vote will send this back to

16 Subcommittee. It's a majority vote threshold. 

17 And the voting starts with Dave.

18 MR. MORTENSEN: Yes.

19 MR. BUIE: Yes.

20 MS. SWAFFAR: Yes.

21 DR. SEITZ: Yes.

22 MR. RICE: Yes.
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1 MS. BAIRD: Yes.

2 MS. BEHAR: Yes.

3 MS. OAKLEY: Yes.

4 DR. THICKE: Yes.

5 MS. ROMERO-BRIONES: Yes.

6 MS. DE LIMA: Yes.

7 MR. BRADMAN: Yes.

8 MS. MOSSO: Yes.

9 MR. ELA: Yes.

10 CHAIR CHAPMAN: Chair votes yes.

11 MS. DE LIMA: All right, moving on to

12 --

13 CHAIR CHAPMAN: I have to read the

14 results.

15 MS. DE LIMA: Oh sorry.

16 CHAIR CHAPMAN: I'm sorry.

17 MS. DE LIMA: I'm just trying to get us

18 some time.

19 CHAIR CHAPMAN: 15 yes, zero no. The

20 motion passes and the item is referred back to the

21 Handling Subcommittee.

22 MS. DE LIMA: All right, moving on to
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1 the next proposal, for ancillary substances

2 permitted in cellulose.

3 So currently, cellulose is listed at

4 205.605(b), for the use in regenerative casings,

5 as an anti-caking agent and filtering aid.

6 The Sunset Review for cellulose was

7 voted on at the last meeting and a chart of

8 ancillary substances for use in cellulose, was

9 included. However, during the second round of

10 public comment, additional ancillary substances

11 were identified.

12 And this happened after the final

13 proposal had already been posted, so this proposal

14 was created to add those ancillaries to the chart.

15 There were three ancillaries which we

16 received concern over in public comment. Vinyl

17 chloride, kymene and resin.

18 The vinyl chloride was definitely not

19 supposed to be on the chart. It should have just

20 read, polyvinylidene. Which corresponds with the

21 cast number that is on the chart. This was just

22 an honest mistake that was made. It wasn't caught
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1 in the transfer between the two leads on this

2 proposal.

3 So I'd like to see this sent back to

4 Subcommittee so we can clean that up, and also

5 continue a conversation and address the two other

6 ancillaries that were called into question in

7 public comment.

8 Opening it up for questions, comments,

9 discussion? Ashley. Oh, Asa.

10 MR. BRADMAN: I just want to say, I

11 think that's a good idea. I know I was thrown for

12 a loop when I saw the vinyl chloride there and

13 started looking things up, about 65, and stuff

14 like that.

15 MS. DE LIMA: It definitely was not

16 supposed to be on there.

17 MR. BRADMAN: Okay.

18 MS. DE LIMA: Ashley.

19 MS. SWAFFAR: I move to refer the

20 proposal on ancillary substances using cellulose

21 back to the Handling Subcommittee.

22 CHAIR CHAPMAN: All right, so we have
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1 a motion, is there a second?

2 MR. BRADMAN: I'll second.

3 CHAIR CHAPMAN: All right, Asa. It's

4 a race to the second.

5 So the motion is to refer the proposal

6 on ancillary substances using cellulose, back to

7 the Handling Subcommittee. The motion was made

8 Ashley, seconded by Asa.

9 It requires only a majority vote. And

10 the voting will start with Jesse. A yes vote is

11 to refer it back to the Subcommittee. Jesse?

12 MR. BUIE: Yes.

13 MS. SWAFFAR: Yes.

14 DR. SEITZ: Yes.

15 MR. RICE: Yes.

16 MS. BAIRD: Yes.

17 MS. BEHAR: Yes, sir.

18 MS. OAKLEY: Yes.

19 DR. THICKE: Yes.

20 MS. ROMERO-BRIONES: Yes.

21 MS. DE LIMA: Yes.

22 MR. BRADMAN: Yes.
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1 MS. MOSSO: Yes.

2 MR. ELA: Yes.

3 MR. MORTENSEN: Yes.

4 CHAIR CHAPMAN: 15 yes, zero no. The

5 motion passes and the item is referred back to the

6 Handling Subcommittee.

7 MS. SWAFFAR: The Chair did not --

8 MS. DE LIMA: You didn't vote.

9 CHAIR CHAPMAN: The Chair votes yes. 

10 Fourteen plus one.

11 MS. DE LIMA: All right, so we are on

12 our last agenda item for handling. That's the BPA

13 proposal. And Asa is going to take us through

14 that.

15 MR. BRADMAN: Thank you.

16 MS. DE LIMA: Oh, I'm sorry, it's a

17 discussion document, not a proposal.

18 MR. BRADMAN: Okay. Thank you. I just

19 want to say, I'm hoping for a lot of robust

20 discussion on this issue. I think this, as was

21 mentioned earlier, opens up a big can of worms,

22 but perhaps a very important one.
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1 So just, I think most people here are

2 probably familiar with the history. There was

3 some early interest in issues around BPA and

4 plastics in packaging materials.

5 There was also a letter from, it's the

6 senator from California, which one? One of the

7 senators sent a note to the NOP about BPA.

8 And that lead to a number of

9 discussions, a request for a technical report that

10 was previously reviewed by the Committee. And it

11 was deemed actually inadequate. But we decided to

12 go ahead with the discussion document to collect

13 more information.

14 So just a quick review, BPA is a

15 material. It's used in cans and other packaging

16 materials, including products containing organic

17 food.

18 It's a known endocrine disruptor. And

19 it's been associated, within a number of studies,

20 with a number of adverse health outcomes. 

21 Potentially at environmentally relevant levels.

22 I should mention too, as disclosure,
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1 that I've had funding from the National Institutes

2 of Health, to work on studies related to BPA.

3 We developed this discussion document

4 to get input from the organic community. And also

5 to learn more about what manufacturers and

6 processors are using and what their experience is

7 with packaging materials and the use of BPA, and

8 alternatives.

9 I'm not going to review the health

10 issues here, other than what I just said. But one

11 thing that is very clear is that packaging

12 materials are really a definite source of exposure

13 to BPA. There's very well done studies showing

14 that if you, for example, have soup or tomato

15 sauce from cans, for example, that are lined with

16 BPA, you have higher levels in your body.

17 If you relate those levels to the

18 current FDA standard, the FDA position on that is

19 that the exposure levels are below a threshold

20 that would cause an adverse health affect. 

21 However, that is contradicted a little bit by

22 recent studies.
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1 And I should also mention, finally,

2 related to that and why I am particularly

3 concerned about this material, it's also listed by

4 the State of California as a, under Proposition

5 65, as a known reproductive toxicant.

6 In terms of the comments that we got

7 back, I was hoping for a little bit more. And one

8 of the concerns among commenters was that there

9 really wasn't enough time to properly review the

10 issue, answer your questions and get back.

11 There were a total of six comments. 

12 And they were kind of, not divided, there was some

13 emphatic agreement that this material is

14 inappropriate in packaging materials for organic

15 food and it should be banned and prohibited from

16 being in packaging material that contacts organic

17 food.

18 And the rationale for that was under

19 the Section 205.272. Where the following are

20 prohibited, well commingling and contact with

21 prohibited substances, prevention practice

22 standard on the following are prohibited.
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1 There's a reference to packing

2 materials that may contain pesticide-related

3 materials or preservatives. And then the use of

4 any bag or container that has been in contact with

5 any substance in such a manner, as to comprise the

6 organic integrity of any organically produced

7 product or ingredient placed in those vessels.

8 So I guess really the question for us

9 is whether we feel that contamination by BPA

10 compromises the organic integrity of the food,

11 because of these concerns about health. And

12 again, there were about four or five comments

13 agreeing with that.

14 There were some other comments that

15 raised concerns about what are the larger

16 implications if we take this on and we're to

17 actually recommend banning this.

18 Basically the concern being there that

19 there is potentially thousands of materials that

20 are used in packaging materials that could be

21 showing up in food, that the material in the

22 packaging material is not intended to alter in any
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1 way or interact with the food. So it's kind of a,

2 it's not a direct use related to the actual food

3 itself, and in that sense it may be beyond the,

4 really scope of our authority to address.

5 And then again, it could open up just

6 a huge area that could place a lot of burden and

7 work on the Board and on the NOP, without really

8 enough time to really discuss and evaluate this

9 issue. Particularly with the timing for this

10 discussion document.

11 So one of the requests is that

12 essentially we keep this on the docket, reissue

13 the discussion document for the fall, and continue

14 the discussion. But I think there's really enough

15 important issues raised here that we can have

16 some, at least useful discussion now, and decide

17 whether we want to consider going ahead with some

18 sort of proposal or at least keeping it on deck as

19 an issue to address.

20 MS. DE LIMA: I'm going to call on

21 myself first and then Emily and then Joelle.

22 Yes, while I see what folks are talking
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1 about when they say look at what this might mean

2 for other substances down the road, the larger

3 broader impact, personally, I also see consumers

4 asking us, on the retail side, about BPA. And

5 that I can't tell them it's certified organic and

6 therefore you don't have to worry about BPA in

7 here.

8 So I definitely want to see the

9 discussion go further, because while there might

10 be other additives that are called into question,

11 this is the only one I'm really hearing about from

12 consumers.

13 MR. BRADMAN: Right. I think that's

14 actually a good point too.

15 And just to reiterate, in our

16 discussion document we did list a number of

17 questions. One was to ask about what alternatives

18 are being used, within the phenol family.

19 There is BPS, BPF. There's other

20 related compounds that have been used in plastic

21 materials.

22 And then there's been a number of other
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1 compounds that were mentioned in the draft

2 technical report and in other reviews. For

3 example, by Environmental Working Group, about oil

4 resin related materials that also have been

5 affective as can liners.

6 And to date, there were no comments or

7 submissions related to those questions, to obtain

8 more information about what's actually been used

9 in the organic industry.

10 MS. DE LIMA: Emily.

11 MS. OAKLEY: Do you think you'll have

12 your revised TR back in time to have a proposal

13 for the fall that might then generate more public

14 discussion or would you want to stick with the

15 discussion document, again, for the fall?

16 MS. DE LIMA: I don't think we know, we

17 don't know yet when we're going to get the TR. 

18 Joelle.

19 MS. MOSSO: First, a couple

20 disclaimers. One, I am not a fan of BPA, and two,

21 is that my company is a major co-manufacturer for

22 tomato products in cans. We do not use any cans
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1 that have BPA. So we don't participate in that.

2 The customers that we have would have

3 to comment on what the alternatives are. However,

4 we do have a BPA-free facility.

5 The comments I have, mostly in regard

6 to BPA, are, what is the limits of our regulatory

7 authority to get into packaging materials that are

8 not active packaging materials? Because I do

9 think that that is going to be a much larger

10 conversation as we look and expand, not even in

11 packaging materials, but also into crop production

12 materials or things that may move inputs, that may

13 also have contamination.

14 And to the point on BPA being the topic

15 that everyone talked about, I think that's today. 

16 Today we talk about BPA, what's tomorrow?

17 So I guess that's a question, somewhat

18 to the NOP, and how we might more effectively get

19 our concerns out to maybe the regulatory

20 authorities that have the jurisdiction to make

21 packaging discussions. Because I'm just not sure

22 we have the regulatory authority to do that.
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1 MR. MCEVOY: Yes, that's a really good

2 question. We're not sure. I think we can go back

3 and look at the statute and the authorities that

4 we have and provide information during the time

5 period between now and the next meeting.

6 So that is a very good question, what

7 is the regulatory authority under OFPA to look at

8 packaging materials, BPA, but other materials as

9 well.

10 And then the other, I guess

11 possibility, is bringing in those regulatory

12 authorities that are responsible for packaging,

13 clarifying what the regulatory framework is for

14 packaging materials with food. I would imagine

15 it's the FDA, but finding specifically what

16 offices they are and how they review these types

17 of materials.

18 MR. BRADMAN: It is FDA. My sense,

19 from a lot of the comments we received and my

20 experience with this issue, I think that some of

21 the kind of public health and organic

22 environmental community might have a different
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1 standard than the FDA.

2 In part because it's a known endocrine

3 disruptor; it's listed as a reproduction toxicant. 

4 And kind of, if you want to take a precautionary

5 approach, let's try to just avoid exposure. 

6 Particularly if alternatives are possible.

7 But again, within the information we

8 asked for within the discussion document, we

9 didn't get much information about what

10 alternatives are being used and what the

11 implications are of those materials.

12 DR. SEITZ: You mentioned that you

13 didn't get any input on alternative materials. 

14 Did the Committee have a chance to do any

15 preliminary research on whether there were good

16 alternatives? And is there is a possibility that

17 if this were taken out, we might find equally

18 noxious replacements for those materials?

19 MR. BRADMAN: There was some discussion

20 of that. In the Draft TR there is a mentioned of

21 it.

22 And I certainly also looked at some of
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1 those materials. And as I mentioned before, there

2 is BPS and BPF. And these are very similar

3 compounds that have the same role in terms of the

4 structure of the plastics.

5 But there are some other materials. I

6 mentioned the oil related resins. But I think

7 that there is a lot more information that needs to

8 be reviewed.

9 And I definitely agree with you. In

10 the last five years, I've become familiar with the

11 term regrettable substitute in environmental

12 health. And I think this is an arena where we

13 want to be careful.

14 MS. DE LIMA: Harriet.

15 MS. BEHAR: So looking in the

16 discussion document at the relevant areas of the

17 rule, 205.272, commingling and contact with

18 prohibited substance prevention practice standard,

19 the handler of an organic handling operation must

20 implement measures necessary to prevent the

21 commingling or organic and non-organic products

22 and protect organic products from contact with
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1 prohibited substances.

2 And then if you go to B1, it does say

3 packaging materials and storage containers or

4 bins, that contain synthetic fungicide

5 preservative or fumigants are prohibited.

6 So I'm wondering if something couldn't

7 be inserted in there. Either by category or by --

8 So do I have to repeat all that? I'm

9 just wondering if in, when we're thinking. 

10 Because we don't list prohibited substances in

11 handling. So how do we work on this?

12 And either we could do a category once

13 we have, if we have a better idea, or we could add

14 BPA in that sentence, I would think, as a place to

15 do it.

16 But I think that we do have authority

17 because right here we are managing, packaging,

18 that it doesn't contain synthetic fumigants,

19 preservatives or fungicides.

20 MS. DE LIMA: Tom.

21 CHAIR CHAPMAN: So, I think the

22 authorization for that sentence comes from the
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1 areas commingling in OFPA, but you do raise an

2 interesting point. If we create an area of a list

3 that references prohibited products for handling,

4 maybe.

5 Maybe that's a way, I don't know. But

6 that would be, I'd be interested in hearing the

7 NOPs feedback on that.

8 MR. BRADMAN: What about on Number 2,

9 below that? The notion that reuse of any bag or

10 container that's been in contact with any

11 substance, that essentially compromises the

12 organic integrity. A reproductive toxicant, known

13 carcinogen.

14 I mean, it seems to me those could be

15 logical definitions, for example, of a substance

16 that compromises the organic integrity, synthetic

17 substance.

18 MS. DE LIMA: Dave.

19 MR. MORTENSEN: Yes, I guess I was

20 struck reading the draft, as you say, to the

21 tenfold increase in detection in the body after

22 eating tomato soup. That's very high compared to
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1 like herbicide exposure that I know more about.

2 And the idea that we think about this

3 as a risk cup and not individual compounds, as we

4 know. So we're being exposed to endocrine

5 disruptors through BPA, but we're also being

6 exposed to endocrine disruptors through pesticide

7 residues and other sources.

8 So it is a can of worms, it looks like,

9 but it certain looks like one we should be

10 opening, I think, and taking a very critical look

11 at.

12 MS. DE LIMA: Tom.

13 CHAIR CHAPMAN: So I should say that I

14 also, like other members of the Board, would like

15 to see BPA disallowed from organic products. And

16 somehow, is just how do we do it and how do we do

17 it without opening up a can of worms.

18 These two sections, my biggest concern

19 is, I don't, you know, is that opening up the door

20 to reviewing all food contact surfaces and

21 substances, and if so, then would all those need

22 to become listed, if they're of synthetic origin
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1 and are we going down a road, or a rabbit hole,

2 similar to ancillary substances, inerts and things

3 like that.

4 MR. BRADMAN: One thought I -- sorry,

5 Emily.

6 MS. DE LIMA: Emily.

7 MS. OAKLEY: Well, I think that, I want

8 to kind of answer yours and I wanted to discuss

9 something that Joelle said.

10 I think that, in order for that to be

11 something that NOSB addressed, we would have to

12 ask to have it on our work agenda. So I think the

13 can of worms can be contained to some extent, that

14 we choose to look or not look at a substance.

15 And I agree that contaminated inputs in

16 agricultural production are definitely a concern,

17 but I also think that, as A-Dae was pointing out,

18 this is a different level of contact, because

19 you're having to finish consumed product, touching

20 something of grave concern. So I don't think it's

21 quite the same issue, but I agree that

22 contaminated inputs are of concern.
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1 MS. DE LIMA: Asa.

2 MR. BRADMAN: Just, there could also be

3 a threshold for concern. Like a known carcinogen,

4 a known reproductive toxicant. Or there's been

5 demonstrated research that shows increased

6 exposure related to a certain use of a material.

7 It could open a can of worms, but then

8 another way to look at it too is it's kind of part

9 of the process of continuous improvement. You

10 know, we have a movement in this country at all

11 levels for manufacturers, to big chemical

12 companies to smaller, towards green chemistry. So

13 maybe this is part of that trend of continuous

14 improvement.

15 We don't have to look at it as an

16 overwhelming process. That there can be a way to

17 narrow it down and deal with it piece-by-piece.

18 MS. DE LIMA: Harriet.

19 MS. BEHAR: So food contact substances,

20 like sanitizers, are already regulated. If it's

21 not on the list, it can't be in contact with an

22 organic product.
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1 But under packaging, we only have these

2 categories: fumigants, fungicides and

3 preservatives. So I think that's really more

4 where we're wondering what, as more things kind of

5 come up, what is it in packaging.

6 But in a processing facility, if

7 someone has just used quaternary ammonia on a food

8 contact surface, you cannot have contact with the

9 organic product. That must be washed off with

10 potable water or, I mean, there are sanitizers

11 that are allowed to have direct food contact. 

12 Alcohol and hydrogen peroxide and phosphoric acid

13 and those things.

14 MS. DE LIMA: Tom and then Joelle and

15 then I think we need to wrap it up.

16 CHAIR CHAPMAN: Yes, just want to, food

17 contact substances go far beyond just the items

18 you mentioned. All packaging needs to be listed,

19 the materials that foods are handled on top of

20 need to be listed. It's a fairly extensive list

21 that are maintained by, I believe, the FDA.

22 MS. MOSSO: This is more of a question
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1 for Miles for the NOPs. I seem to recall that at

2 some point of time there was guidance on food

3 contact, direct food contact.

4 MR. MCEVOY: Yes, I think you're right. 

5 Help me out here, Dr. Brines.

6 DR. BRINES: Yes, there was at some

7 point. I don't believe that there is any current

8 policy on the use of food contact substances in

9 our program handbook, which is the current

10 compilation of all NOP policies, instructions and

11 guidance documents.

12 MS. MOSSO: So, just a follow-up

13 question, where did it go?

14 DR. BRINES: Well, when we implemented

15 the program handbook, the intent was to take -- to

16 make one consolidated source of official NOP

17 policy that would be accessible to the public in

18 a transparent way. So certainly there was

19 something circulated before the program handbook

20 that might have had informal policies or email

21 decisions.

22 I don't know where the origin of that
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1 food contact policy was. I'm sure I've seen it a

2 couple of times, but I don't think it was formally

3 retired. It's just not part of the program

4 handbook. Miles may want to weigh in.

5 MR. MCEVOY: Yes, the program handbook

6 contains the current interpretations and policy

7 for the natural organic program. So the

8 regulations statute and program handbook.

9 So anything that's not in there is not

10 part of our current policy or interpretation.

11 MS. DE LIMA: Asa, you have any closing

12 thoughts?

13 MR. BRADMAN: Well, I was going to say,

14 if we want to move this towards any decision15 making, I guess maybe, you know, one alternative

16 would be to try to come up with a proposal for the

17 next meeting. The other would be to really extend

18 the discussion. And I think that is important,

19 given how big this issue is.

20 And also the, you know, we didn't

21 really get many answers to our questions about

22 alternatives being used and what people are using. 
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1 And to be responsive to get that information

2 responsive to the requests for more time, maybe it

3 makes sense to reissue this.

4 But I wouldn't want there to be too

5 much delay in the long run. You know, we don't

6 want, I think there is an important issue here. 

7 But I do respect that this hasn't been out there

8 that long and we don't have that much information

9 on alternatives and how effective they are.

10 MS. DE LIMA: Yes, I'd agree with that. 

11 And I just want to say thanks to Asa, as a new

12 member coming onto the Subcommittee and taking the

13 lead on this. I was personally very relieved. 

14 And he's done an excellent job, so thank you, Asa.

15 So that concludes Handling

16 Subcommittee's agenda.

17 CHAIR CHAPMAN: Thank you, Lisa. And

18 we have gone from an hour and a half behind

19 schedule to a mere 35 minutes behind schedule.

20 I had really wanted to be able to break

21 at 4:20 for you folks, but I guess we will be

22 fashionably late. It's 4:35 right now, we'll take
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1 a ten-minute break and start back up at 4:45 with

2 the Livestock Subcommittee.

3 (Whereupon, the above-entitled matter

4 went off the record at 4:35 p.m. and resumed at

5 4:47 p.m.)

6 CHAIR CHAPMAN: If Board Members could

7 get back to their seats and the public could sit

8 down, we're going to get started again. If Board

9 Members could return to their seats and the public

10 could sit down, that would be much appreciated.

11 Okay, we're going to get back underway. 

12 And next up is the Livestock Subcommittee. 

13 Ashley.

14 MS. SWAFFAR: Okay, welcome to the

15 livestock, all 20 of you in the audience. First

16 up we'll talk about 2019 Sunset substances, Dr.

17 Brines, start with chlorine materials.

18 DR. BRINES: All right, we're at

19 Section 205.603 of the national list. That is the

20 synthetic substances allowed for use in organic

21 livestock production.

22 And the first Sunset material to be
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1 discussed by the Board, and you said chlorine

2 materials, but I've got chlorhexidine as the first

3 one.

4 MS. SWAFFAR: I have chlorine materials

5 listed.

6 DR. BRINES: Okay, we'll start with

7 chlorine. All right, it's under Paragraph A as a

8 disinfectant, sanitizer and medical treatments as

9 applicable.

10 Under 7, chlorine materials,

11 disinfecting and sanitizing facilities and

12 equipment, residual chlorine levels in the water

13 shall not exceed the maximum residual disinfectant

14 limit, under the Safe Drinking Water Act, i

15 calcium hypochlorite, ii chlorine dioxide and iii

16 sodium hypochlorite. Thanks.

17 MS. SWAFFAR: Okay, I am the lead on

18 chlorine materials. Same as handling, chlorine

19 materials are used for disinfecting and sanitizing

20 livestock facilities and equipment.

21 We had broad support from several

22 livestock farmers and certifiers stating,
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1 generally, chlorine is used to sanitize many

2 surfaces to kill pathogenic microorganisms.

3 One commenter said chlorine dioxide is

4 routinely used to kill pathogenic microorganisms

5 in waterlines because sodium hypochlorite is

6 corrosive to the pipes. No alternatives are

7 currently allowed.

8 And then we did have the same commenter

9 that requested we do a comprehensive review of

10 sanitizers, but the Subcommittee felt that this is

11 beyond the scope of this Sunset process.

12 Any comments or questions on chlorine

13 materials? All right. Seeing none,

14 chlorhexidine, Dr. Brines.

15 DR. BRINES: All right, thank you. 

16 Continuing under the same Paragraph A, we have

17 chlorhexidine or chlorhexidine.

18 The listing reads, as allowed for

19 surgical procedures conducted by a veterinarian,

20 allowed for use as a teat dip when alternative

21 germicidal agents and/or physical barriers have

22 lost their effectiveness. Thank you.
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1 MS. SWAFFAR: Harriet.

2 MS. BEHAR: So chlorhexidine is used as

3 an antimicrobial during surgery for cleansing

4 wounds, skin and equipment. It's also used as a

5 pre and post teat dip to aid in the controlling

6 bacteria that causes mastitis.

7 There is numerous synthetic

8 disinfectants on the national list of approved

9 synthetics for organic livestock production,

10 including iodine, ethanol, isopropanol, sodium

11 hypochlorite and hydrogen peroxide, but not all

12 are useful in a surgical environment or as a teat

13 dip, as allowed under this chlorhexidine.

14 It also reportedly kills mastitis

15 causing pathogens faster than iodine and is more

16 persistent in its disinfection activity. It's

17 gentler on the skin than iodine, which is

18 especially useful in northern climates, where I am

19 from, where an irritated utter and teats can be

20 especially problematic for the animals in cold

21 winter months.

22 And I have seen it used that way on
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1 numerous farms. Especially in Northern Minnesota.

2 It's used in agriculture during

3 livestock surgery, on teats, pre and post milking,

4 and on milking equipment. It's also used in food

5 processing facilities as a hard surface

6 disinfectant.

7 And in human dentistry as a mouth wash. 

8 I don't know, I always wonder when my dentist

9 gives me this cup of chlorhexidine and I say, did

10 you know you can clean utters with that?

11 (Laughter)

12 MS. BEHAR: So that's the story on

13 chlorhexidine.

14 MS. SWAFFAR: Any discussion? Thank

15 you. Glucose, Dr. Brines.

16 DR. BRINES: Thank you. Continuing

17 under Paragraph 205.603, we have glucose. Thanks.

18 MS. SWAFFAR: Harriet.

19 MS. BEHAR: Okay. This material has

20 been on the national list since 1995, with minimal

21 public comment. Both pro and con at each Sunset

22 Review.
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1 It's been used most frequently in

2 organic dairy operations to manage ketosis or

3 other situations when an infusion of glucose is

4 needed to restore the blood sugar balance in an

5 ill cow.

6 On non-organic dairy operations,

7 propylene glycol, glycerin or corticosteroids

8 might also be used.

9 Careful management of feed rations

10 before and immediately after birthing is typically

11 used to avoid the occurrence of ketosis, but that

12 cannot always be avoided. And there might be some

13 excipient ingredients in glucose that's used in

14 livestock production.

15 MS. SWAFFAR: Any discussion? Great. 

16 Oxytocin, Dr. Brines.

17 DR. BRINES: Thank you. Continuing

18 under the same paragraph, we have oxytocin use and

19 post parturition therapeutic applications. 

20 Thanks.

21 MS. SWAFFAR: Harriet.

22 MS. BEHAR: I'm just scrolling on my
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1 computer. I have more than that. Okay, Oxytocin.

2 Oxytocin is a hormone. It's naturally

3 produced in the pituitary glands of humans, cattle

4 and other mammals.

5 In non-organic production, it is used

6 regularly to help dairy cows relax and let down

7 their milk. There is some concerns with overuse

8 of oxytocin in non-organic production systems, as

9 well as the abuse of this hormone in the human

10 population.

11 In the NOP regulations, it's only

12 allowed post-birthing in a therapeutic way to ease

13 various dam issues that are associated with the

14 birthing of the calf. Including displaced

15 abomasum and retained placenta.

16 It's been on the national list of

17 approved synthetics since 1995, with minimal

18 public comment on this material, pro or con. Some

19 organic milk marketers require their milk

20 suppliers not use this material.

21 This is very little public comment over

22 the years, except there was some this time around. 
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1 It seems to be rarely used in organic production,

2 although some certifiers did mention it, that as

3 it being used.

4 It could be considered as essential for

5 animal health and welfare. Especially in

6 emergency situations.

7 Is this what I'm supposed to talk

8 about, the public comment? Should I talk about

9 the public comment now? Okay.

10 So most said that it wasn't commonly

11 used. The Organic Valley CROPP Cooperative

12 prohibits its use.

13 NOC talked about some abuse and that

14 the annotation should possibly be clarified,

15 because of post parturition. It doesn't say how

16 long, it could be eight months later. So there's

17 some issue there.

18 Vermont Organic farmers said it was

19 used for retained placenta. Both WhiteWave and

20 Horizon said it was no longer necessary and should

21 be removed.

22 Garth Kahl saying that it should be
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1 kept as a, for an emergency in any kind of

2 veterinary tool kit that organic producers use. 

3 PCO mentioned nine producers were currently using

4 it, CCOF mentioned 38.

5 And Beyond Pesticides supported re6 listing, but wanted clearer annotation.

7 And then I also spoke with a few

8 veterinarians that work a lot of with organic

9 producers, in Wisconsin, and the two of them both

10 felt that it was unnecessary and that it was, that

11 if you were careful about your feeding, before

12 feeding your dry cows before they gave birth, you

13 could deal with it.

14 And another way to have the animal

15 naturally release oxytocin is to put on a sleeve

16 and get your hand in there and massage the udder. 

17 Which I have done. Not only can I make pectin in

18 my kitchen, but I can stick my hand inside a cow.

19 (Laughter)

20 MS. BEHAR: So that's it for oxytocin.

21 MS. SWAFFAR: Appreciate that, Harriet.

22 (Laughter)
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1 MS. SWAFFAR: Any discussion? Okay. 

2 Seeing none, moving on to tolazoline, Dr. Brines.

3 DR. BRINES: Thank you. Continuing in

4 the same section, we have tolazoline, cast number

5 59983.

6 Federal law restricts this drug to use

7 by or on the lawful written or oral order of a

8 licensed veterinarian, in full compliance with the

9 AMDUCA and 21 CFR Part 530 of the Food and Drug

10 Administration Regulations.

11 Also for use under 7 CFR Part 205, the

12 NOP requires, one, use by or on the lawful written

13 order of a licensed veterinarian, two, use only to

14 reverse the effects of sedation and an analgesia

15 caused by Xylazine, and three, a meat withdrawal

16 period of at least eight days after administering

17 to livestock intended for slaughter and a milk

18 discard period of at least four days after

19 administering to dairy animals. Thank you.

20 MS. SWAFFAR: Thank you, Dr. Brines. 

21 Dan.

22 DR. SEITZ: So, tolazoline is used to
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1 reverse the effects of Xylazine. And Xylazine is

2 used a sedative, analgesic and muscle relaxant in

3 veterinary medicine.

4 Under the NOP requires that its use be

5 by the lawful written order for a licensed

6 veterinarian, used only to reverse the effects of

7 sedation and analgesia caused by Xylazine. And it

8 also requires a meat withdrawal period of at least

9 eight days, after administering to livestock

10 intended for slaughter, and a milk discard period

11 of at least four days, after administering to

12 dairy animals.

13 It was first listed in 1995. It was

14 recently up for re-listing during the 2015 comment

15 period for the 2017 Sunset.

16 Several comments were received

17 indicating Xylazine, tolazoline, to be important

18 tools for farmers and veterinarians and that

19 should stay on the list.

20 There were only a few comments this

21 time around. None that mentioned that it should

22 be removed.
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1 There was one comment that Xylazine,

2 however, should maybe be taken, that we should

3 maybe take another look at whether Xylazine should

4 be continued to be listed. And that's it. Yes.

5 MS. SWAFFAR: Any discussion? Seeing

6 none, moving on. Copper sulfate, Dr. Brines.

7 DR. BRINES: Thank you. We're in a new

8 paragraph, Paragraph B of 205.603. That's as

9 topical treatment, external parasiticide or local

10 anesthetic as applicable. And this listing is

11 copper sulfate. Thanks.

12 MS. SWAFFAR: Jesse.

13 MR. BUIE: Copper sulfate in livestock

14 management is used specifically as a walkthrough

15 footbath to help control and prevent hoof related

16 disease in dairy cattle and sheep.

17 According to the technical review

18 commission by the Livestock Committee, there are

19 no natural non-synthetic products available that

20 can be used as a management strategy, to treat

21 hoof related diseases and lameness in dairy cattle

22 and sheep operations.
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1 A summary with the public comments

2 received reiterated minimizing the accumulation in

3 soil and that there was no effective alternative

4 on the national list.

5 MS. SWAFFAR: Any discussion? Harriet.

6 MS. BEHAR: Just for the future, zinc

7 sulfate was voted to be put on the national list,

8 and that's one alternative that does then have the

9 same issue as copper sulfate. Although I'm not

10 sure which, there's a species that it's not good

11 for, but I can't remember which one.

12 And also, we have another product

13 that's been petitioned, tymol. Also for a hoof

14 treatment.

15 And the petition does discuss it at

16 length, that tymol is an excellent replacement for

17 copper sulfate, because it doesn't have the copper

18 issues. So, there could be some opportunities in

19 the future to think about removing copper sulfate. 

20 But obviously not until we have the alternatives

21 on the list.

22 MR. BUIE: Right. But, Harriet, in
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1 case of the zinc sulfate, it also took five times

2 the quantity to have the same effect as copper.

3 MS. SWAFFAR: Any further discussion? 

4 Steve.

5 MR. ELA: I guess I just have the, you

6 know, given the other side of copper sulfate on

7 crops, that the disposal of it, it seems like

8 that's still, the statements are it's not being

9 disposed in a way that elevates soil levels. But

10 I'd like a little more, given how much the growers

11 have to regulate that when they use copper sulfate

12 or fixed coppers, it seems like the livestock

13 people should have to document where they dispose

14 of it and that it's not actually raising the soil

15 levels.

16 MS. SWAFFAR: Francis.

17 DR. THICKE: Well, I would just point

18 out that foot baths are not absolutely necessary. 

19 In most grazing operations, organic, that I know

20 of, don't really use them. If they get a lame

21 foot they will treat it individually. So I think

22 we just need to keep that in mind, it's not
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1 something that everybody uses or everybody needs

2 to use.

3 MS. SWAFFAR: And I will say I did find

4 that pretty interesting, Steve, about how there

5 was a commenter that said we should limit how they

6 dispose of it. So that might be something we want

7 to look at in the future, as a Committee, to

8 address that.

9 Any further discussion? Okay, great. 

10 Lidocaine, Dr. Brines.

11 DR. BRINES: All right, thank you. So

12 lidocaine, continuing under Paragraph 205.603(b),

13 we have lidocaine as a local anesthetic.

14 Use requires a withdrawal period of 90

15 days after administering to livestock intended for

16 slaughter and seven days after administering to

17 dairy animals. Thanks.

18 MS. SWAFFAR: Okay, so I'm doing

19 lidocaine. Lidocaine is a local anesthetic, which

20 has a rapid onset of action in a short-term in

21 duration. And it only numbs the area to be worked

22 on.
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1 We did receive quite a bit of public

2 comment that we should continue the use of local

3 anesthetics, lidocaine and procaine.

4 And commenters said that given the

5 ranges and procedures that livestock receive, they

6 encourage us to retain these items on the national

7 list. Pretty much broad support on re-listing

8 those.

9 Any discussion? Great, moving on to

10 procaine, Dr. Brines.

11 DR. BRINES: Thank you. And this is

12 the last one on the livestock part of the agenda

13 for Sunset 2019.

14 And we have procaine as a local

15 anesthetic. Use requires a withdrawal period of

16 90 days after administering to livestock intended

17 for slaughter and seven days after administering

18 to dairy animals. Thanks.

19 MS. SWAFFAR: Okay, I got procaine

20 again. Procaine, once again, is another local

21 anesthetic. Short-term duration, only numbs the

22 area to be worked on.
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1 Quite a bit of support, as with

2 lidocaine, for re-listing as the, they said it was

3 critical for animal welfare for the procedures

4 that are done to cattle.

5 Any questions, comments? Yes, Francis.

6 DR. THICKE: Well, I question if we

7 really need to have procaine on the list. The

8 comments we had over the last review, it seemed

9 like nobody was using it. Lidocaine seems to be

10 preferred. And procaine seems to be formulated

11 with antibiotics.

12 The veterinarians who told us about it

13 said that they haven't seen it by itself, only

14 with antibiotics. Which of course we cannot use.

15 And so it's a little confusing to have

16 it on there. Somebody grabs procaine and it's got

17 antibiotics in it.

18 So it's something that we should just

19 think about and maybe look a little deeper into if

20 people are really using it and if we should keep

21 it on the list.

22 MS. SWAFFAR: Emily.
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1 MS. OAKLEY: Yes, I was going to echo

2 that. It seemed like it's not really widely used

3 in the public comments. And I know that support

4 for it was, as another tool in animal welfare.

5 But if it's not being used or if it's

6 only available in combination with an antibiotic,

7 then it seems like we should Sunset it.

8 MS. SWAFFAR: Dave.

9 MR. MORTENSEN: Ashley, I was just

10 curious, what is the sort of physiological basis

11 of the huge differences in the withdrawal periods? 

12 Ninety to 70 to seven days in dairy cattle versus

13 slaughter beef, 90 in slaughtered animals, seven

14 in dairy.

15 Is there evidence that the levels of

16 those compounds are low enough in the dairy

17 products, in a week's time, I guess is the

18 question?

19 MS. SWAFFAR: This is not really my

20 area. Dan, do you want to --

21 DR. SEITZ: You mean, why was there the

22 reduction? I think that, if I remember that
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1 conversation correctly, there was the worry that

2 if the wait time was too long, either needed

3 medications would not be administered or that, I

4 think that was the main one. That needed

5 medications would not be administered to the

6 animal. And I'm not sure if there was another

7 rationale as well.

8 MR. MORTENSEN: I --

9 DR. SEITZ: And actually, if I remember

10 back again, there was some sense that that wasn't,

11 the very high level was an arbitrary number and

12 there wasn't a clear reason why that had been set

13 that high in the first place.

14 MS. SWAFFAR: Sorry --

15 DR. SEITZ: But I can't say for sure.

16 MS. SWAFFAR: Yes. Sorry, I drew a

17 complete blank. So last year we did a proposal

18 that we shortened that withholding time down to

19 eight days for slaughter and six days to dairy

20 animals.

21 MR. MORTENSEN: Ah.

22 MS. SWAFFAR: So we passed that last
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1 fall. I had a little bit of lapse in judgment and

2 had to think about that.

3 MR. MORTENSEN: Okay, thanks. Thank

4 you, that's helpful.

5 MS. SWAFFAR: Yes. So I will say, on

6 my comment on this, is I would like to see, from

7 stakeholders, if you are using this, because I

8 keep hearing that same thing every time we talk

9 about these is, lidocaine is more common,

10 procaine, some people say they use it, some people

11 say they don't. If people use it, you need to

12 write in and tell us that you use it. It's

13 critically important. Emily.

14 MS. OAKLEY: Yes, and I would just add

15 to that, that it's used without antibiotics. We

16 need to hear both of those things.

17 MS. SWAFFAR: Tom.

18 CHAIR CHAPMAN: Can I ask something? 

19 If it's used with antibiotics and antibiotics is

20 prohibited, wouldn't that be a prohibited

21 practice? So then that would lead to de22 certification of that cattle.
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1 MS. SWAFFAR: Well, that isn't wasn't

2 one of the questions that the Subcommittee put

3 out, as their second question.

4 CHAIR CHAPMAN: Okay.

5 MS. SWAFFAR: But yes, you're right. 

6 I'm sure someone wouldn't copped to that. Just

7 kidding.

8 Any further discussion? Great, that

9 concludes our Sunset items. Now on our discussion

10 document, clarifying emergency for the use of

11 synthetic parasiticides in organic livestock

12 production. Harriet.

13 MS. BEHAR: Okay, so this was put in

14 place as a discussion document apt to kind of

15 address the, after the Moxidectin and

16 Fenbenzadole, the withdrawal times were greatly

17 reduced from three months down to a few days. For

18 each of those.

19 And then of course now Ivermectin was

20 recently voted to come off the list. So there was

21 a concern from some, and I was one of them, who

22 felt that since they were so much more readily
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1 available, to livestock producers to use, because

2 there was much less of a waiting time, 90 days was

3 a pretty long time to wait, to be able to sell an

4 organic product.

5 Now, this is not for slaughter stock,

6 this is just for fiber or milk. That we should

7 define emergency treatment.

8 And we did get, I think one or two

9 producers, who gave input, and the rest were

10 mostly certifiers. Most did agree that they could

11 benefit from a definition of emergency treatment,

12 but it was a little bit, nobody agreed on one

13 certain way.

14 Some were pretty broad, similar to the

15 comment that Tracy gave us, and some were a little

16 bit more prescriptive, that it should follow a

17 similar type of practice standard, like we have

18 for pest management. Where we have first you do

19 kind of a cultural activities for parasiticides. 

20 Maybe it would include fecal monitoring and that

21 sort of thing. Grazing protocols.

22 And then if you have not, if your
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1 organic system plan has failed and you can then

2 show that you have an infestation, then you can

3 use the parasiticides. And that would be the

4 definition of an emergency.

5 That it's not used, obviously not routinely,

6 but that not only is it not routine, but it's also

7 based in a holistic system. That you're doing all

8 these other things first, before you would then

9 resort to a parasiticide.

10 So that's, so again, most certifiers

11 responded and felt that it would be useful to

12 them, to have this definition.

13 But I'm a little disappointed that we

14 didn't get more producers. Because, for me, I

15 would think that they would want to know what

16 emergency treatment meant and what was the

17 protocol that they needed to go through to kind of

18 help them through that type of practice standard,

19 to mean that they would not need parasiticides. 

20 And prevent the use of them.

21 MS. SWAFFAR: Thank you, Harriet. Open

22 the floor up for discussion. Anybody have
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1 anything? Okay, I'll call on myself.

2 I would like to see us move forward

3 with this as an actual proposal, not as a

4 guidance. I'm sorry, but I do not like guidance.

5 I think guidance is just guidance and

6 it is not a rule. We are doing this to define

7 something and I do not feel like guidance is the

8 correct thing for that.

9 And sorry, but you probably won't see

10 guidance out of livestock for two and a half more

11 years. So that's my opinion.

12 Thanks to Harriet, and Jean did a lot

13 of work in this document. And we got our work cut

14 off for us, this summer, getting this crafted. We

15 would love to bring this back in the fall, I

16 believe.

17 And I will say, since the docket wasn't

18 open that long, if any producers or other

19 certifiers do have definitions or answers to the

20 four questions that we posed, when the open docket

21 opens, please feel free to comment there. Because

22 we'll be starting work on this. And all the input
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1 we can get is needed. Lisa.

2 MS. DE LIMA: Was there any discussion,

3 I saw a comment, I guess they were in the minority

4 that they thought that if the OLPP was implemented

5 then this wasn't necessary. I don't know, I'm

6 asking for your all's take on that.

7 MS. SWAFFAR: You want to answer that,

8 Harriet, or you want me to?

9 MS. BEHAR: Could you say that again? 

10 Sometimes over here I get a little feedback.

11 MS. DE LIMA: There was a public

12 comment and they thought that if the OLPP was

13 implemented there wasn't a need for an additional

14 definition.

15 MS. BEHAR: And yes, that is true. 

16 There is some discussion in the animal welfare

17 standard, so of course, when we start working on

18 this, I mean, I think we can still define

19 emergency and put that into the regulation, but we

20 might not need to put in a practice standard

21 because the animal welfare, hopefully, it's going

22 to go through. And then I think that will inform
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1 our work. But we'll know that in May.

2 So by the time we're writing a

3 proposal, we'll have some idea of what we need to

4 be doing.

5 MS. SWAFFAR: And I would just say,

6 we're just further clarifying, further defining

7 this. And this came out of a product from last

8 year's Sunset.

9 We heard from the stakeholders that

10 this needed to be defined, so that's kind of where

11 we're moving forward with this, is we heard that

12 from the community.

13 So any further discussion? Miles.

14 MR. MCEVOY: Yes. So the animal

15 welfare, Organic Livestock and Poultry Practices,

16 the effective date is delayed until May 19th. 

17 It's under review by the department.

18 There is discussion of emergency, what

19 the emergency means, in that final rule that's

20 been published. And it's just not effective yet.

21 And then the comment about guidance,

22 whether or not the Board is making a
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1 recommendation for guidance or for a rule change. 

2 In some ways to us it's not, it doesn't have to be

3 that clear, we just need to know, in your

4 recommendations, what you want, what you're

5 recommending. And then based on that

6 recommendation, we can determine whether or not

7 that was going to require a rule change or we can

8 do it through instruction or guidance.

9 So it all depends on whether or not

10 it's just a clarification of existing regulations

11 or it's something that requires a rule change.

12 So I would encourage you to continue to

13 work on this topic. And then with that, we can

14 then determine whether or not the final

15 recommendation is something that requires either

16 clarification through guidance or fact sheets or

17 instruction or training, or it needs a rule

18 change.

19 MS. SWAFFAR: Thank you, Miles. And

20 with that, the Livestock Committee is done. And

21 I would like to point out that we got you back on

22 schedule.
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1 (Laughter)

2 CHAIR CHAPMAN: We are back on

3 schedule. Thank you, Ashley.

4 (Applause)

5 CHAIR CHAPMAN: Next up is the

6 Compliance Accreditation Certification

7 Subcommittee with Scott Rice as Chairperson. 

8 Scott.

9 MR. RICE: Thank you, Tom. First up on

10 our agenda today is the proposal we put forward on

11 the personnel performance evaluations of

12 inspectors, looking at NOP 2027.

13 There was a lot of good discussion with

14 public comment, both in person and in writing from

15 certifiers and other stakeholders on this.

16 Between the time that we finalized this

17 document in December of 2016 and our meeting this

18 week, we saw an updated version of 2027 published

19 by the program. Which addressed the primary issue

20 that we saw as a problem.

21 And that is the absolute requirement

22 that inspectors receive and audit every, for every
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1 inspector, every year. We've since gotten the

2 allowance to, as certifiers that is, the allowance

3 to have a system in place that is based more on

4 risk and can be more flexible, when such a

5 alternative is approved by the program.

6 So given that this is somewhat outdated

7 at this point, we're looking to bring this back to

8 kind of refocus the document more on inspector

9 training and qualification, as was pointed out in

10 much of the public comment, and work on it from

11 there.

12 Is there any discussion? Miles.

13 MR. MCEVOY: Yes. This is an

14 instruction that we issued to certifiers a number

15 of years ago, under the authority of the

16 regulations under 205.501(a)(21). Where it states

17 that the certifiers have to comply with implement

18 and carry out any other terms and conditions

19 determined by the administrator to be necessary.

20 So we felt that this was a necessary

21 addition to ensure the quality of the inspection

22 process. And it relates back to another
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1 requirement for accreditation, which is also under

2 205.501(a).

3 Where it states that, in a couple of

4 different places, in under one, have a sufficient,

5 that a certifying agent has sufficient expertise

6 in organic production and handling techniques to

7 implement the conditions for the organic

8 certification program.

9 And then under five, ensure that its

10 responsibly connect persons, employees and

11 contractors, with inspection analysis and decision

12 making responsibilities, have sufficient expertise

13 in organic production or handling techniques to

14 successful perform the duties assigned. So it

15 relates to those requirements as well.

16 And then under 205.501(a), it's one of

17 these here, six, conduct an annual performance

18 evaluation of all persons who review applications

19 for certification, perform on-sight inspections,

20 review certification documents, evaluation

21 qualifications for certification, make

22 recommendations. Anyone involved in the
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1 certification process has to have an annual

2 evaluation.

3 What we were finding during our audits

4 was that, though the majority of organic

5 inspectors are doing excellent work and are highly

6 qualified, we did find some inspectors that needed

7 a lot of improvement in terms of the thoroughness

8 of the inspections that they were conducting.

9 And we found that some certifiers had

10 never evaluated inspectors in the field. So they

11 were doing the performance evaluations, but they

12 were never actually looking at how the inspector

13 was doing their work.

14 And so we issued 2027 to make it clear

15 that a performance evaluation that doesn't include

16 an evaluation of the person actually doing the

17 job, is not adequate. And it relates back to the

18 regulations, but it clarifies what our

19 expectations are, in terms of ensuring that the

20 certifier is ensuring that that inspector is

21 qualified in doing a thorough inspection.

22 We did get a lot of feedback on that,
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1 that a lot of certifiers really appreciated that,

2 learned a lot and improved the inspection process

3 because of that. In the field review and

4 observing of how an inspector does their work.

5 And they requested that they move their

6 resources to those inspectors that needed more

7 oversight. And that moved to a more of an ISA

8 model of those that are highly qualified and that

9 you've seen that they have demonstrated that they

10 have met the qualifications to be an experienced

11 inspector. You go to the ISA model where they

12 field evaluated every two to three years, rather

13 than every year.

14 So we agreed with that feedback and

15 then have provided that flexibility in the

16 revision to 2027, but we still hold certifiers

17 accountable to make sure that all of their

18 inspectors are highly qualified and thoroughly do

19 the inspections, when they're doing certification

20 work.

21 MR. RICE: Thanks, Miles. Any further

22 discussion on this proposal? Tom.
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1 CHAIR CHAPMAN: Yes, and I agree with

2 the need to have a qualified and evaluated

3 inspectors, and I look forward to working on this

4 from a wider lens of qualifications. I think

5 that's going to add some real value.

6 MR. RICE: Harriet.

7 MS. BEHAR: So based on that, I would

8 like to make a motion to send the proposal,

9 personnel performance evaluations of inspectors

10 dated December 13th, 2016, back to Subcommittee.

11 CHAIR CHAPMAN: I have a motion, is

12 there a second?

13 MS. SWAFFAR: Second.

14 CHAIR CHAPMAN: Ashley seconded it. 

15 The motion is to refer the proposal on personnel

16 performance evaluations of inspectors back to the

17 CACS.

18 It's a majority motion, a yes vote on

19 this is to send it back to Subcommittee. And the

20 voting starts with Ashley.

21 MS. SWAFFAR: Yes.

22 DR. SEITZ: Yes.
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1 MR. RICE: Yes.

2 MS. BAIRD: Yes.

3 MS. BEHAR: Yes.

4 MS. OAKLEY: Yes

5 DR. THICKE: Yes.

6 MS. ROMERO-BRIONES: Yes.

7 MS. DE LIMA: Yes.

8 MR. BRADMAN: Yes.

9 MS. MOSSO: Yes.

10 MR. ELA: Yes.

11 MR. MORTENSEN: Yes.

12 MR. BUIE: Yes.

13 CHAIR CHAPMAN: Chair votes yes. 15

14 yes, zero no, the motions passes and this item is

15 referred back to the CACS.

16 MR. RICE: Next on our agenda we have

17 a discussion document on Eliminating the Incentive

18 to Convert Native Ecosystems into Organic Crop

19 Production. And I turn this over to the lead on

20 that, who is Harriet.

21 MS. BEHAR: Here I am again. Okay, so

22 this topic has actually been part of the
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1 discussion of the NOSB and the public, for quite

2 a few years. Since Barry Flamm was on the board.

3 And it was kind of set aside when the

4 natural resources and biodiversity discussion

5 document then became guidance. Because it was

6 seen as somewhat of a tricky subject, although

7 still important.

8 So here it is again, as a standalone

9 discussion document. We did receive quite a few

10 public comments. Obviously struck a chord with

11 many people.

12 I did not see one single public comment

13 that said we should go in and destroy high value

14 conservation areas in order to have organic

15 production, so I think we pretty much have, which

16 is something to celebrate, that we can all agree

17 on something.

18 But this is a tough area, because

19 defining what we're trying to protect, without

20 taking away land that could actually benefit from

21 organic production.

22 You know, certain lands that are
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1 somewhat maybe degraded or even highly erodible

2 lands that could be farmed. If they're farmed

3 organically then they're going to be protected

4 from erosion because that's what we do, is we, you

5 know, they strip crop it or it could be pasture or

6 whatever.

7 So there is, there's a difficulty in

8 figuring out, what is it we're trying to protect

9 and then how do we disincentivize the conversion

10 to organic production.

11 And so part of that is, where do we put

12 that in the rule. I think we can define it, but

13 then how do we get that into the regulation,

14 because the Organic Food Production Act has a

15 three year, how are we setting a regulation or a

16 rule that actually goes before we are even

17 tracking producers for under the regulation, in

18 the Organic Food Production Act, as well as the

19 final rule.

20 I also think that there is an issue

21 that we wouldn't want to have an unintended

22 consequence where we would then encourage people,
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1 if they can't take certain lands and put them in

2 organic, that they just go to conventional. 

3 Especially if it's somewhat of a medium

4 conservation value.

5 So I think there's a lot of tricky

6 issues, although this is an important one.

7 I know that the public comments did

8 give us some good ideas on how to define these

9 areas. Various, with Wild Farm Alliance and World

10 Wildlife Fund and Nature Conservancy and others,

11 all providing really good comments on not only how

12 we can define them and track them here in the

13 United States, but around the world.

14 So, I think some of those tools will

15 become useful. And also, some ideas on the

16 disincentive.

17 A lot of the public, consumers,

18 producers, certifiers. I mean, we had just about

19 every stakeholder make a comment, a stakeholder

20 segment, make a comment on this proposal. Which

21 again, is somewhat unusual to have a kind of

22 across the board type of interaction. Because it
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1 actually does affect everyone.

2 And there was a lot of heartfelt

3 discussion, by people, of how they really feel

4 very in-tune with the native environments and

5 really feel like we need to protect these. 

6 Because they are so precious and they are

7 disappearing rapidly.

8 And those of us who know that

9 biodiversity is important to organic agriculture,

10 that we rely on health ecosystems, that we don't

11 want to start destroying the things that we are

12 relying on. I guess that's it.

13 MR. RICE: Thank you, Harriet. Emily.

14 MS. OAKLEY: This is a question for

15 Miles. Miles, can you help us identify how we

16 might work within the regulations in OFPA to,

17 assuming we can agree on a definition of high

18 value conversation area or fragile ecosystems,

19 create a disincentive within the regulations?

20 MR. MCEVOY: Yes, I'm not sure. I

21 remember when I worked for the Washington State

22 Department of Agriculture, before the NOP was in
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1 effect, that we were, we had an IFOAM program that

2 part of that was that you could not convert native

3 land into organic production.

4 And it was, I think what we did with

5 our standard was that it hadn't been in

6 cultivation within like 50 years or so.

7 It was really challenging. There is,

8 in Washington State at least, there was a lot of

9 land that was converted from sage into ag

10 production within the last 50 years. Some of that

11 even more recent than that.

12 So there are areas where there are,

13 where there is land currently being converted from

14 native habitat to farm production.

15 There's also areas where, around the

16 world, where there is food production or

17 harvesting that's happening in a polyculture type

18 of environment that might be a very high value and

19 very biodiverse perspective. So then you have to

20 think about that.

21 Are you going to exclude those types of

22 communities from participating in organic because
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1 it's, you know, maybe it's just a little bit of

2 cultivation or what level? So it's going to be

3 challenging, but it's worth the challenge to try

4 to figure it out.

5 The statute talks about three years and

6 no prohibited substances. So that three-year time

7 frame is probably an easier thing to work with

8 than the five year time frame.

9 But to put in some, maybe there is some

10 way of putting in some other conditions, during

11 that three-year period of time. But that's

12 looking at the statute and trying to figure out

13 whether that authority is actually there.

14 So that's a rambling non-answer to your

15 question.

16 MR. RICE: A follow-up there.

17 MS. OAKLEY: So yes. No, it's a very

18 challenging issue. It's not rambling, it's trying

19 to figure it out.

20 So my question is, what about 205.105. 

21 What if we were to create some, as a method, not

22 a substance, but as a method, would it fit under
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1 there potentially?

2 And in this case, I guess what I would

3 be referring to would be, no conversion of any

4 land that isn't currently farmed, cultivated,

5 grazed, managed in some way. Which I think we

6 would need to work on defining, very specifically

7 and carefully.

8 But that would make it a little bit

9 simpler than trying to come through a level of

10 scales of what we mean by high value or fragile. 

11 And just define it basically as a native wild

12 ecosystem.

13 MR. MCEVOY: Sure, we can take a look

14 at that. That seems like maybe an area to

15 explore.

16 MR. RICE: Thanks, Miles. Okay, Tom.

17 CHAIR CHAPMAN: Yes, we did receive

18 public comment about that through your transition

19 period, that Miles referenced, and whether or not

20 we could expand it. And that's an area of concern

21 that I have because I want to make sure our

22 recommendation on this can be brought forward and
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1 made into a rule. Because I think it's very

2 important to prevent these practices.

3 I've had two thoughts that I'm just

4 going to throw out there for people to digest, on

5 ways of maybe getting around that.

6 I'll preface it with saying I have not

7 thought of all the consequences of these two

8 thoughts, so, you know, cut me some slack, don't

9 kill me later.

10 One idea is, there's two sides to this

11 issue. One is the incentive, the perverse

12 incentive that's created through the good thought

13 of forcing a transition. The opposite issue is

14 the actual conversion of that land.

15 One way to take away that incentive,

16 potentially, would be to force certification of

17 all land, in transition. At least to be monitored

18 by a certifier so that they would have to go

19 through that practice of looking at that.

20 That's one way of looking at it because

21 then you couldn't, if you wanted to transition

22 that land, you would still have to wait three
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1 years because you'd have to start the monitoring

2 through a certification agency.

3 Don't know, had some issues here. 

4 That's one way of maybe getting at it. It doesn't

5 fully resolve the issue and I'm sure it wouldn't

6 make everyone happy.

7 The other area I think we could

8 potentially look at is 6512 of the production

9 handling practices, which states, if a production

10 handling practice is not prohibited or otherwise

11 restricted under this chapter, such practice will

12 be permitted. Unless it is determined that such

13 practice would be inconsistent with the applicable

14 Organic Certification Program.

15 I don't know if there is something

16 under that that we could say it's not applicable

17 with organic certification. So that's another

18 maybe we could look at.

19 And I know some other folks raised,

20 promoting soil fertility and whether or not moving

21 out of a native ecosystem could truly increase

22 that in any sort of a farming capacity.
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1 So anyway, those are some options. And

2 I really encourage members of the community to use

3 the open docket and to continue to search for

4 justifications we can use under OFPA to throw at

5 Miles.

6 MR. RICE: We have Harriet and then

7 Dave.

8 MS. BEHAR: So another thing that I was

9 thinking about that might be useful, not everyone

10 agrees with this, is that we've set the bar really

11 high. That it's land that's never been cropped

12 and then it also has, perhaps, an endangered

13 species or it's a rare and fragile ecosystem. I

14 think we can get definitions for that. And that

15 we just prohibit any future organic production,

16 forever.

17 And then that is kind of IFOAM and

18 numerous, not all, but numerous other

19 certification bodies around the world. That's

20 what they do. Is they just say, never.

21 But I think we would have to set the

22 bar pretty high for, really. And for me I
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1 thought, well, would we ever want something that

2 had the last living thing, to ever gain that

3 organic label on it.

4 So that might be another place. And

5 that would fit, probably, in 105.

6 MR. RICE: Sue.

7 MS. BAIRD: My grandmother was Cherokee

8 and so I was raised to honor our earth and all

9 living creatures. Perhaps more than others.

10 And I say that to preface that I do

11 reverence that. I've done inspections in the

12 western high deserts where sagebrush and native

13 juniper and everything is being torn up and put

14 into crop land.

15 I've done inspections in western Kansas

16 and Nebraska, Colorado, where native prairie grass

17 that has never been torn up is being torn up for

18 crop lands.

19 And it does break your heart. But, and

20 here's the but, the but is that we're not making

21 any more land and land goes for a premium. I'm so

22 sorry, I'm --
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1 If our organic farmers don't buy this

2 land and use organic practices, you will see

3 conventional farmers buy this land and turn it

4 into conventional practices.

5 I'm not sure where we draw the line. 

6 I like what Harriet said is that we have to set

7 the bar pretty high.

8 I've seen those sagebrush, previous

9 sagebrush fields, where the bald eagles are

10 sitting on the pivots and the impalas are grazing

11 that new alfalfa fields, that they had no food

12 for. I see the jackrabbits and the coyotes and

13 whatever running in those fields and they're

14 pretty happy, because they have a new source of

15 food.

16 So, just to comment, this is a tough,

17 tough situation. It's something that we do need

18 to address because those pristine areas are

19 disappearing from our earth. I have no comment on

20 how to make it happen, but we do need to address

21 it.

22 MR. RICE: Thanks, Sue. Dave.
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1 MR. MORTENSEN: Yes. Yes, I agree too

2 that we need to do something.

3 In surveys in the northeast, 80 to 90

4 percent of the biodiversity occurs in ten to 19,

5 20 percent of the slivers of the agroecological

6 matrix. In other words, the farmsteads. The

7 wooded sections, the riparian buffers, the

8 grasslands, the unimproved pastures. That's where

9 most of the biodiversity is.

10 And a fair chunk of that is actually

11 surveying our pest management in our agricultural

12 fields. There is a fascinating literature that's

13 been coming over the last ten years or so that

14 demonstrates that the matrix, the landscape matrix

15 that your farm is in, has a bigger influence on

16 the pests on your farm than the pest management

17 practices that you're performing.

18 In other words, these slivers of the

19 landscape are mediating pest dynamics in the ag

20 fields.

21 It's late and we need to get finished

22 here, but I guess I would just say that I think
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1 that those slivers are critical. There's a couple

2 of thoughts that I have about how this might be

3 something that we look at.

4 One is that, when I've been involved

5 with workshops on this subject, with farmers at

6 sustainable ag conferences, the room is packed

7 because of the interests that exists in farm level

8 planning, to assess how these slivers are

9 servicing their farmsteads and therefore the

10 stewardship that they deserve.

11 So I think there's a huge education

12 role here that could be an education role

13 targeting the inspection community, around the

14 ecosystem services that arise, that results in

15 farmer initiatives to want to preserve the land

16 and not transform it to have pivots, and whatever,

17 that would exist.

18 The other thing that perhaps we could

19 be looking at is the NRCS is doing a lot of farm

20 level planning, assessing where the most benefit

21 comes from federal program incentives, like EQIP,

22 like incentivizing planting back biodiversity in
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1 biodiversity-impoverished farmsteads, or where we

2 invest in improving riparian buffers, et cetera,

3 et cetera. That we may look at a model of

4 partnering with an agency like that, that's doing

5 this farm level planning.

6 And then there's been some fascinating

7 discussion going on at lunch and breakfast, and

8 all through the course of the last several days,

9 about folks that are here and very interested in

10 working on this planning.

11 There are cool examples of how this is

12 being done in the Netherlands, that I got to see

13 this September. Like bee bed and breakfast on

14 your farm. Doesn't that sound fascinating?

15 So you actually design your farmstead

16 as a bee bed and breakfast. So you're growing

17 food for humans, but you're also creating a

18 habitat for bees.

19 Imagine where we have species diversity

20 on the order of, we think about commercial bees,

21 one species in our orchards, 150, 180 species of

22 bees that are pollinating our organic crops. If
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1 we preserve these slivers of biodiversity.

2 So I think there is some really cool

3 things on the education front in maybe partnering

4 with other organizations that are doing farm level

5 planning.

6 MR. RICE: Okay, we've got Emily, A-Dae

7 and Sue, and then we really need to think about

8 wrapping up. And then I see Harriet now. And

9 Asa.

10 MS. OAKLEY: I just want to advocate

11 for the fact that the environmental movement was

12 really the genesis of the organic movement. And

13 as we have a population of near 7 billion people,

14 I think that any native ecosystem is a fragile

15 ecosystem, is a high value ecosystem.

16 I don't think that we can create these

17 levels of worth and value. I think that every

18 single one of them is an explicit value to us and

19 that we need to do whatever we can to protect them

20 and keep them out of cultivation.

21 I hear what Sue is saying, but I think

22 that we don't have control over the conventional
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1 ag world. We do have control over what we do and

2 the values that we project.

3 And I want to just strongly try to

4 suggest that we think about how to create language

5 that will not allow any native lands, under any

6 circumstances, to be grown in organic farming.

7 MR. RICE: A-Dae.

8 MS. ROMERO-BRIONES: I find it very

9 ironic that we're having this conversation. Where

10 were you 500 years ago?

11 You know, this is one of the main

12 arguments that were used to dispossess tribal

13 people of their lands, that we weren't

14 agricultural producers and they didn't see any

15 value in having lands being undisturbed. And that

16 was one of the main tenets of removing tribal

17 peoples from their lands.

18 So on one end I feel like this

19 conversation is 500 years too late, but it does

20 open up, I think, a great partnership for tribal

21 communities and indigenous farmers who do have

22 legal mechanisms for keeping their lands pristine,
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1 in a sense.

2 I think there is a lot of public

3 concern about having tribal ownership of lands

4 based on casino development. But not all tribes

5 want to put lands into casino development.

6 But they do have these legal mechanisms

7 that could possibly be used to create partnerships

8 between organic farmers and surrounding tribal

9 communities, so that some of these lands do remain

10 undisturbed. And I think that's a partnership

11 that has been long in the making. And it hasn't

12 made that conversion yet.

13 So there are still tribal communities

14 and indigenous farmers that are outside of the

15 organic world, and are probably beyond organic. 

16 Most of the substances that we review in this

17 meeting aren't have been known to a lot of

18 indigenous farmers. So they're not even at this

19 level of using some of these substances.

20 So I think at some point, during the

21 Subcommittee, we can have conversations about what

22 those partnerships may look like. And actually
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1 kind of nail down maybe some possible paths to

2 creating those partnerships.

3 MR. RICE: Thanks for that. Sue, then

4 Harriet, then Asa.

5 MS. BAIRD: Just was thinking, and I've

6 got a friend that feels so strongly about human

7 population, that if they have a child, they adopt

8 a child. Which they've ended up with 12 kids so

9 I'm not sure they're helping the population.

10 What if, if you turn one into

11 production you have to retain one. One for one. 

12 That would at least retain some of the land in its

13 pristine. Just a thought.

14 MR. RICE: Harriet.

15 MS. BEHAR: Okay, so I have a couple of

16 things. When Dave was talking about like the

17 NRCS, and in my state, the Department of Natural

18 Resources, do have conversation easements.

19 So I am thinking about the owners of

20 this land. They are going to need to make a

21 living and so there might be some programs out

22 there where if they are retaining this land, that
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1 there are opportunities for them to keep it

2 pristine and wonderful.

3 The other thing too is I had thought

4 about possibly still allowing wild harvest on

5 lands that are of high conservation value,

6 especially if they're doing things like collecting

7 native seeds. Some of those rare species. As

8 long as they are not diminishing the resource.

9 The third thing is, in Wisconsin, when

10 someone puts in a wetland, if they take out a

11 wetland for development, they have to build a

12 wetland somewhere else.

13 However, I think it's been about 25

14 years since this tradeoff on the wetlands is. And

15 they found that they only have about ten percent

16 of the biodiversity after 25 years. In those

17 recreated wetlands.

18 I just do not, I mean, maybe if we

19 waited a thousand years we would get that. And

20 this is after them coming in and re-colonizing

21 with the native plants. But they just don't have

22 the same biodiversity.
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1 These precious areas that have never

2 been touched by humans. Never been under the

3 plow, have the multistory climax ecosystems are

4 really, really special. And we, as humans, cannot

5 recreate them.

6 MR. RICE: Asa, then I think we'll need

7 to wrap up.

8 MR. BRADMAN: Okay. And Harriet said

9 a number of things that I was thinking about, but

10 one, I think restoration is important, but

11 restoration is not an alternative to, in my mind,

12 to developing pristine landscapes.

13 The other issue though, as we think

14 about this, which you also alluded to, is that

15 there is going to be private property issues and

16 private property rights. And if land starts

17 getting classified outside of any existing

18 framework, we know like issues around wetlands and

19 stuff like that is already very controversial,

20 that we might want to think about those obstacles,

21 as the ideas get developed. So they don't torpedo

22 any proposals.
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1 And then the other point I think is,

2 again to think about, there's requirements for

3 restoration and things like that, but then there's

4 also at least how to avoid incentivizing native

5 land conversion. And maybe they can be a little

6 bit separated. And there might be a way to change

7 the incentives to, at least, as one step.

8 MR. RICE: That's a lot of good

9 discussion, ideas that we can take back to our

10 discussions in the CACS. And with that, we'll

11 wrap up this portion of the agenda, and I give it

12 back to the Chair with nine minutes ahead of

13 schedule.

14 CHAIR CHAPMAN: Thank you. Thank you. 

15 I appreciate the great discussion everybody. You

16 all think you're getting out of here early but I

17 have a surprise.

18 Unless there is an objection, we will

19 be moving to the presentations of certificates and

20 appointments of new members, to recognize the new

21 members on our board. And with that, I will turn

22 it over to Miles.
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1 MR. MCEVOY: Okay, thanks, Tom. So we

2 have five new members, and there's been a lot of

3 great conversation and discussion by the five new

4 members.

5 I hope that you're comfortable with

6 moving on with another four and a half years of

7 your public service. You now have a little bit of

8 a better sense of what you've gotten yourself

9 into, but really, really appreciate everyone on

10 the Board for their service. But really want to

11 recognize the five new members for agreeing to

12 serve on this Board.

13 There were many applicants for the

14 National Organic Standards Board at this last

15 round. In terms of the evaluation of those, those

16 applicants, we used the NOSB criteria that were

17 developed many years ago, as part of the federal

18 register notice, part of the system that we go

19 through, to evaluate those things, evaluate the

20 applicants.

21 There's also a look at balance in terms

22 of geographical and production systems and
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1 diversity, which is very important to former

2 Secretary Vilsack.

3 So with that, I want to present a

4 plaque signed by former Secretary Vilsack to the

5 new members of the National Organic Standards

6 Board, and thank you very much for your public

7 service. With that, I think we should at least

8 give them a round of applause for their service.

9 (Applause)

10 CHAIR CHAPMAN: So we'll recess the

11 meeting before we take the photo. Anything else,

12 Miles, or that's it? Okay.

13 Thank you very much for that and

14 congratulations to the new members. I just want

15 to say, I remember being a new member and I'm

16 really impressed with the amount of questions and

17 engagement you folks all had. That's a really

18 good class of folks that we got appointed here.

19 So thank you to the program, thank you

20 to the former Secretary, and thank you to the new

21 members. Without objection, we will be moving

22 into recess and starting back up tomorrow at 8:30
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1 in the morning.

2 And just as a quick reminder, there is

3 a reception that starts in five minutes at the

4 Whole Foods Rocky Mountain Regional Office,

5 somewhere a little bit north of the ballpark. I

6 hope to see you guys there. Have a great evening. 

7 We are in recess.

8 (Whereupon, the above-entitled matter

9 went off the record at 5:55 p.m.)

10

11

12

13

14

15

16

17

18

19

20

21

22
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A

A- 210:5

A-Dae 1:18 249:15

252:14 328:8,12

331:9,17 351:22

352:3,4,5,8 380:17

435:6 436:7

a.m 1:10 6:2 9:14,15

140:5,6 205:5

AAFCO 247:10,19

249:17

abandoned 148:14

ability 159:15 179:17

236:7 252:7 311:5

313:1 314:1

able 11:19 30:5 40:10

64:6 103:4 106:2,12

107:5 111:16 112:9

129:12 137:16,17

156:11 169:17 221:13

237:2,3 261:2 385:20

407:3

abomasum 392:15

above-entitled 9:13

140:4 205:4 386:3

444:8

absence 243:4 356:21

absolute 246:11 413:21

absolutely 13:21 16:22

35:15 38:22 63:5

217:6 276:16 315:10

399:18

absolutes 85:10

absorb 279:19 311:5

absorption 281:3

absorptive 279:14

abundance 29:9 312:22

abuse 392:9 393:13

ACA 54:10 57:2

ACA/IOIA 185:20

academic 255:5

Acadian 2:16 91:12,16

93:5

accept 12:13 35:13

36:10

acceptable 134:22

231:19

accepted 271:6,13

accepting 36:16

accepts 36:18

access 7:3 19:5 60:3

108:21 243:10 252:11

252:11 253:16 330:18

accessible 60:16

383:17

accessory 324:8

accidentally 335:12

accommodate 255:14

accompany 35:16

account 235:2

accountable 417:17

accounted 46:11

accreditation 5:11 53:4

167:20 413:6 415:1

accredited 35:19 36:1

36:11 156:2 180:3

184:18 187:11

accumulated 282:13

298:20

accumulation 46:1

113:18 116:12,16,19

116:22 175:10,12

234:15 398:2

accuracy 181:17

accurate 63:19 268:17

accurately 269:7

achieves 181:1

achieving 54:12

acid 4:9 24:21 25:1 65:1

84:13,18 85:1 112:22

113:22 270:12,14

285:20 291:2,5,13

292:1 293:12,17

323:22 337:5 382:12

acidified 4:6 285:13,17

285:20 286:1 317:12

acidity 284:10

acids 48:3 113:2 114:11

acknowledge 102:18

103:13 313:18

acknowledged 26:11

acre 217:14

acreage 81:21 264:7

acres 34:14 263:5

act 142:11 155:6 213:13

261:15 287:17 387:14

421:14,18

acting 123:12 176:1

206:1

action 34:16 248:3

400:20

actions 168:6

active 45:6 147:3 373:8

actively 42:22 262:3

activities 280:1 281:17

407:19

activity 33:4,8 105:14

146:14 147:5 149:11

207:16 210:21,22

211:12 261:20 349:20

389:16

actors 58:12

acts 327:7

actual 95:22 123:17

158:16 339:14 347:14

370:2 409:3 427:14

Adams 2:7 96:9 100:11

100:14,14 104:4,7,13

104:17 105:2,22

106:17

adaptive 162:12

add 46:7 89:10 112:20

150:3 154:16 157:20

158:19 187:15 207:14

237:4,5,22 325:19

333:2 341:11 357:14

362:14 377:13 405:14

418:5

added 9:7 11:11 25:1,1

90:19,21 100:21

111:22 142:1 145:7

149:19 150:16 166:4

212:9 228:19,20

237:4 280:3 323:16

324:22 335:9,16,18

336:1 338:18 356:2

addendum 334:13,16

adding 69:19 75:18

90:11 216:6 337:12

addition 60:6 145:4

161:7,16 179:13

181:9 183:4 249:19

290:12 323:4 326:2

334:11 336:8 414:21

additional 75:3 76:10

107:12 110:7 111:9

111:18 113:10,15,21

139:7 159:16 161:5

163:10,15 166:20

168:2 181:14 196:2

197:4 211:19 216:6

216:22 228:19 362:10

410:13

additionally 98:9

267:10 269:7 270:16

318:6 335:12

additive 176:6 294:8

297:19

additives 237:15

312:20 371:10

address 61:15 64:10

95:1 105:19,20

108:19 160:12 171:15

233:12 234:14 248:18

250:9 319:3 339:2

355:20 357:3,18

363:5 370:4,19 400:8

406:15 431:18,20

addressed 45:12 53:6

57:10 83:17 136:13

161:8 164:11 190:8

210:4 234:17 380:11

413:19

addresses 339:3

addressing 177:19

191:19 207:7 213:1

357:1

adds 235:1 236:5

adequate 162:9 216:10

356:8 416:17

adequately 161:8 167:9

adhering 20:17

Adjourn 5:22

adjuster 284:14

adjustments 222:14

administered 404:3,5

administering 395:16

395:19 396:9,11

400:15,16 401:16,17

Administration 395:10

administrator 2:5

414:19

admission 34:20

adopt 60:10 438:7

adopted 182:13

adsorb 279:19

adsorption 281:3

adulteration 62:1

272:10

advance 6:14

advanced 330:16

advancement 218:20

advancements 26:12

advances 271:18

advancing 184:15

advantage 335:8

adverse 75:15 133:1

366:20 367:20

advised 164:7

advisory 2:2 36:2

advocate 21:19 165:1

435:10

advocating 273:13

aeroponic 100:18 101:3

102:14 241:13 243:7

aeroponics 26:6 101:5

173:13 209:15 245:4

AFCO 251:2

Affairs 258:4

affect 159:10 271:7,11

335:13 367:20 423:1

affective 372:5

affidavit 347:7,19 348:1

350:10,22 351:1,5,6,7

affidavits 348:19

350:11

affiliate 121:3

affiliation 7:6 8:11

10:14 17:21 34:4

37:22 51:16 57:16

61:12 69:9 74:12

79:15 85:15 88:1 91:9
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96:11 100:13 107:16

110:12 117:12,14,17

123:8 140:10 142:20

146:3 153:8 160:6

168:21 171:2 179:21

183:10 189:21 205:20

215:7 246:7 254:5

257:22 261:11 264:20

269:2 274:5

affiliations 7:9 120:15

afford 201:7

affordability 194:12

afraid 91:2

afternoon 139:20

205:21 232:22 240:21

258:2 264:21

ag 34:12 190:19 292:14

424:9 432:19 433:6

436:1

agar-agar 335:22

354:20

agave 267:9

age 198:9

aged 198:8

agencies 217:16,17

247:12

agency 74:16 136:7

188:3 428:2 434:4

agenda 278:4 308:3

343:3 349:6 365:12

380:12 385:16 401:12

413:10 419:16 441:11

agent 36:14 108:3

284:10,10 287:1

311:4 317:8 318:2

362:5 415:5

agents 388:21

aggressive 230:6

ago 63:15 71:21 95:15

129:18 306:16 359:17

414:15 436:10 442:17

agree 42:12 55:19 56:5

56:21 71:19 187:20

190:16 198:5 246:22

249:2,3 250:16

254:15 255:11 261:22

376:9 380:15,21

385:10 407:10 418:1

420:16 423:17 432:1

agreed 201:18 223:1

250:8 407:12 417:14

agreeing 369:13 442:11

agreement 202:21

368:13

agrees 101:1 156:2

429:10

agricultural 18:5 44:22

90:7 91:14 111:12,15

111:20 112:5 144:8

158:19 191:10 207:1

258:19 261:18 264:12

279:3 292:6,8 300:14

319:15 327:10 340:9

343:13 345:6,6,8,15

354:4 380:16 432:11

436:14

agriculturally 262:22

292:14

agriculture 1:1 60:15

60:21 85:11 91:18

133:20 144:11 146:11

148:4 190:17 191:12

203:3 206:11,12

207:2,5,12 208:7

233:7 261:15 264:3,6

390:2 423:9,22

agroecological 432:5

agroecosystem 146:13

agronomic 219:22

agronomist 86:14

Ah 404:21

ahead 6:18 79:4,7 90:5

126:8 156:5 189:16

322:19 340:5 366:12

370:17 441:12

aid 182:7 234:21 279:10

282:10,14,17 286:2

287:1 362:5 389:5

aids 301:12

aiming 60:11

air 206:7

alcohol 317:14 382:12

aleck 10:9

Alexander 2:10 69:7,8

69:12

Alexis 3:5 69:7 74:10

74:11,14 77:16

alfalfa 431:11

algae 4:14 75:8,10 78:5

83:11,12,17 92:1,6,8

92:12 94:5,13,14

95:15,18 156:9,22

353:9,22 356:2

360:14

algae-derived 74:19

algaes 157:9 357:6

360:6

align 125:4

aligning 358:15

alike 324:1

all's 410:6

allegations 139:7

Alliance 422:9

alliance's 263:15

alliances 263:21

allotment 6:21

allow 9:5 11:9 26:8

35:13 59:11 60:18

103:6 111:11,19

114:11 124:2,10

125:9 126:20 128:14

130:8 134:20 137:22

175:20 176:7 195:3

195:15 204:19 250:15

264:10 317:16 327:18

345:7 355:1 356:11

436:5

allowable 128:3 346:18

allowance 414:2,2

allowed 9:8 11:12 13:19

14:6 90:2 92:1 97:17

108:1 113:11 131:1,3

131:3 133:5 153:3

155:4,15 156:19

158:5,9 164:4 173:17

174:4 175:4 176:19

178:2 204:3 208:13

218:6,20 220:17

227:20 228:4,11

265:18 279:3,8

285:17 290:21,21

300:14,18 323:17

324:17 327:1 346:14

355:13 382:11 386:20

388:7,18,20 389:13

392:12

allowing 36:4 128:10

128:17 130:13 134:4

169:10 176:16 262:13

327:17 354:17 439:4

allows 12:8 15:21 96:4

173:5 227:3

alluded 339:9 440:14

alongside 334:15

alter 369:22

alterations 108:10,19

109:8

alternate 72:3 73:10

alternative 76:1,12 85:7

126:21 140:20 141:20

172:17 216:13 301:7

311:3 321:19 375:13

384:15 388:20 398:3

398:8 414:5 440:11

alternatives 76:6

141:15 155:10 206:10

259:14 281:17 283:2

303:12 311:18 312:7

315:12 367:8 371:17

373:3 375:6,10,16

384:22 385:9 388:6

398:20

altogether 213:4

alumina 280:22

aluminum 279:16

amazed 129:16

amazing 58:16 145:6

183:19

Amazon 329:20

AMDUCA 395:9

amend 265:17 355:11

amendment 103:1

212:14 213:1,6,13

amendments 69:20

102:21

America 57:22 284:17

American 107:19 151:7

247:10

amidated 318:20

amino 48:2 323:22

ammonia 109:19 382:7

Amorphophallus

310:17

amount 9:22 12:11

41:19 75:3 78:12

95:22 123:3 131:11

132:1 150:4 152:10

183:19 223:10 228:18

228:19 232:9 296:2

303:16 356:20 443:16

amounts 76:9 176:15

217:13 294:18

ample 267:14

amplification 65:14

amplify 65:9,10

AMS 2:5

Anaerobic 228:16

analgesia 108:3 395:14

396:7

analgesic 396:2

analysis 266:16 415:11

analyze 49:8

analyzing 150:1,2

ancillaries 362:14,15

363:6

ancillary 4:15 112:17

160:13 162:19,22

258:20 289:22 302:20

326:4 362:1,8,10

363:20 364:6 380:2

and/or 324:8 335:6

344:22 388:21

anesthetic 108:4

397:10 400:13,19

401:15,21

anesthetics 108:2

401:3

angry 139:15

animal 91:14 107:6,18

108:15 109:12,21

188:21 248:4 253:4

253:16 257:12 279:10
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301:13 344:7 393:5

394:14 402:3 403:4

404:6 410:16,21

411:14

animal's 172:9 253:3

animals 40:22 81:1

102:20 103:5 107:20

108:7,17 162:5,7

247:14 301:14 302:3

302:17,17 389:20

395:19 396:12 400:17

401:18 403:13 404:20

Ann 2:18 139:21 261:10

264:18,19,22 268:1

annotate 75:9 79:5

92:11

annotated 182:8 293:16

353:22

annotating 74:20 78:13

annotation 4:13 75:13

84:15,22 89:9,11,20

94:11 111:1,8 112:7

113:1,10,12,16

114:14 115:12 154:12

171:19 259:9 290:7

323:19 324:21 344:9

345:11 347:13 349:19

393:14 394:6

annotations 80:13

163:9 182:11,19

248:18

annual 131:8 187:18

216:9 254:22 415:17

416:1

annually 64:5 227:12

256:7

answer 67:19 74:3 82:5

87:17 94:1 106:10

107:10 125:5 167:14

170:17 194:10 200:13

200:18 216:14 237:9

246:16 249:10 253:9

259:7 274:1 309:5

321:6 347:11 348:13

368:10 380:8 410:7

answered 104:11

121:10 199:17

answering 88:12 137:3

answers 48:20 100:7

193:4 195:9 240:13

277:5 290:10 384:21

409:19

anti-caking 284:10

362:5

antibiotic 403:6

antibiotics 97:16

402:11,14,17 405:15

405:19,19

anticipate 98:17 296:7

antimicrobial 389:3

Anybody 408:22

anymore 43:11 273:22

anyway 178:11 251:18

274:20 308:5 429:1

apologies 107:15

apologize 9:17

appear 162:13

appearance 335:13

appeared 36:16 132:9

appears 311:12 312:5

applause 277:3 413:4

443:8,9

apple 68:11 318:12

320:4

apples 97:15 319:16

320:2

applicable 26:15

125:19,21 387:9

397:10 428:13,16

applicants 442:13,16

442:20

application 8:21 10:3,6

11:3 64:22 136:6

175:20 180:15 182:8

250:10 337:5

applications 91:14

236:4 391:19 415:18

applied 3:4 12:18 62:22

67:13 68:5,11,19,20

68:21 80:11 82:20

83:2 113:13 123:22

129:22 136:15,17

139:1 169:17 187:21

217:13 229:7 237:17

269:3 271:17 345:21

applies 247:20 351:12

apply 23:20 135:10

149:17 159:17 182:17

232:7 237:3,7 290:7

326:11

applying 82:7 101:12

167:19 207:7

appointed 443:18

appointments 441:20

appreciate 51:6 64:10

75:17 93:21 140:15

143:3 162:22 163:8

179:3 183:17 212:5

394:21 441:15 442:9

appreciated 211:17

240:14 360:3 386:10

417:1

appreciates 74:17

91:16 97:18 100:16

180:13

appreciation 188:9,21

approach 53:2 67:4

73:1 76:3 149:1 174:6

178:1 248:1 303:1

375:5

approaches 12:7 99:11

appropriate 128:3

202:16 274:8 288:15

approval 234:8

approve 352:10

approved 75:16 114:13

153:18 158:4 212:10

240:10 326:8 389:8

392:17 414:5

approves 54:15

approving 157:5

approximately 160:9

266:19

APRIL 1:7

apt 406:14

aquaculture 101:8

102:9,19

aquaponic 27:18 69:14

69:15 70:4,11,14 72:1

72:11 73:5,9,11

100:18 101:7,18

102:4,15 103:11

104:11,14 106:18

125:4,9 143:17,19,20

202:14 241:13 243:8

aquaponics 26:6,18

27:2 70:7,20 72:13

101:6 102:22 143:16

144:20 145:1,5,12

173:14

aquatic 92:4 102:20

103:4 137:22 154:13

154:14,18 156:15

158:6

aquiculture 203:19

arable 206:4

arbitrary 174:5 178:8

404:11

area 22:3,8 30:14 95:19

123:19 138:14,17,20

186:2 192:21 210:17

216:1 225:22 227:10

257:11 279:19 316:4

359:18 370:6 378:2

400:21 401:22 403:20

420:18 423:18 426:14

426:20 428:7

areas 60:2 76:17 77:7

96:3 104:18 135:15

141:5 148:13 180:20

201:8 226:1 256:20

263:14 376:16 378:1

420:14 422:9 424:12

424:15 431:18 440:1

arena 376:12

argue 151:18 221:22

271:20

arguing 204:7

arguments 436:12

Arizona 193:11

aroma 335:14

arranging 99:8

ARSENAULT 2:2

art 257:7

arthropods 105:17

149:14

artichokes 267:9

articles 256:13

articulated 169:20

artificial 177:20

Asa 1:14 41:2 45:11

47:1 84:11 113:21

227:16 236:11 239:18

243:14 301:2 302:13

302:16 319:7 340:13

340:14 341:14 349:13

363:9 364:3,8 365:13

381:1 384:11 385:11

385:14 435:9 438:4

440:6

ascertain 35:11

Ascophyllum 92:22

95:20,21 96:4

ascorbic 24:21

ash 281:2 284:19

Ashby 2:8 139:22 269:1

274:4,6,6,11 277:11

277:16

Ashley 1:19 21:16

22:21 99:16 120:13

121:8 126:7,8 167:6

249:15 250:18 285:22

287:20 322:17,20

323:14 351:14 352:7

360:4,12 363:9,18

364:8 386:13 403:9

413:3 418:14,20

Asia 310:18,21

aside 256:14 420:3

asked 7:5,11 99:18

125:3,20 149:12

194:6,8,20 195:12,17

196:13 198:22 230:9

273:6 307:11 312:8

321:14,16 348:20

359:13 375:8

asking 29:1 62:7

120:14 142:5 196:13

198:2,3 212:22

233:10 259:17 347:7

351:7 355:7 371:4

410:6
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

448

ASPCA 3:1 107:19

109:21

aspect 165:15 213:11

238:1

aspects 200:19

assert 147:2

assertion 26:19 150:20

151:4 185:22

assess 130:3,4 162:1

247:2 248:17 308:8

308:10,11 433:8

assessed 190:4 346:22

assessing 433:20

assessment 257:9

assign 67:11

assigned 415:14

assist 172:1

assistance 357:22

associate 27:3

associated 12:13

222:15 313:16 366:19

392:13

Associates 2:10 3:19

79:17

association 2:8,21 3:8

3:20 51:18 180:3

187:11 247:11 256:10

258:2,5 261:13

263:15 312:17 318:3

324:12

associations 317:18

319:6

assuming 135:3,6

163:5 423:17

assumption 67:5,8

assumptions 230:22

assurance 2:14,15 3:5

61:22 62:20 74:15

246:10

assure 67:15

at-risk 192:21

atmospheric 286:21

attacks 7:12

attaining 60:17

attapulgite 4:4 278:18

279:8,9,13

attempt 100:17

attempting 184:4

attempts 19:11 81:10

attend 11:19

attendance 256:9,10,11

attention 161:20 190:5

attributes 27:15

audience 309:16

386:15

audio 9:19

audit 35:17 55:4,13

255:8 413:22

auditable 132:16

auditing 132:1

auditor 255:19 256:4

auditors 255:6 256:2,4

audits 167:20 184:9,22

185:3,8 416:3

August 323:3

auspicious 274:9

Austin 331:15

authentic 20:8

authenticity 62:21

336:12

author 94:22

authorities 373:20

374:3,12

authority 125:20 370:4

373:7,22 374:7

377:16 414:15 425:13

authorization 377:22

authorize 138:5

authorized 35:19

AV 17:10 25:20

availability 75:18 89:11

91:2 112:12 119:3

141:5 217:22 231:7

260:1 308:1,16 312:6

313:13 314:10 343:17

344:12 348:17

available 19:15,16

29:10 30:9 60:9 76:2

80:11 83:9,21 91:1

111:5,21 121:22

124:3 151:7,13

153:20 155:11 156:14

156:18 173:1 204:8

208:6 218:8 240:17

259:1,11 261:6

267:15 268:10 297:1

300:19 304:3 308:9

311:17 314:7 315:13

323:10 327:4 329:11

348:8 397:19 403:6

407:1

avenues 201:8

avid 20:3

avoid 59:3 375:5

391:11 441:4

avoided 108:14 311:13

391:12

avoiding 59:21

aware 14:16 34:19

47:22 98:3 133:17

174:13,17 272:5

321:13

awareness 188:4 299:2

321:17

awesome 261:21

awhile 306:16

B

B 285:16 347:14 349:11

397:8

B1 377:2

babies 142:5

baby 142:12 265:8,10

Babylon 70:22

bacillus 149:18

back 6:5 9:16 10:10,11

10:12 24:2 25:21

31:21 32:3 63:9,21

67:8 73:15 75:4 78:16

78:17 85:4 129:9

132:14 135:16 139:18

149:11 150:9,14

158:17 160:21 165:4

179:12 193:14 202:6

203:19 212:11 259:18

268:16 291:1 296:16

321:9 338:16 346:2

350:4,13 351:16

352:7,11 353:6

356:10 359:3 360:6

360:14,15 361:20

363:3,21 364:6,11

365:5 368:7,10

372:12 374:2 386:1,7

386:11 404:10 409:15

412:21 413:2 414:7

414:22 416:17 418:10

418:16,19 419:15

433:22 441:9,12

443:22

background 38:11 95:6

124:19 153:12 258:8

359:8

backgrounds 255:6

backing 53:22

backyard 12:15 15:9

bacteria 19:16 40:22

389:6

bad 70:13

bag 244:7 369:4 378:9

BAIRD 1:13 33:3,7,17

33:19,22 67:19 68:7

68:18 69:1 104:10,16

104:19 170:13 332:13

333:20 341:1 342:6

352:19 361:1 364:16

419:2 430:7 438:5

baked 291:15

baking 24:21 291:16

balance 30:15 60:11

147:20 174:19,22

175:7,14 176:22

263:3 391:4 442:21

balanced 108:22

balances 257:7

bald 431:9

balloons 149:18

ballpark 78:1 444:5

Ballroom 1:9

bank 202:8 204:18

banned 195:19,21

368:15

banning 369:17

bar 54:11 202:15

429:10,22 431:7

bare 124:4 130:17

131:1 136:21

barking 276:20

barrier 60:3 92:6 94:15

192:1 237:18

barriers 306:13 307:13

308:9 388:21

Barry 420:2

basally 239:4

base 63:4 65:10,12

237:8 243:22 266:13

269:20 280:13 284:15

based 19:12 67:4 72:16

73:18 99:13 115:3

147:16 187:17 194:18

197:13 207:4,17,20

213:9,10 214:15,17

214:18 232:7,10

236:17 237:10,14

242:3 244:14 245:1

245:21 249:18 251:15

263:18 264:6 267:5

273:14,17 294:5

314:18 323:21 346:20

353:20 408:7 412:5

414:3 418:7 437:4

BASF 3:7,15 17:12 38:2

38:6 233:1,5

basically 32:8,20

165:11 202:17 208:22

223:9 231:10 292:11

292:20 336:11,14

369:18 426:11

basil 24:3 143:21

241:17 243:21 245:13

245:13,14

basis 122:17 201:15

403:10

batch 240:4

baths 399:18

batting 274:4

bean 67:15

becoming 8:19 11:1

12:6 148:4 272:5,21

bed 69:18 70:1 434:13

434:16

bedrock 118:3

beds 96:1
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Neal R. Gross and Co., Inc.

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bee 434:13,16

beef 301:5 403:13

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beetle 246:19

begging 159:19

beginning 7:7 9:20,21

10:13 18:16 21:20

214:8 234:20 238:21

278:8

begs 125:8

behalf 74:3 85:17,19

107:21 170:1 202:19

265:5

BEHAR 1:14 14:14,16

15:3 24:14 30:13 37:2

41:3,14,16 56:11 66:3

73:18 82:4 110:4

131:5 157:19 158:21

159:8 165:4 186:9,12

186:17 192:16 196:11

208:19 213:16 214:2

224:21 245:7,12

249:16 296:14 306:9

309:8 316:4 320:9

322:9 330:4 332:14

333:21 337:20 338:2

341:2 342:7 347:6,21

348:10,15,18 349:15

352:20 361:2 364:17

376:15 381:19 389:2

390:12,19 391:22

394:20 398:6 406:13

410:9,15 418:7 419:3

419:21 429:8 438:15

Belgium 235:11

belief 62:2 241:9

beliefs 141:1

believe 14:5 73:19,21

86:19 87:8 94:18,22

101:20 106:7 121:15

161:19 163:22 188:13

216:21 260:10,18

266:4 267:2 273:22

277:20 322:1 325:8

328:18 346:17 382:21

383:7 409:16

believes 53:9 70:9

173:14

bend 143:3

beneficial 144:15

147:17 150:17 184:7

benefit 153:13 169:16

407:11 420:20 433:20

benefits 20:9 60:14

64:13 92:9 148:1

263:8 267:2

bentonite 4:4 280:16,19

280:22 281:5,13

Berkebile 2:9 107:15

110:13,14 114:10

115:6,11 116:7,13

117:9

Berkeley 62:13

berries 86:2

best 13:2 29:9 135:21

162:11 167:17 191:18

220:22 221:1,2

223:12,18 249:3

251:3 259:5 266:10

275:21 303:15

Beth 3:11 140:8,9,11

better 15:6 22:18 35:3

56:12,22 57:2 80:22

99:10 118:20 120:16

134:11,15 135:18

161:22 166:10 186:1

190:10 217:6 219:3

221:4,18 223:19,22

243:2 251:22 276:2

306:13 307:12 309:10

310:5 359:16 377:13

442:8

beverage 286:22

beverages 282:15

294:1

beyond 26:15 142:6

192:6 249:16 271:22

286:10 288:11 349:5

349:9 370:3 382:17

388:11 394:5 437:15

bi-polyethylene 38:21

bias 198:6

biased 201:7

big 21:19 22:15 34:12

66:16 220:7 221:20

228:12 229:5,5

365:21 381:11 384:19

bigger 306:10 432:15

biggest 191:22 224:16

226:5 275:8 379:18

Bill 2:10 3:19 74:10

79:13,14,14,16 82:2,3

84:7,11 85:13,13,14

85:16,18

billion 62:22 63:16

271:16 435:13

binary 196:3 201:17

bind 296:22

binder 311:4

binding 298:12

binomials 74:20 92:12

354:1 355:2,13 359:6

bins 377:4

bio- 213:9

bio-based 49:21,22

172:16,20 173:2,7,10

174:12 176:1,18

212:15,16,21 213:3,6

213:17 234:11 236:13

237:3

bio-degradation 214:7

bioactive 266:17

biobased 38:14,16,19

38:22 39:7,14 40:9

41:19,21 50:4,8,17

51:2

biochemist 15:1

biodegradability 41:18

212:17 213:5

biodegradable 3:6 8:22

9:5,8 11:4,9,12,21

12:3 13:18 38:5,7,9

38:12,14,17 39:2,4,7

39:13,18,22 41:21

44:16,20 50:1,2,14

60:7 152:9 153:1

172:13,15,19 173:9

174:12 176:18 212:3

212:9,10 213:17

214:3 233:3,17 234:1

234:10,12 235:12

237:11,13

biodegradation 38:12

39:19 44:12 213:12

234:4 235:20 236:1

238:22 239:2

biodegrade 236:7

237:19 238:2

biodegrading 42:4

biodiverse 424:19

biodiversity 28:13

30:16 31:1 106:7,21

146:14 147:21 190:6

206:19 210:9 257:10

261:17 262:3,5,21

263:17 264:4,14

420:4 423:9 432:4,9

433:22 435:1 439:16

439:22

biodiversity-impover...

434:1

biofuels 151:2

biologic 33:8

biological 32:1 33:4

44:12 81:5 105:14

146:14 147:3,4

149:10,16 206:6

207:15 210:21 211:11

214:5 242:5 261:19

261:20 269:21 270:5

270:8

biologically 26:9 43:10

99:12 101:9 191:7

216:3

biologist 65:8

biology 19:12,14 30:1

32:17 33:12,12,14

42:17 59:21 62:9

69:20 193:17 208:2

217:21 227:4

biomass 39:5 40:5,13

40:13,18 42:19 44:4

47:6,7,8,18,19,21

169:3,14

Biopolymers 233:1,5

bioponic 141:4

bioponics 140:14

biotech 64:21

biotechnology 270:12

337:4

biotic 81:8

birds 109:17

birth 394:12

birthed 58:15

birthing 391:10 392:14

Bisphenol 4:17

bit 16:8 22:1 41:7 42:9

55:9,15 67:20 106:6

184:20 206:3 207:13

258:7 297:7,13

298:13 301:9 306:10

320:20 321:2 326:15

367:21 368:7 401:1

402:1 405:1 407:12

407:16 425:1 426:8

441:6 442:7 444:5

bits 260:12

black 174:21 176:15,16

240:4,6

blank 404:17

blend 222:13

blends 220:9 230:6

bless 250:20

blessed 275:20

blessing 34:17

blight 97:15

blind 310:4

block 227:1 311:12

blocks 226:13

blood 391:4

blueberries 85:22

224:11 225:6,19

226:16,19

blur 101:13

board 1:3,9 2:2 3:6 7:8

7:14,18 10:11 36:2

41:7 42:2 51:19 53:11

58:5 88:5,8,10 89:14

89:19 90:5 93:22

98:18 99:3 110:19

114:20 139:16 149:4
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

450

153:13 155:4 171:15

178:21 180:4 187:4

202:18 205:8,14

208:9 212:4 223:6

229:22 233:2 234:7

240:21 244:17 247:5

248:16 251:19 265:2

265:4 272:15 278:1

278:13,22 283:7,22

284:1 285:11 286:13

307:7 318:16 323:9

323:13 325:21 328:5

330:20 331:14,15

333:6 337:19 343:5

346:5 347:10 354:22

356:14 370:7 379:14

386:6,8 387:1 411:22

420:2 422:22 441:21

442:10,12,14 443:6

boards 121:2

bodies 429:19

body 29:6 256:10

367:16 378:21

boil 28:11 201:14

Bollag 2:10 69:7,10,12

74:2

bolster 255:19

bonemeal 220:16

boots 339:13

boron 97:8

bottom 197:21

bought 71:10

boundaries 190:13

191:14,15,18

bounds 262:20

BPA 4:17 260:13,17

365:12 366:3,7,14

367:2,7,13,16 369:9

371:4,6 372:20 373:1

373:6,14,16 374:8

377:14 379:5,15

BPA-free 373:4

BPF 371:19 376:2

BPI 212:7

BPS 371:19 376:2

Bradman 1:14 47:2,20

48:4,22 49:8,19 84:12

113:22 198:17 199:4

199:12,20 227:17

236:12,20 238:4,7,11

238:13 239:6,10,13

239:17 243:15,19

244:8 301:4 303:6,20

319:8,18,22 332:4

333:12 340:15 341:14

342:12 353:3 361:7

363:10,17 364:2,22

365:15,18 371:13

374:18 375:19 378:8

380:4 381:2 384:13

419:8 440:8

Brands 2:15 193:9

265:7

break 78:6 139:16,17

179:11 197:5 204:22

222:6,7 231:2 385:20

386:1 430:19

breakdown 44:3,9

breakfast 434:7,13,16

breaking 14:18 43:22

238:14

breaks 176:6

breakthroughs 228:12

breast 266:19 276:15

breed 249:9 253:18

breeding 270:2 271:1

brief 90:16 163:20

343:11

briefly 32:5 56:4 84:14

112:6,21 113:7

163:18 238:6 359:12

brine 285:2 289:21

Brines 2:3 8:7 115:18

115:19 278:19,20

280:16,17 282:2,6

283:8,9 284:4,5

285:14,15 286:16,17

287:10,11 289:2,3

291:3,4 293:4,5

300:10,11 310:10,11

316:22 317:1 322:18

322:21,22 334:7,8

343:1,2,8 383:5,6,14

386:17,18 387:6

388:14,15 390:15,16

391:16,17 395:2,3,20

397:6,7 400:10,11

401:10,11

bring 24:4,5,7 96:5

188:13 274:21 409:15

414:7

bringing 24:11 374:11

brings 306:9

broad 101:11 201:15

232:11 251:21,22

268:5 288:2,21

353:20 387:21 401:7

407:14

broad-based 12:18

201:5

broaden 95:4

broader 167:4 182:21

371:3

broadly 26:15 248:10

broken 16:16 31:6

43:13 215:16,19

brought 164:6,14,21

241:16 296:21 354:10

426:22

brown 91:22 92:5 94:5

96:1 154:17,22

156:21 354:17

Broydrick 2:10,10

79:14 85:16,17,18

buffers 432:7 434:2

BUIE 1:15 29:13 30:5

332:9 333:16 340:19

342:2,17 352:15

360:19 364:12 397:13

398:22 419:12

build 142:7 144:22

145:1 439:11

building 133:22 134:1

141:22 148:15 222:17

222:18 249:22

builds 145:7

built 162:10

bulk 23:16

bunch 275:2

burden 157:21 370:6

burdened 76:9

burdensome 112:19

163:7

burning 15:20

business 2:17 13:22

191:15 203:20 226:9

233:2 304:22

businesses 96:15,20

98:3,4 219:13

busy 246:19

butchered 57:15 160:5

butchering 171:6

butter 284:12 298:12

button 135:9

buy 28:1 194:14 198:13

199:22,22 200:22

243:17 306:5 329:17

329:18,20 431:1,3

buzz 8:2

byproduct 144:16

291:14 292:3,7

byproducts 317:11

C

CAC 52:3

CACS 6:9 184:3 254:16

418:17 419:15 441:10

caffeine 298:11

CAFO 19:4

calcitrant 216:3

calcium 4:7 5:3 287:18

293:11 296:22 387:15

calcium- 298:11

calculated 45:19

calf 392:14

California 34:13 62:14

226:1 241:6 366:6

368:4

call 47:19 88:13 133:20

141:10 144:10 189:16

244:22 370:20 409:1

called 21:9 39:1 163:9

235:10 252:16 310:19

363:6 371:10

calling 212:14

calls 251:15 295:20

calorie 311:2

Canada 146:8 151:10

152:3 153:4

Canada's 152:2,3

Canadian 83:5,7 91:12

cans 366:15 367:15

372:22,22

capacity 151:17 216:1

428:22

capsule 311:11

capsules 311:13

capture 19:20 21:2

201:3

car 199:22,22 200:13

carbohydrate 268:9

276:17 311:2

carbohydrates 276:14

carbon 4:7 19:21 21:2

38:18 39:3 43:12 44:4

47:13,14 48:14

148:20 207:8 209:4

228:19 239:21 240:4

240:6 262:8 263:7

286:15,15,19,20

carbonate 4:6 284:4,6,9

carbonation 286:22

carcinogen 378:13

381:3

care 20:6 40:8,9 57:22

58:8 133:14 137:7,9

142:11 207:3 252:12

274:20

careful 19:21 128:22

302:2 376:13 391:9

394:11

carefully 12:17 83:18

98:16 101:2 142:13

426:7

cares 58:11

carrageenan 354:22

carried 238:17

carry 98:1 261:2 414:18

carrying 71:8

cars 200:5

CAS 310:12

case 46:4 66:10 148:2
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

451

196:1 228:22 233:15

234:1,2 276:9 399:1

426:2

cases 43:22 63:11

66:15 75:2 95:19

139:2 158:18 227:10

229:6 235:14 304:7

325:12

casing 301:7 302:8

306:5

casings 4:10 300:9,22

301:4,6,20 303:2

304:1,11 305:1 362:4

casino 437:4,5

cast 362:21 395:4

catalytic 200:14

categories 382:2

category 119:15,18,21

324:2 377:7,12

catfish 102:6

cattle 392:3 397:16,21

402:4 403:12 405:22

caught 362:22

cause 119:6 294:19

367:20

caused 63:13,15

212:15 395:15 396:7

causes 297:11 389:6

causing 389:15

cautioned 354:12

cautious 13:2

CCOF 34:14,17,19,21

35:5,13 36:15,16,17

394:4

CDFA 34:17

CEA 3:12 26:3

celebrate 420:16

cell 47:16 270:19,22

271:3,5,6

cells 271:4

cellulars 215:18

cellulose 4:16 112:15

112:20 160:13 162:19

162:21 301:8 302:19

362:2,3,6,8 363:20

364:6

census 201:4

Center 296:20

centers 104:1,3 150:14

151:19 152:13

cents 58:20

centuries 70:21

century 297:5

CEO 26:2 169:14

certain 89:6 152:10

155:14 177:6 232:9

233:19 237:3,15

251:20 379:9 381:6

407:13 420:22 422:1

certainly 72:11 131:21

251:19 262:16 273:20

319:22 375:22 383:18

certainty 218:11

certificates 441:19

certification 2:11,13

3:2,9 5:11 8:20,21

11:2,3 26:5 28:8

69:14 71:7,16 72:21

73:7,10,13 74:16

102:20 103:2,6

105:12 118:11 125:15

125:19 126:2,13,19

127:11 128:10,19

160:8 169:12 171:7,8

180:1 188:5 190:4,9

191:17 202:4 217:16

242:12 246:9 254:14

255:17 258:13 316:11

349:20 405:22 413:6

415:8,19,20,21 416:1

417:19 427:16 428:2

428:14,17 429:19

certifications 159:5

certified 2:9 3:8,10 8:19

11:1 13:7 15:14 20:12

20:20 21:20,21 22:5

22:10,11 26:10,19

29:20 35:11 69:16

74:21 75:21 83:4,20

87:12 88:22 89:1

96:19 97:4 98:12

102:5 103:12 104:8

110:15 111:16 118:13

124:9 125:10 134:13

143:6,7,19 144:4,5

153:16 155:19 162:20

169:19 170:4 180:2

187:2 192:18 220:1

242:8 280:9 289:11

305:2 312:16 314:9

315:22 316:17,19

335:20 355:22 371:5

certifier 36:11 52:14

54:16 55:8,20 131:10

159:18 162:17 178:5

185:1,4 204:10

248:13 250:9 252:2

253:21 281:19 347:10

416:20 427:18

certifiers 29:1 36:1,9

52:8,9 53:7 78:16

103:10 112:13,16

116:3 123:20 124:10

125:16 129:18 130:7

131:22 132:6 134:20

136:5,9 153:21 154:5

154:8 157:5 164:10

165:11 166:4 167:10

167:18 172:1 180:3

181:16 182:5 184:8

187:11,21 192:6,9

203:14 247:1,4 249:5

249:6 251:7,14

280:12 281:20 312:15

317:18 345:1 350:21

387:22 393:2 407:10

408:10 409:19 413:15

414:2,14,17 416:9

417:1,16 422:18

certifiers' 53:20

certifies 77:18 110:16

134:9 180:4 188:1,2

certify 34:21 77:21

103:4 104:3 106:12

106:18 125:17,22

153:22 160:9 171:11

certifying 36:14 104:11

104:13 130:10 171:10

415:5

cetera 249:9 335:22

358:16 434:2,3

CFR 324:15 395:9,11

chain 62:15 67:10,11

68:20 75:5 123:14

270:6 336:10

chains 97:2 268:6,9

chair 1:13,19 6:3 8:7,9

9:16,22 10:4,7,10

14:8,12 15:11 16:2

17:7,9 21:6,15 22:21

24:13 25:18 29:11

30:12 31:10 32:5,11

32:22 33:5 34:1 36:20

37:1,18 41:1 43:16

45:10 46:22 51:5,11

51:13 54:18 55:17

56:4,10 57:12 60:22

61:5,8 64:15,17 66:1

66:18 67:18 69:3,6

73:17 74:9 77:15 78:3

79:10,13 82:2 84:7,10

85:12 87:20 91:4 94:3

95:12 96:8 99:15

100:10 103:19 104:9

105:6 107:11 110:2,7

110:10 113:20 114:18

116:9 117:5,10

120:13 121:8 122:19

123:6 126:7 127:16

129:4 132:21 134:6

137:13 138:3,15

139:13 140:7 142:16

145:18,20 146:1

149:7 150:18 151:21

153:5 156:4 157:18

160:2 163:14,18

165:3 167:6 168:15

168:18 170:8,11,20

170:22 174:8 175:17

178:17 179:6,8 180:3

183:7 186:7,20

189:13,20 192:15

193:6 196:9 197:16

198:16 201:20 202:1

202:11 204:19,20

205:7 208:17 210:5

211:15,19,22 213:14

214:11,13 215:3,5

218:22 224:20 227:15

229:10 232:13,18

236:10 238:3,6

239:18 240:11,19

243:13 244:9 245:5

246:1,4 249:12,15

250:18 252:14 253:22

254:3 257:1,17,20

261:8 264:17 268:3

268:12,19,21 274:3

277:1,4,8,15,17 301:3

303:14 325:19 329:2

329:19 330:2,14

331:5,8,20,22 332:17

332:17,22 334:3,3

340:7 341:7,7 342:13

342:18,19 343:10

346:16,22 347:9,17

348:6,12,16 349:4

350:2 351:11,18,21

352:1,3,6 353:5,5

360:8,11 361:10,10

361:13,16,19 363:22

364:3 365:4,7,9,9

377:21 379:13 382:16

385:17 386:6 405:18

406:4 413:2,5 418:1

418:11,14 419:13,13

426:17 441:12,14

443:10

chaired 88:7 258:16

Chairman 91:10

Chairperson 1:11 278:3

413:7

challenge 13:12 76:4

131:14 357:19 425:3

challenges 13:16 18:11

25:3 59:12,13,18

60:14 64:11 102:1

142:15 188:4 190:13

192:12 248:12

challenging 54:3

163:12 256:19 305:1

424:7 425:3,18
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

452

chamber 49:5,10

chambers 48:6

champion 108:11

chance 38:4,10 61:9

107:20 175:8 375:14

change 4:13 6:17 35:21

77:5 89:9,20 111:1,8

114:14 154:12 161:6

166:3,10 168:13

180:16 195:18 206:5

213:13 259:20 260:19

263:21 349:18 412:1

412:7,11,18 441:6

changed 71:14 137:21

150:3 203:15 204:4,5

changes 54:6 101:4

171:19 173:18 308:19

345:10

changing 142:9 298:4

channel 96:19 279:15

channels 255:2

Chapman 1:11,13 6:3

9:16,22 10:4,7,10

14:8,12 15:11 16:2

17:7,9 21:6,15 22:21

24:13 25:18 29:11

30:12 31:10 32:5,11

32:22 33:5 34:1 36:20

37:1,18 41:1 43:16

45:10 46:22 51:5,11

51:13 54:18 55:17

56:4,10 57:12 60:22

61:5,8 64:15,17 66:1

66:18 67:18 69:3,6

73:17 74:9 77:15 78:3

79:10,13 82:2 84:7,10

85:12 87:20 91:4 94:3

95:12 96:8 99:15

100:10 103:19 104:9

105:6 107:11 110:2,7

110:10 113:20 114:18

116:9 117:5,10

120:13 121:8 122:19

123:6 126:7 127:16

129:4 132:21 134:6

137:13 138:3,15

139:13 140:7 142:16

145:18,20 146:1

149:7 150:18 151:21

153:5 156:4 157:18

160:2 163:14,18

165:3 167:6 168:15

168:18 170:8,11,20

170:22 174:8 175:17

178:17 179:6,8 183:7

186:7,20 189:13,20

192:15 193:6 196:9

197:16 198:16 201:20

202:1,11 204:20

205:7 208:17 210:5

211:15,19,22 213:14

214:11,13 215:3,5

218:22 224:20 227:15

229:10 232:13,18

236:10 238:3,6

239:18 240:11,19

243:13 244:9 245:5

246:1,4 249:12,15

250:18 252:14 253:22

254:3 257:1,17,20

261:8 264:17 267:22

268:3,12,19,21 273:1

273:3 274:3 277:1,4,8

277:15,17 282:3

290:17 292:18 295:9

296:1 298:18 300:2,5

301:3 303:14 304:2

305:4 307:16 313:22

317:7 319:12,20

321:22 322:10,12

325:19 329:2,19

330:2,14 331:5,8,20

331:22 332:17,22

334:3 340:7 341:7

342:13,18 343:10

346:16,22 347:9,17

348:6,12,16 349:4

350:2 351:11,18,21

352:1,3,6 353:5 360:8

360:11 361:10,13,16

361:19 363:22 364:3

365:4,9 377:21

379:13 382:16 385:17

386:6 405:18 406:4

413:2,5 418:1,11,14

419:13 426:17 441:14

443:10

Chapman's 24:5

chapter 428:11

chapters 18:13

character 7:13

characteristics 35:4

characterized 318:18

charge 322:7

charged 247:13

chart 362:7,14,19,21

cheaper 133:11

check 33:21 348:4

cheese 293:21 296:17

297:1,16,21 299:13

299:17,22 300:5,6

cheeses 299:16,22

chemical 36:4 86:6

381:11

chemical-free 27:4,13

27:22

chemically 43:10 264:6

chemicals 197:12

243:4 301:11

chemistry 213:20

258:11 381:12

Cherokee 430:7

chewing 311:14

Chiapas 70:22

chickens 109:18 118:1

chicory 267:18

chiefly 196:6

child 438:7,8

children 14:3 275:20

Chile 86:5 206:1 208:22

211:10

chlorhexidine 5:4

387:2 388:14,17,17

389:2,13 390:9,13

chloride 4:8 289:2,4,10

290:11 301:12 362:17

362:18 363:12

chlorine 4:7,8 5:3,3

287:9,12,14,18,21

288:3 386:17 387:1,4

387:7,10,12,15,18,18

388:1,3,12

chlorite 4:6 285:14,18

286:2

choice 59:2,3 60:7

151:17

choices 60:8 81:13

choose 96:2 201:17

219:14 229:3 262:1

275:14 380:14

choosing 149:21

159:17 313:19

chord 420:10

chunk 432:10

circulated 383:19

circumstances 248:14

251:12 436:6

circumvent 36:3

citation 155:5

cite 132:14

cited 64:3 124:21

234:15 298:20 313:11

citing 155:12 312:21

313:13 356:5

citizen 117:15,17

120:17 274:6

citrate 297:2,16

citric 285:20

citrus 304:10 317:12

318:11 319:16 320:2

city 148:19

claims 34:21 93:18

272:16,19 313:1

clamshell 244:7

Clarence 3:12 17:19,20

25:19,21 26:1 34:1

clarification 113:5

136:11 163:3 171:22

180:21 183:4 187:8

250:12 285:7 319:9

328:10 412:10,16

clarified 184:20 188:22

393:14

clarifies 172:4 324:14

416:18

clarify 41:6 54:21 55:15

77:9 91:17 92:13,17

192:9 196:1 213:5

217:7 222:20 228:3

290:20 325:15 331:18

349:7 354:3 357:5

clarifying 5:8 171:17

180:11 246:14 300:2

337:22 374:13 406:10

411:6

clarity 7:9 231:21 297:8

353:17

class 75:7 92:12 354:1

355:6 443:18

classes 95:3

classic 276:9

classification 258:17

289:15 328:7 331:1,2

331:19,20 340:6

359:5

classifications 156:15

216:17 329:10

classified 216:20

282:17 292:10 329:9

354:4 440:17

classify 331:3,11 332:1

340:8,14

clay 279:14 280:22

281:2

clean 144:7,8,12 284:16

363:4 390:10

cleaner 12:2

cleansing 389:3

clear 7:17 34:9 55:2

98:19 103:9 122:10

129:1 130:3 132:18

136:15 170:3 192:7

216:16 217:20 233:20

234:3 236:14 244:10

245:20 260:16 263:9

320:6 328:15 356:12

356:21 358:14 367:11

404:12 412:3 416:14

clearer 394:6

clearly 28:7 37:10

55:22 101:7 108:10

137:4
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

453

clears 88:11

click 8:4

client 280:13

clients 104:19 132:8

188:19 280:9 281:20

climate 151:8,14 206:5

250:4

climates 149:1 389:18

climatic 43:19

climax 440:3

close 113:14 141:20

171:12 316:16

closely 52:7 93:15

closer 161:19 207:12

275:10 297:14

closing 384:11

cloth 225:3,4,7

co- 258:15

co-lead 295:8

co-manufacturer

372:21

CO2 39:5 40:5,13,15,17

42:19 47:5 48:10

coagulant 289:10

290:12

coal 84:17 114:4,11,16

Coalition 2:10,11 18:14

21:18 69:13 96:14

143:2

coast 241:6

coating 130:2 137:8

coatings 335:17

coco 144:16 209:12,18

215:15 221:7,22

231:18

coconut 144:17 207:11

code 269:21,22

coded 329:9

codifies 109:6

codify 77:4 248:17

coefficient 239:14

coincidental 276:8

coir 144:16 207:11

209:12,18 221:8,22

231:18

cold 389:20

Coleman's 26:19

collagen 301:8 302:22

302:22

colleagues 139:10

185:13

collect 48:22 157:2

366:12

collected 138:9

collecting 48:5 439:6

colonized 215:15

Colorado 1:10 18:8

169:6 170:2 430:16

colors 90:20 279:20

comb 157:1

combination 237:6,20

268:13 403:6

come 6:5,19 8:8 10:12

23:3 25:21 29:5 114:5

129:9 131:17 133:10

140:8,13 149:11

151:3 177:15 179:18

185:21 187:6 219:5,6

226:3 254:7 255:21

275:10 297:6 301:13

307:14 321:1 382:5

384:16 406:20 426:9

comes 40:12 43:12

68:12 85:4 120:3,5,7

124:5 136:19 137:10

167:16 306:4 309:13

321:9 331:1,10 333:4

340:11 377:22 433:21

comfortable 144:12

229:4,15 349:16

442:5

coming 9:18 14:20 15:2

39:3,22 61:14 95:8

100:5 127:13 131:12

138:14 145:5 160:18

167:11 192:19 210:19

227:1,4,5 255:6

292:22 339:20 385:12

432:13 439:20

comment 6:6,10,11,13

7:7 14:19 15:1 16:4

37:2 42:11 44:10 52:3

64:20 77:10 91:19

110:18,22 112:14,21

116:11 160:14,19

163:21 165:9 169:11

171:16 172:12 186:10

202:5 215:10 221:18

229:14 232:14 233:3

234:18 261:1 265:15

267:6 284:13 285:3

287:4 289:19 290:1

290:22 291:19 292:11

293:18 296:2 299:4

301:19,21 302:11

312:1,4 313:15 315:9

317:21 318:9 325:7

337:1,11 339:7

343:15,21 344:15

353:14,19,20 355:2

357:10 359:1 362:10

362:16 363:7 373:3

390:21 392:18,21

393:8,9 396:14 397:1

401:2 405:6 407:15

409:21 410:3,12

411:21 413:14 414:10

420:12 422:19,20

426:18 431:16,19

commentaries 178:20

commented 52:12

344:22

commenter 202:2

285:4 313:3 328:17

355:17 356:1 388:3,8

400:5

commenters 7:11

94:18 293:19 294:4

313:11 320:12 345:4

345:14 354:12,16,19

355:5,10,21 356:7

368:8 401:4

commenting 110:20

265:5

comments 4:2 12:16

25:8,14 52:2 61:3,16

73:15 78:6,18 79:8

80:1,6,7,8,19 84:13

84:16 92:21 93:4

96:13,17 97:3,10 99:2

106:2 115:1 117:6

120:17 121:4 126:1

137:2 156:7 160:12

179:3 180:6,8,22

183:16,21 186:14,14

187:13 192:11 206:15

208:8 210:13 241:3

246:2 249:4 252:8

259:5 260:4 277:10

277:12,18 280:7,10

281:12,16 282:21,21

282:22 283:20 286:3

286:7 288:8 290:17

290:20 291:20,22

292:13 298:7 301:15

301:17 302:12 303:8

305:16 306:1,2

312:14 313:6,7 315:1

317:17 318:3,21

319:3,13 321:10

325:3 326:13 337:13

344:18,18 345:22

346:20 350:6 354:11

363:8 368:6,11

369:12,14 372:6

373:5 374:19 388:12

396:16,20 398:1

402:5,8 403:3 420:10

422:7,11

commercial 34:10 36:6

37:11 72:14 75:18

89:10 91:1 93:5,9

112:12 233:16 260:1

308:1 360:3 434:20

commercializing 318:5

commercially 76:2

90:22 111:5 259:11

300:19 311:17

commingled 318:6

commingling 368:20

376:17,21 378:1

commission 397:18

commitment 58:7

189:10,11 241:7

committee 58:10 79:8

86:21 88:7 91:21

92:10 149:4 154:10

254:16 256:11 289:6

295:18 366:10 375:14

397:18 400:7 412:20

Committee's 97:18

committees 288:20

common 2:19 183:12

190:21 229:3 317:9

405:9

commonly 79:6 93:1

134:13 291:14 355:8

393:10

communicate 155:14

194:2

communication 170:4

255:2

communicators 255:13

communities 72:5 86:8

424:22 436:21 437:9

437:13

community 54:9 95:17

99:3 103:12 106:20

141:9 190:16 202:20

204:5 241:8 295:3

303:10,11 314:4

344:18 350:6,20

367:4 374:22 411:12

429:2 433:13

compaction 231:11

companies 79:18 89:13

90:17 122:1 203:20

211:11 305:8,17

315:14 381:12

companion 111:7

company 61:21 62:2,8

91:12 95:20 121:2

123:2 169:2 206:2

244:4,4 265:6,9 266:6

308:4,5 329:21 338:4

372:21

comparatively 68:16

compared 228:5 378:22

comparison 272:14

compassionate 143:13

compatibility 325:9

competence 184:10
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

454

competency 255:19

256:5

competitors 237:22

compilation 383:10

complaints 64:5 139:4

139:7

complete 44:9 112:17

323:17,20 329:6

404:17

completed 154:3 293:9

completely 31:22 38:21

39:4,13 43:8 44:13

55:19 132:16 276:8

completeness 63:11

complex 37:6,8 39:20

166:8 279:16

complexity 166:11

compliance 5:11 139:4

153:21 159:14 181:1

395:8 413:6

compliant 154:22 181:8

complicated 66:17

184:13 351:9

complicates 177:22

comply 125:10 126:11

126:12,17 168:3,6

414:17

component 155:18

209:20 214:5 221:12

229:18 291:16

components 216:3,20

238:15 239:7

composed 146:20

280:22

composition 215:17

217:13 266:15,20

compost 24:5 36:15

131:19 135:2,10

144:19 145:3,7

146:21 174:3 177:6

177:18 207:11 208:15

209:12,20,22 210:2,3

217:6 218:12 221:8,9

221:12,19,22 222:6,7

222:13 223:2,7 229:8

229:13 230:7,8,11

231:2,17,18,18,22

compost-used 27:19

compostable 212:18

213:10 233:6

composted 222:1,1

composters 20:3 23:8

composting 24:12

233:7

composts 220:10

231:15

compounds 371:20

372:1 376:3 379:3

403:16

comprehensive 108:15

260:11 263:17 286:8

288:9 388:9

comprehensively 7:18

comprise 369:5

comprised 96:14

282:13

compromise 90:15

209:13 221:13 236:8

271:7

compromises 369:10

378:11,16

computer 392:1

con 390:21 392:18

conceive 274:14

concentrate 327:20

concentrated 284:21

concentration 46:3

concentrations 46:17

concept 57:7 71:18

76:13 86:21 146:9

180:14

concern 114:3 136:4

147:8 148:18 163:4,8

167:10 197:21 298:18

311:10 319:10,12

328:1,2 339:21 359:1

362:16 369:18 379:18

380:16,20,22 381:3

406:21 426:20 437:3

concerned 79:5 84:17

117:15,17 119:12

180:15 298:13 368:3

concerning 225:15

concerns 43:17 53:7

78:7,14 79:3 103:13

163:6,9 175:9 181:9

188:18 281:18 283:1

294:10 313:8,11

314:14 315:4 326:16

345:18 355:15 368:8

369:11,15 373:19

392:7

concludes 277:18

322:15 385:15 406:9

conclusion 60:10

130:13

concrete 314:16

condition 207:5 250:4

conditions 43:20 44:14

144:10 196:6 235:3

247:2 269:14 414:18

415:7 425:10

conduct 415:17

conducted 74:17

184:22 185:3 388:19

conducting 416:8

conference 256:9

conferences 141:10

433:6

confidently 147:2

confirming 212:11

conflicts 278:5,8

confused 25:16 243:7

346:7

confusing 402:15

confusion 54:22 212:16

217:5 344:11,22

congratulate 123:11

congratulations 443:14

connect 415:10

consensus 314:1

consequence 421:22

consequences 80:14

81:19 98:18 118:9

427:7

Conservancy 422:10

conservation 147:7

190:5 241:8 263:14

420:14 422:4 439:5

conserve 64:6

conserves 262:21

consider 22:3 53:12

58:3 64:8 65:21 86:21

93:22 98:16 99:6

106:21 112:2 116:18

117:7 118:7 119:15

129:19,21 137:7

142:4 148:7 150:6

158:12,15 161:13

162:14 190:17 241:11

243:20 244:2 370:17

consideration 103:16

163:1 194:16 200:6

201:4 243:12 300:22

313:17 346:4 347:4

347:20 356:10

considered 96:22 101:2

136:18 137:6 141:16

158:4 221:19 230:11

250:6 271:2 293:22

293:22 327:10 336:17

356:13 393:4

considering 23:16

152:14 158:11 176:17

234:7 299:8 306:12

consistency 54:13

130:6 162:18 188:14

251:18 312:22

consistent 37:5 53:15

71:19 155:11 182:7

248:1 356:21 357:6

consistently 137:12

167:19 172:2 187:21

247:4

consists 39:12

consolation 73:6

consolidate 307:4

consolidated 383:16

consortium 307:19

constantly 32:16

constitute 252:4

constitutes 182:6 183:1

187:9

constraining 314:13

constraints 309:12

318:5 320:10,21

consultant 26:3 206:1

254:10

consulted 86:14

consulting 183:14

consume 119:11

consumed 67:22

380:19

consumer 14:1 27:8,9

27:12 34:6 140:12

148:21 188:16 193:19

194:3,21 195:9 196:3

196:5 197:5,8,10

201:7 245:18 267:2

consumer's 201:3

263:14

consumers 2:21 24:20

25:3,15 27:3 28:22

58:12 59:1,3 62:7

63:20 64:6 70:17 71:7

73:4 119:4 133:14,15

169:16 170:6 189:8

194:17 195:2,4

196:20,21 198:8

199:15 204:13 242:16

243:3,9 245:19

261:13,22 266:11

371:3,12 422:17

consumers' 194:5

consuming 297:1

311:13

consumption 298:15

contact 232:16 260:21

285:19 287:14 368:20

369:4 376:17,22

378:10 379:20 380:18

381:19,21 382:8,8,11

382:17 383:3,3,8

384:1

contacts 368:16

contain 156:9 182:10

216:20 369:2 377:4

377:18

contained 336:13

380:13

container 19:18 20:5,11

23:11,13 70:5 86:10
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

455

86:17,22 98:5,19 99:1

101:12 117:20 118:5

118:14,16 122:10

123:5 130:11 131:7

131:15 133:2 134:11

136:1 146:9 149:14

152:3 164:1 173:21

177:1,2 195:3,6,8,11

195:13 215:11,20

216:5,6 218:1,3,8,18

218:19 219:6 220:1

223:3 224:6,7,17

225:17 226:17 227:18

228:3 229:1,9 231:4

242:1 244:12,18

369:4 378:10

container- 59:17

container-grown

122:11 128:12 130:14

132:6 133:12

containerized 26:6

195:15,19,21

containers 97:19 99:9

101:15 124:14 126:2

127:20,22 128:7,8,11

128:19,22 148:13

152:10 176:9 209:3

209:14,20 221:9,12

224:12 225:3 227:2

228:9 377:3

containing 36:4,7

366:16

contains 124:6 384:6

contaminate 37:17

contaminated 37:3

63:18 380:15,22

contaminating 36:7

contamination 63:14

206:6 260:9 369:9

373:13

contemplated 72:14

content 50:4 57:7

107:18 125:2 127:14

173:10 174:17 212:16

213:3,6,10 299:1

contentious 70:8

contents 4:1 5:1 30:1

298:22

contests 184:6

context 101:21 106:9

107:7 120:16 178:19

178:22 182:16,21

206:3 207:1 260:12

296:11

continual 216:7

continually 184:13

continuation 26:4

continue 6:6 9:1 14:10

28:8 53:1 59:10 65:7

87:14 89:19 92:20,21

93:22 99:7 103:10

108:4 129:2 133:5

160:22 189:16 191:7

254:13 284:1 285:12

287:7 363:5 370:13

401:2 412:12 429:3

continued 8:19 11:1

26:18 86:9 101:19

197:8 285:4 289:14

291:19 305:18 397:4

continues 11:5 336:20

continuing 195:3,15

254:18 255:18,22

256:1,21 282:8 283:9

284:5 285:15 286:17

287:11 289:3 291:21

317:3 388:16 390:16

391:17 395:3 400:12

continuous 20:22 21:4

60:11 76:14 77:4

80:20 83:1,19 97:19

180:14,17 190:9

221:14 259:12,22

381:9,13

continuously 14:1

265:17

continuum 209:13

contract 52:14 254:9

306:19

contracted 54:16 57:5

309:4

contractor 154:1

256:17

contractors 52:18

415:11

contradicted 367:21

contradictory 137:5

184:15 276:10

contrary 187:15

contribute 102:15

contributed 103:17

contributes 72:7

102:10 144:22

control 13:21 97:11,15

108:10 161:20 165:7

179:2 207:5 242:9

247:10 250:2 287:2

397:15 435:22 436:1

controlled 48:7 118:19

144:10

controlling 218:6 389:5

controls 242:4

controversial 21:9

440:19

controversy 324:3

convene 261:2

convenient 304:16

conventional 19:14

62:4 119:18 124:14

129:11,12 130:13,21

131:1,2,2 133:20

135:15 208:21 313:13

313:16 316:15 318:14

319:15,17 322:2

330:8 338:18,22

345:6,8 422:2 431:3,4

435:22

conventionally 108:8

316:18

conversation 194:2

245:2 262:14 264:11

296:10 363:5 373:10

404:1 423:18 436:9

436:19 438:18 442:3

conversations 437:21

conversion 40:17 51:22

102:2 190:2 191:7,16

192:17 356:5 421:9

426:3 427:14 437:12

441:5

convert 5:17 42:19

356:3 419:18 424:2

converted 43:8 169:5

263:5 424:9,13

converter 200:15

converting 264:5,8

convey 7:19

convince 178:6

Coody 2:11 91:7 96:9

96:12,12 99:19,22

100:3

cook 68:12

cool 434:11 435:2

coop 22:9

cooperative 22:17

393:11

coordinated 247:22

copies 65:4 337:8

copped 406:6

copper 5:6 116:20

117:2 397:6,11,13

398:9,17,17,19 399:2

399:6,11

copper-based 97:11,14

113:17

coppers 25:10 113:8

116:11,12,14 399:12

cores 317:11 320:19

Cori 3:8 183:9 186:21

187:1

corn 115:2,9 151:3

Cornucopia 2:14 18:1

18:17 25:2

correct 41:8,14 61:10

65:17 67:5,7 94:5

106:4 155:21 331:8

331:21 409:8

correcting 83:14

correctly 404:1

correlation 318:22

corresponds 362:20

corrosive 388:6

corticosteroids 391:7

cost 12:5 63:15

cost- 63:19

cost-effective 51:3

Costco 122:1,3

costs 12:13 13:17

cotton 272:2 337:14,16

counter 242:20

counterfeiters 271:22

counterfeiting 271:15

271:18

counterparts 118:15

countries 84:4 151:11

316:9

country 64:3 170:3

248:14 264:13 381:10

couple 16:19 23:1 47:2

291:22 318:20 325:20

329:2 372:19 384:2

415:3 433:1 438:15

coupled 109:7 267:6

course 29:18 32:16,18

39:6 43:20 44:11,17

45:8 68:13 115:2

131:18 143:22 165:16

226:16 242:21 256:7

256:8 339:6 402:14

406:19 410:17 434:8

Court 1:10

cover 12:8 16:5 17:3

20:4 24:6 56:19

covered 82:14 138:1

187:14

cow 391:5 394:18

cow's 266:13

cows 392:6 394:12

coyotes 431:12

crafted 409:14

crafting 109:8

crazy 178:11

cream 284:12,12

291:15

create 18:20 65:3 76:4

119:1 141:17 214:17

337:8 378:2 423:19

425:21 435:16 436:4

437:7

created 9:7 11:11

279:16 280:1 362:14

427:12
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

456

creates 174:4 279:18

creating 14:3 30:18

69:21 129:1 147:18

148:15 173:8 267:3

434:17 438:2

creative 101:22

creativity 60:16 81:16

creatures 430:9

credentialing 53:3

criteria 81:10 85:10

92:18 93:3 155:7,12

155:18 158:12 185:21

198:10 199:14,16,18

212:11 256:4 263:19

312:3 325:9 442:16

criterion 52:16

critical 216:5 281:13

286:5 304:8,14

306:22 310:6 320:17

358:10 379:10 402:3

433:1

critically 263:1,9

405:13

criticized 274:22

crop 5:17 13:10 17:3

23:5,22 24:10 82:13

92:1 94:14 97:7,18

99:11 104:21 112:22

113:8 126:12,16,22

127:1 137:9 154:11

156:1 164:3 180:8

181:5 218:14,21

221:2 222:9 226:17

235:6 263:6 354:10

355:18 357:9 373:11

419:18 421:5 430:14

430:18

crop's 131:12,17

CROPP 393:11

cropped 429:11

croppers 20:4

cropping 92:9

crops 12:8 13:13 15:14

16:5 24:6,9,17,17

30:15 35:9 74:18

91:21 97:12 99:8

100:17 101:15 113:11

124:1,8,11 126:2,21

128:10 138:13 145:8

176:15 216:11 217:2

223:19 224:16 235:1

357:13 399:7 434:22

cross 186:2 353:20

crucial 16:22

Cruelty 107:20

Cruse 187:10

crust 59:8 147:5 243:6

crux 201:12

crystallization 284:22

CSA 18:7 197:19

cucumber 119:21 120:6

cucumbers 121:17,18

Cufone 61:11 69:11

70:7

cultivated 426:4

cultivation 13:11 127:7

424:6 425:2 435:20

cultural 407:19

culture 45:4 299:16

313:12

cumulative 294:10,20

298:8

cup 379:3 390:9

curd 310:22

curious 78:4 84:20

95:14 105:10,11

116:11 122:6 134:8

176:3 200:2 239:19

255:12 257:3 273:12

304:13 403:10

current 64:21 113:16

141:19 168:11 172:18

179:10 207:1 209:17

217:10 266:8 291:20

298:3 309:4 319:3

335:5 367:18 383:7,9

384:6,10

currently 36:16 47:9

69:15 85:3 92:5 104:7

104:11,13 106:17

107:1 114:11,12

123:1,2,16 154:14

157:3 171:11 173:6

182:2 212:22 220:4

222:4 224:12,15

260:7 266:20 293:16

299:6 309:20 335:21

337:16 349:21 354:14

362:3 388:7 394:3

424:13 426:4

custody 67:11

customer 152:18

customers 48:18

242:15 245:8 373:2

cut 40:3,10 42:15 129:6

151:22 167:7 228:7

243:21 244:4,6 360:2

409:13 427:8

cute 275:8

cuts 81:18

cutting 72:5

cycle 19:20 59:21

145:15 269:18 293:10

cycled 31:12

cycles 206:18 210:8

261:19

cycling 26:8 99:13

262:19

D

Dae 210:6

dairy 284:11 293:7,16

296:20 299:6,9,12

391:2,6 392:6 395:19

396:12 397:16,21

400:17 401:18 403:12

403:14,16 404:19

dam 392:13

damage 226:21

damaged 162:6

Dan 1:19 14:13 15:11

64:18 66:2,18,20

114:18 129:5 132:21

134:6 273:4 302:13

346:6 395:21 403:20

dance 24:15

dangerous 71:12

Danone 2:18 264:22

265:12

dart 229:21

data 100:7 118:7

119:15 121:22 122:2

Database 305:14 314:6

317:22

date 258:22 274:9

372:6 411:16

dated 323:10 418:10

daughter 329:5

daunting 260:15

Dave 1:16 14:13 16:2

24:5 42:6 95:13

150:18 191:20,22

238:3 239:18 304:5

358:8 360:17 378:18

403:8 429:7 431:22

438:16

David 2:15,16 87:22

91:6,7,8,11 189:15

193:7,9 359:12

day 6:4 51:8 218:15

272:12 275:6 277:12

296:17 308:1,6

days 54:2 198:14

395:16,18 396:9,11

400:15,16 401:16,17

403:12 404:19,19

406:17 407:2 434:8

dba 265:6

de 1:15 2:12 45:12

64:19 65:18 90:16

142:18 146:5,6

149:17 151:6,20

152:5,7 278:3,11

279:12 280:14,20

281:22 282:3,4 283:6

283:12 284:8 285:22

286:12,20 287:20

288:13,22 289:9

290:19 291:12 292:16

293:2,14 295:7,14

296:13 298:5,17

299:10 300:4,8 301:2

302:13 303:13 304:5

304:19 306:8 307:15

309:7 310:8,14

313:20 314:17 315:7

315:19 316:20 317:6

318:15 319:7 320:8

321:5,21 322:13,21

323:14 325:18 328:4

328:12 330:3,13,19

331:7,21 332:3,8,18

333:11 334:5 335:1

338:1,12 339:5 340:1

340:4,10 341:6,13

342:11,22 343:7,9

346:6 347:5,16

349:10 351:10,14,22

352:2,5 353:2,8 358:5

358:8,18 360:4 361:6

361:11,15,17,22

363:15,18 364:21

365:8,11,16 370:20

372:10,16 376:14

377:20 378:18 379:12

380:6 381:1,18

382:14 384:11 385:10

410:2,11 419:7

de- 118:10 405:21

de-certified 120:9

DEA 169:21

dead 275:17

deadline 90:6

deal 14:4 78:9 86:12

89:17 100:3 203:5

356:15 358:14 381:17

394:13

dealing 15:15

dealt 170:18

dear 88:21 184:2

261:13

death 276:16

deaths 63:15

debeaking 108:14

decades 81:3,4

December 413:17

418:10

decide 67:10 295:19

370:16

decided 203:19 296:11

366:11

deciding 38:18
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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decision 64:14 98:4,6

197:7,13 198:11

200:4 201:9 259:11

267:4 327:10 415:11

decision- 384:14

decision-making 21:14

decisions 35:20 81:3

98:9 194:17 202:22

204:16 383:21

deck 8:6,8,9 17:20 34:2

37:20 51:15 61:10

69:7 87:22 91:7 96:10

100:11 107:15 117:11

140:8 142:19 146:2

153:7 171:1 179:9

183:8 186:21 189:15

193:7 205:18 215:6

232:20 240:20 254:4

257:21 261:10 264:19

268:22 370:18

declined 109:12

decrease 195:21 206:7

229:5 231:10

decreased 229:8

decreasing 146:17

dedication 171:14

212:5

deemed 366:11

deems 64:3

deep 190:12 192:4

347:4

deeper 142:6 164:20

194:1 402:19

deeply 57:22 58:9

266:8

defeating 164:22

defer 239:15 240:1

343:5

define 19:11 27:16

64:22 100:17 106:6

161:3 182:3 247:9

253:7 328:14 358:1

407:7 409:6 410:18

421:12 422:8,12

426:11

defined 161:11 182:15

182:15 197:13 246:21

247:7 248:2 269:9

337:4 411:10

defining 160:12 263:18

354:13 357:20 411:6

420:19 426:6

definite 367:12

definitely 55:14 166:11

247:19 362:18 363:15

371:8 376:9 380:16

definition 26:13 27:7

64:21 65:5 87:3 98:13

101:5,6,6,10 102:22

105:14 134:16 161:12

161:13,16 162:16

165:9 166:17,22

167:4 169:20 172:3

177:16 182:1,4,12

206:12 215:13 216:2

216:9,10 217:4,6

221:19 222:3,22

230:10 232:6 246:22

249:16 250:6 251:2,2

251:3 252:16,22

253:11 337:10,22

344:4 407:11 408:4

408:12 410:14 423:17

definitions 101:2

173:19 192:14 206:13

215:13 217:7,10

276:10 354:14 356:21

378:15 409:19 429:14

definitive 295:10

degradation 43:2 45:5

46:20 47:3,21 214:10

225:11

degrade 42:14 49:6

235:12

degraded 46:19 206:5

421:1

degrading 39:4 40:5

45:7 48:17

degree 343:17 356:14

Dehne 2:11 168:19

171:4,4 174:18

175:11 176:12 177:12

177:14 179:7

delay 385:5

delayed 411:16

deliberation 278:1

deliberations 58:10

78:18

deliver 27:22 148:20

delivers 52:5

delve 193:22

demand 20:10 142:1

148:11 150:21 151:4

151:12 308:10

DeMinter 2:13 153:7

160:7,8 163:20

165:21 167:13 168:17

demonstrate 93:7

151:1 234:3

demonstrated 381:5

417:9

demonstrates 432:14

densities 109:18

dentist 390:8

dentistry 390:7

Denver 1:10,10

deny 126:13,19 127:10

department 1:1 107:18

411:17 423:22 438:17

dependent 6:16

depending 48:19 70:4

98:6 182:14 220:12

226:11

depends 50:3 196:12

198:2 225:22 412:9

deposits 284:18

depressed 299:6

deprivation 108:16

depth 158:12,20 194:1

Deputy 2:5

derivatives 83:4

derived 75:14 92:7

111:3,14 112:4 114:4

114:11,15 115:1

154:17 208:14 281:1

289:5,21 290:7 292:2

293:17 310:16 344:6

344:7

describe 23:6

described 127:13

173:19

describes 254:21

description 269:8,16

desert 44:20

deserts 141:7 430:12

deserve 60:6 433:10

deserving 71:17

design 70:4 128:21

434:15

designate 125:18,20

designated 263:13

designation 13:1,3

219:10 329:16

designing 128:18

desire 54:14 172:15

despite 13:8 172:20

271:5

destroy 420:13

destroying 423:11

destruction 191:10

destructive 191:12

detail 157:9 192:12

314:16 357:13 358:12

detailed 61:2 213:22

details 80:4 199:9

detect 66:22

detection 62:1 378:21

detergents 284:15

determination 36:10

252:3

determinations 35:14

36:17

determine 112:9 123:17

153:21 172:8 174:2

182:6 217:11 304:14

412:6,14

determined 111:15

129:21 355:6 414:19

428:12

determiner 221:20

determining 112:11

350:15

deterrent 272:19

detrimental 93:19

develop 90:17 109:2,15

developed 49:14

141:16 242:15 260:10

323:7 334:19 367:3

440:21 442:17

developing 61:21 98:21

440:12

development 76:5,11

101:16 103:9,17

146:7 218:18 219:21

259:13 269:6,13,17

270:10 271:7,12

291:8 437:4,5 439:11

devices 200:16

devilish 275:11

devised 299:14

dialogue 221:14 346:5

diatomaceous 4:5

282:3,5,9,10,12,19

diatoms 282:14

die 162:5

diet 108:22

dietary 169:7 289:11

310:20 318:1

diets 325:5

difference 28:10 59:9

69:22 133:17 228:14

228:21 276:17

differences 403:11

different 24:9 30:6,7

37:13 39:8,9,12 43:19

43:19 44:15,15 45:3

48:9 50:4,5,9,10,15

74:6 86:16 131:9

138:22 141:18 145:11

147:4 165:18 166:6

176:19 196:17 208:20

209:1 218:15 219:13

227:8 228:1 230:6,7,8

234:2 237:15,20,22

248:15 250:10 256:15

276:10 288:6 306:11

307:5 325:22 336:10

344:3 348:21 350:10

374:22 380:18 415:4

differentiate 34:9 40:7

differentiates 37:10

237:21 267:19
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differentiation 52:14

166:1

differentiator 27:11

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differs 266:12

difficult 50:13,20 51:20

113:4,13 140:14

209:17 221:11 320:10

320:14

difficulty 128:9 304:8

421:7

dig 326:15

digest 427:4

digesting 239:5

digging 345:1

dilemma 164:10

diligence 163:3 164:18

dilute 338:21

diluting 49:2

DiMatteo 3:19 79:17

diminishing 439:8

dioxide 4:7,8 5:4 44:4

286:15,16,19,20

287:18 387:15 388:3

dip 388:20 389:5,13

direct 21:21 167:1

285:18 370:2 382:11

383:3

direction 25:16 98:6

161:2 216:22 259:13

directions 153:3

directly 135:22 145:8

219:20 268:18 280:7

329:21 335:10 336:1

director 2:4,11,16 3:3,8

3:9 55:8 57:19 70:6

91:11 107:18 153:10

171:7 180:1 187:1

203:12 246:9

Directors 3:6 180:4

212:4

dirt 70:2 133:20 202:14

203:2 204:14

disagreement 138:20

295:2

disallow 35:9 216:13

disallowed 122:15

133:3 379:15

disappear 68:14 274:16

disappearing 423:7

431:19

disappointed 408:13

disastrous 118:9

discard 395:18 396:10

discernment 192:3

disclaimers 372:20

disclose 243:17 329:4

disclosure 366:22

discourage 71:5

discreet 306:3

discrepancy 184:10

discuss 87:5 117:22

124:18 209:12 244:21

370:8 380:8 398:15

discussed 38:14 84:5

112:22 113:7 188:7

193:19 334:22 350:14

387:1

discussing 152:16

339:18 349:11

discussion 4:17,20 5:8

5:16,20 38:9 65:7

76:17 86:13 98:2 99:2

122:8 136:1 160:22

171:17 173:12,20

178:21 180:11 190:2

193:22 195:7 215:11

241:14 244:16 246:14

246:17 248:9 253:20

254:17 261:4 263:4

264:2 278:15 279:1

280:15 282:1 284:2

285:12 286:13 287:8

289:1 290:13 293:2

294:22 295:18 296:19

300:8 302:10 303:7

310:8 316:21 318:16

322:14 330:19 337:19

338:12 340:5 350:4

353:18 356:4 357:13

358:4 359:3 363:9

365:17,20 366:12

367:3 370:10,13,14

370:16 371:9,16

372:14,15 375:8,19

376:16 384:18 390:14

391:15 395:1 397:5

398:5 399:3 400:9

401:9 406:8,9,14

408:22 410:2,16

411:13,18 413:13

414:12 417:22 419:17

420:1,4,9 423:3 434:7

441:9,15 442:3

discussions 58:13 70:8

296:6 366:9 373:21

441:10

disease 242:9 397:16

diseases 97:12 147:17

397:21

disincentive 422:16

423:19

disincentivize 421:9

disincentivizing 51:22

disinfectant 287:16

387:8,13 390:6

disinfectants 389:8

disinfecting 287:13,22

387:11,19

disinfection 389:16

disinfestation 228:16

disintegrating 235:16

disk 16:17

disked 49:2

displace 283:13

displaced 392:14

display 242:20

disposal 13:17 399:7

dispose 399:13 400:6

disposed 399:9

dispossess 436:12

disregard 137:1

disruptor 366:18 375:3

disruptors 379:5,6

dissolve 284:19

distance 148:19

distinct 336:8

distinction 55:3,11

98:19 136:6,8 245:20

distinguishable 336:9

distinguishing 27:10

distraction 10:1

distribute 22:18 96:15

223:19

distributed 143:11

distributing 57:20

distributor 57:21

diverse 26:9 255:4

diversity 106:21 206:6

434:19 443:1

diverted 53:12

divided 368:12

Division 2:4

Dixon 2:14 17:22 18:1

21:8 22:2 23:7,21

24:2 25:7

DNA 3:4 4:12 47:17

61:17,19 62:18 63:4

63:17 64:5 65:4 67:21

68:14,15,16 269:4,5

269:15 271:10,11,21

272:18 273:17 334:6

334:12 335:1,3,6,9,13

335:16 336:6,8,13,16

336:22 337:2,9 340:8

341:11

DNA's 271:17

DNA-based 62:19

docket 107:14 211:17

229:15 232:19 240:13

350:5 370:12 409:17

409:20 429:3

docking 108:14

document 4:17 5:8,16

94:22 112:8 122:8

171:17 173:13,20

180:11 215:11 234:20

246:14,17 261:4

263:4 264:2 286:9

296:8 353:18 356:4

357:13,17 359:3

365:17 366:12 367:3

370:10,13 371:16

372:15 375:8 376:16

399:13 406:10,14

409:13 413:17 414:8

419:17 420:5,9

documentation 76:10

339:14,21

documents 160:22

187:17 192:8 354:8

383:11 415:20

dog 276:20

doing 22:19 33:10

46:15 47:9 48:5,11

56:1 81:18 117:1

126:12 135:21 145:10

149:20 164:18 185:12

192:3 210:1 226:22

228:7,9 246:19 257:8

257:15 276:4,14

297:6,17 306:12

332:19 350:21,21,22

400:18 408:7 409:6

411:4 416:5,11,13,16

416:21 417:19 433:19

434:4 435:4 439:6

doled 308:8

dollars 58:20 196:22

203:13

domain 90:15

domestic 169:16,18

door 141:20 327:16

330:5 379:19

double 348:4

doubt 53:9

Downtown 1:10

dozen 90:19 305:22

dozens 90:6

Dr 8:7 15:12 66:21

77:17,22 114:19

115:8,15,18,19

127:18 132:22 146:6

152:1,6 219:2,16

220:14 234:10 239:15

240:2 273:5 274:2

278:18,20 280:16,17

282:2,6 283:8,9 284:4

284:5 285:14,15

286:16,17 287:9,11

289:2,3 291:3,4 293:4

293:5 299:11 300:9
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342:9 343:1,2,8 346:7

346:19 352:17,22

357:16 358:20 359:4

360:21 361:4 364:14

364:19 375:12 383:5

383:6,14 386:16,18

387:6 388:14,15

390:15,16 391:16,17

395:2,3,20,22 397:6,7

399:17 400:10,11

401:10,11 402:6

403:21 404:9,15

418:22 419:5

draft 358:11,12,13

372:1 375:20 378:20

drafters 107:3

draining 192:20

draw 93:14 244:17

431:5

drawing 174:1 191:13

191:15

dress 231:13

dressing 220:10 223:21

drew 404:16

dried 335:19

Drinking 287:17 387:14

drip 16:18

Driscoll 219:3 225:1

Driscoll's 2:19 215:9

216:11 219:11,16,19

224:4 229:14

Driscolls 34:15

drive 19:6

driven 84:4 222:16

driver 221:20

drivers 215:18

drop 63:1

drought 262:8

drug 395:6,9

drugs 247:13

dry 296:17 297:16

394:12

drying 280:2 281:8

289:21

due 13:16 99:5 163:2

164:18 243:3 250:3

266:22 267:16 279:15

280:10 318:5 355:14

dumped 31:17

dung 246:19

duped 71:9

duration 400:21 401:21

duties 415:14

dwellings 148:6

dwindling 262:10

dying 253:4

dynamics 216:15

432:19

E

eagles 431:9

ear 143:3

earlier 61:3 138:18

149:12 187:16 236:15

238:8 245:17 249:4

252:8 273:6 278:6

291:10 301:19 359:13

365:21

early 6:19 191:21 366:3

441:16

ears 192:1

earth 4:5 59:8 71:22

118:4 143:16,22

147:6 282:3,5,9,10,19

430:8 431:19

Earth's 243:6

Earthbound 34:15

earthworm 81:7

earthworms 80:19

81:21 149:13

ease 392:12

easements 438:18

easier 14:5,7 142:3

304:21 425:7

easily 72:11 217:9

308:7

easy 176:10 177:9

178:15 202:22 203:7

eat 191:13 239:4 275:22

311:6

eating 15:6,8 302:3,5

378:22

echo 197:17 315:1

316:1 349:8 357:14

358:19 403:1

eco 225:1 264:9

eco-based 13:6

ecological 30:15

102:13 206:18 210:9

261:16 262:16,20

263:3 355:15

ecologically 147:19

191:5

ecology 207:3

economic 13:22 58:21

102:11 133:2 221:1

305:9 306:4 322:6

economically 65:12

191:5 303:17

economy 189:8

ecosystem 76:16 85:11

93:12 206:17 262:7

426:12 428:21 429:13

433:14 435:14,15,15

ecosystems 5:17 52:1

102:3 190:3,20

192:17 262:12,14

264:4,11,15 356:3

419:18 423:10,18

440:3

ecotox 46:18

ecotoxicological 40:21

43:1

Ed 2:22 160:4,5 168:18

168:19,20,22

edge 102:6

edible 62:19 242:19

educate 25:2,10

education 187:9 254:18

255:18,22 256:1,21

258:9,10 433:11,12

435:3

educational 154:4

Edwards 2:14 139:20

246:5 254:6,7 257:5

257:19

effect 40:22 80:9 87:5

298:8,10 399:2 424:1

effected 158:2

effective 63:20 305:11

306:3 385:9 398:3

411:16,20

effectively 339:11

373:18

effectiveness 388:22

effects 45:14 46:21

98:16 175:10 208:4

294:11 395:14 396:1

396:6

efficiency 257:14

effort 92:13 93:21

110:20 357:5

efforts 91:16 92:16

194:22 230:5 265:16

266:14

egg 291:17

eggs 19:3

eight 9:3 11:7 23:14

150:1 266:19 393:16

395:16 396:9 404:19

either 93:11 112:5

150:12 152:17,18

208:4 231:20 240:12

252:10 253:3 335:11

355:13 377:7,12

404:2 412:15

ELA 1:16 43:17 78:4

105:7 106:11 116:10

122:6,14 129:9

130:17 149:9 175:18

177:4,13 199:21

200:10 229:11 232:1

244:10,15 291:13

292:20 315:8 318:17

321:6 332:6 333:14

338:14 340:17 341:22

352:13 361:9 365:2

399:5 419:10

elaborate 21:22 24:10

25:15 94:8 120:21

357:11,12

Elan 88:4

elastic 50:19,22

electronic 257:13

elegant 178:1

elements 31:6 32:21

106:22 269:21 270:9

elephant 310:16

elevates 399:9

elevator 68:2

eleven 139:18

eligible 73:12 154:14

263:22

eliminating 5:16 190:2

356:2 419:17

Eliot 26:19

else's 12:15 15:9

email 232:15 268:18

383:20

emails 183:18

embrace 160:16

embryos 270:20

emergencies 162:17

248:9 249:7

emergency 5:8 160:12

161:3,11,19 162:2,4

162:16 165:5,9,15

166:8,18 167:1,5

171:18 172:1,4

180:12 182:1,7,10,12

182:15,20 183:1

246:15,21 247:1,3,7,9

247:19 248:2,20

250:2,5 251:4 252:4

393:6 394:1 406:10

407:7,11 408:4,16

410:19 411:18,19

Emily 1:17 21:16 30:12

31:10 94:3 103:20

120:13 122:19 156:5

156:5,13 174:9

197:16 208:18 219:1

229:12 288:13 294:22

295:15,15 313:21

314:17 328:8 357:8

358:18 360:12 370:21

372:10 380:5,6
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435:6

emphasized 97:10

emphatic 368:13

employees 52:17 243:3

415:10

employees' 144:3

employer 55:8

employing 193:10

empower 192:9

emulate 190:19

emulsifier 293:21

297:21

emulsion 20:4 23:14

24:22 82:21

emulsions 83:3

enable 63:17

enact 221:15 238:21

encapsulated 335:19

enclosures 148:1

encompass 253:13

encompasses 268:6

encountered 272:15

encourage 7:8 20:19

54:8 70:19 103:15

114:13 141:18 160:15

160:17,20 173:4,20

217:19 234:22 292:1

319:2 343:13 401:6

412:12 421:22 429:2

encouraged 74:8

encouragement 54:7

encourages 112:1

encouraging 71:3

114:8 306:18 343:19

endangered 429:12

ended 165:19 438:8

endocrine 366:18 375:2

379:4,6

ends 12:12 31:13,15

218:4

enemy 173:11 175:16

179:4

energy 21:3 53:13 72:3

356:16

enforce 217:11

enforceable 168:4

192:8

enforced 19:2 133:11

167:9 180:19

enforcement 139:4

168:5 188:14 192:10

192:12

enforcing 172:2

engage 70:19

engaged 230:4 337:16

engagement 356:11

443:17

Engel 191:20

engender 53:10

engineering 271:2

enhances 146:13

261:17

enhancing 262:3 263:2

enjoy 62:14 242:20

243:11

enlighten 296:6

enormous 76:9

enquiries 103:10 104:5

enriched 266:1 267:7

267:14,17,20

enriches 150:15

enriching 153:2

enrichment 108:22

324:11

ensure 7:3 28:19 62:9

93:9 95:3 118:8 139:9

190:20 235:22 414:21

415:9

ensures 234:9

ensuring 212:5 236:3

416:19,20

entail 181:15

enteral 323:17,20

324:22 325:8,16

326:12 328:14,16

329:5,8,14,15

entered 204:11

entire 71:13 80:11

entities 35:19,21 93:5

203:8

entity 58:18

entrepreneurs 148:16

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envelope 83:22

environment 31:3

71:21 72:2 105:8

118:19 144:9 146:17

147:7,19 155:9

158:14 190:21 191:2

197:1,9 208:11 224:1

231:5 233:22 243:3

261:19 262:5 389:12

424:18

environmental 13:17

113:3,5 140:13 197:6

197:22 217:3 242:4

283:1 372:3 374:22

376:11 435:11

environmentally 27:5

27:14 87:9 118:16

172:16 366:21

environments 30:18

44:9 48:8 86:8 142:9

144:7 423:4

enzymes 40:10 239:1

EQIP 433:21

equal 7:3 72:22

equally 375:17

equipment 66:16 288:1

387:12,20 389:4

390:4

erodible 421:1

erosion 12:1,9 118:19

421:4

escalation 250:10

esophagus 311:12

especially 51:20 60:2

79:21 203:7 217:8

223:18 266:16 281:14

293:21 296:3 298:2

309:13 316:8 389:18

389:20 390:1 393:5

422:3 439:6

essential 64:9 109:20

255:18 263:10 265:19

266:4 275:15 276:4

276:11 286:5 293:22

294:1 299:21 323:22

336:17 393:4

essentiality 271:20

275:12 280:11 294:5

317:20

essentially 70:5 129:2

370:12 378:11

essentials 276:2

establish 28:5,17

established 29:20

172:6 336:20

estimate 224:19

et 249:9 335:22 358:16

434:2,3

ETH 49:14

ethanol 151:2 389:10

ethical 13:1

EU 63:15 64:3

EU's 174:6

evaluate 59:17 114:9

285:5 370:8 442:19

442:19

evaluated 52:20,21

185:16 416:10 417:12

418:2

evaluating 53:2 55:1,6

56:1

evaluation 52:5,11 54:1

55:4,19,21 56:2 92:18

154:2 155:6 184:7

185:12 186:16 187:18

234:16 302:2,7

318:13 319:14 415:18

415:20 416:2,15,16

442:15

evaluations 5:14 53:14

53:19 184:1 185:15

413:11 416:11 418:9

418:16

evaluators 52:15,17

evaporate 274:17

evaporation 284:21

evening 444:6

evenly 223:20

event 162:2

eventually 103:3

ever-changing 142:1

ever-evolving 59:13

everybody 6:4 49:15

51:10 204:22 277:17

278:13 400:1,1

441:15

everyone's 220:8

evidence 65:21 93:17

139:7 206:20 210:14

210:15 211:3 403:15

evolved 226:8

evolving 84:2

exact 33:16 92:14 214:1

exactly 30:10 31:22

132:10 156:9 166:12

examine 281:17

examined 142:14

example 25:9 29:15

38:20 44:20 46:2 49:1

63:12 83:7 93:1 102:4

117:2 124:20 151:10

207:9 208:13,15

209:9 210:1 211:8

222:22 223:2 226:5

228:17 234:10 241:16

256:6 270:19 276:8

299:18 304:11,21

305:3 307:17 320:3

367:14,15 372:3

378:15

examples 161:16

162:17 166:4 183:5

251:9,11 270:16

434:11

exceed 287:15 387:13

excellent 78:12 255:13

322:5 385:14 398:16

416:5

exception 9:2 11:6

155:15 164:11 165:2

exceptions 178:3

251:11,12

excess 298:13

excessive 144:18

excipient 391:13

exciting 71:1

exclude 75:11 354:14

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115:20 116:5 269:8

269:10 270:2,18

271:3 302:6 320:1

337:3,10,21 345:20

350:16

excluding 72:20

excuse 220:6 304:15

353:11

executive 3:8 57:19

70:6 187:1

exemptions 155:7

exist 86:14 212:22

247:2 433:17

existing 63:10 235:2

412:10 440:17

exists 128:4 324:2

433:7

expand 90:14 106:5,20

129:14 373:10 426:20

expanded 107:9 143:10

Expanding 59:2

expands 77:7

expanse 101:19

expansion 326:11

expect 45:20 46:6

255:16 261:22

expectation 74:21

181:16 359:9

expectations 192:7,9

416:19

expelled 31:18

expensive 22:15 148:4

experience 13:8 56:12

57:20 101:3 140:16

162:4 185:5,17

251:16 255:8 308:13

367:6 374:20

experienced 52:19,22

256:16 272:13 417:10

experiments 48:14,16

expert 82:18 85:1 131:5

153:15 258:12 295:16

expertise 415:5,12

experts 308:14

explain 30:13 168:11

210:14 316:2

explaining 97:3

explanation 120:11

213:22

explicit 435:18

explicitly 72:9

explore 426:15

exponential 119:20,22

exposed 379:4,6

exposure 59:4 367:12

367:19 375:5 379:1

381:6

express 19:1 96:18

188:1,8 189:2

expressed 190:14

301:22

extend 115:22 258:5

384:17

extension 18:3

extensive 58:6 80:14

149:21 255:8 266:14

382:20

extensively 267:1

317:19

extent 146:16 380:13

external 47:10 207:22

235:9 397:9

extra 44:8 155:21

250:11

extract 88:22

extracted 154:13,20,21

156:17 158:7 318:11

320:12 330:9

extracting 287:1

extraction 49:15,16

95:4 154:15 284:15

292:21 326:22 346:17

354:17

extracts 91:22 92:4

extreme 123:20 222:5

251:12

extremely 169:11

308:11

eyes 139:15

F

fabric 225:20 226:18

face 54:3 59:12 64:11

259:3

Facebook 143:5

faced 62:4

facilitate 16:4

facilities 287:22 307:2

320:16,19 387:11,20

390:5

facility 102:9 166:14

242:14 309:20 373:4

382:6

facing 18:12

fact 132:9 133:19

144:21 145:2,11

172:20 184:6 187:16

188:20 194:16 212:19

235:14 237:13 240:9

241:10 274:22 302:2

339:9 412:16 435:11

facto 90:16

factor 30:21 272:19

294:9

factors 42:16 43:6

313:18

factory 12:22

factory-farmed 302:17

facts 64:12 93:14 118:6

118:12

failed 172:6 249:20

250:3 408:1

fails 342:21

failure 181:5

fair 432:10

fairly 59:17 84:2 199:5

231:2 382:20

fairness 190:20 207:3

faith 195:18,20

fall 12:9 16:21 65:4,19

89:14 98:1,13 152:15

160:22 169:19 193:20

194:4 261:5 271:4

278:17 311:21 315:9

353:19 356:10 359:3

370:13 372:13,15

405:1 409:15

fallow 17:2

falls 337:3,21

familiar 366:2 376:10

families 86:6 144:3

196:8 197:15

family 102:12 143:9

200:5 265:6,7,7,11,14

266:2 268:16 271:4

371:18

family-owned 8:14

10:18

famous 251:20

fan 372:20

far 45:6 46:9 48:2

194:15,19 195:1

281:11 282:20 382:17

farm 3:4 8:13,14,15,16

10:17,17,18,20 13:15

13:18 18:7,8,10 23:2

45:18 106:14 107:18

142:22 143:6,9 144:2

144:4,6,19 158:16

159:19 225:1 234:10

262:4 263:15,21

422:9 424:14 432:15

432:16 433:7,19

434:5,14 435:4

farmed 421:2,2 426:4

farmer 13:7,8,20 18:16

85:7 174:11 176:10

202:13,14,14 203:2

236:5 433:15

farmer's 143:9

farmer-distributed 22:9

farmers 2:12 13:2 14:5

15:13 18:7,12,14,15

20:7,8,17,19,21 21:18

21:20,21 22:4 27:18

29:2 34:10 35:1 44:18

60:6,20 62:6 70:16,19

71:3 73:5 85:3 133:5

171:9 173:6 174:11

174:13,16 193:17

203:22 207:7 209:22

212:13 234:22 235:5

237:7 262:2 316:13

387:22 393:18 396:18

431:1,3 433:5 436:21

437:8,14,18

farming 2:16 11:22 13:4

14:5,7 18:9 26:12

59:13 117:3,16,18

142:22 143:4 173:15

194:9 196:21 202:17

204:9 233:20 258:10

428:22 436:6

farmland 22:13

Farmlands 148:3

farms 2:10,19,21 3:12

12:22 26:3 34:15,15

43:20 69:12,14,16,17

70:1,4,11,14 71:9,17

72:1,11 73:9,11 85:20

116:14 143:2 145:12

168:20 174:20 183:12

241:1,4 244:4 339:17

390:1

farmstead 434:15

farmsteads 432:6 433:9

434:1

fascinating 432:12

434:6,14

fashionably 385:22

fast 63:19 66:10 121:11

231:9 250:21 332:20

faster 12:8 389:15

fatally 275:16

fate 31:12

fats 48:3

favor 195:2,13 206:15

287:5 291:21 292:13

337:13

favorability 195:15

favorite 132:14

Favre 2:15 139:20

240:20 246:8,9

249:14 250:5,22

251:6 253:1,12 254:2

331:13 333:5

FDA 63:2 169:21

240:10 367:18,18

374:15,18 375:1

382:21

FDA's 324:15
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Neal R. Gross and Co., Inc.

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fears 140:21 142:10

feasibility 159:21

feasible 223:4

Feather 220:16

feature 173:2

February 96:21 334:16

fecal 407:20

fed 302:18

federal 34:8 89:20

125:21 247:12 395:6

433:21 442:17

feed 27:8,18 28:12

42:22 69:19 135:14

203:14,15 247:10,20

391:9

feedback 46:10 113:9

261:3 378:7 410:10

416:22 417:14

feeding 23:4 27:13 60:4

328:17 329:5,8

394:11,12

feeds 27:20

feel 15:4,6,7 42:2,4

45:16 57:9 82:4 88:10

88:17 140:21 161:7

164:5 166:3 167:9,19

171:22 174:1 175:13

176:18 178:7 187:14

196:19,21 229:15

251:3 270:11 303:1

305:21 320:20 357:2

369:9 409:7,21 423:3

423:5 436:18

feeling 73:18 174:5

303:8

feels 103:8 438:6

fees 181:20

fellow 55:6 114:20

359:12

felt 286:10 288:11

388:10 394:10 406:22

408:11 414:20

Fenbenzadole 406:16

Ferman 2:15 189:15

193:7,8,9 197:3 198:5

199:3,8,13 200:3

201:1,22 245:18

fermentation 270:3

fertile 20:6

fertility 12:10 23:8 24:6

124:22 127:13 131:12

131:17 132:1 133:22

145:14 218:3 222:11

222:14 223:14 229:8

235:6 428:20

fertilization 174:3

177:18 270:3,5,19

fertilizer 87:11 118:18

150:4 175:22 176:2

207:19 208:3 217:19

223:7 242:4

fertilizers 19:15 34:10

34:11,20 36:4,6 37:11

37:12 86:7 156:1

242:9

fettuccine 311:19

fiber 60:13 80:22

215:15 310:19,20

407:6

fibers 222:1

field 16:10,11,12,15,19

24:11 26:15 32:19

39:16 44:22 45:4

48:13,16 49:1 51:4

52:11 53:19 54:1

55:21 56:2 118:15

119:1 122:4 133:9

148:10 150:8 184:6

188:16 225:12 235:22

236:6,7 237:19

238:16 243:7 416:10

417:3,12

field-based 98:11

fields 11:20 16:1 17:1

44:7,19 48:5,19

147:14 431:9,11,13

432:12,20

fiercely 140:22

Fifty 120:1 222:5

fight 286:5

figure 23:9 85:6 221:2

290:14 425:4,12,19

figuring 358:15 421:8

file 75:6 139:8

filed 139:3

files 257:13

fill 321:1

fillings 317:8

film 8:22 9:6 11:4,10

13:18 14:6 38:9 39:10

39:16 49:22 50:16,19

60:7 173:6 212:10,18

212:20 213:10 234:2

235:14,21,21 236:4

236:14 237:1,16

239:21

films 9:8 11:12 46:19

212:9 233:4 234:9

235:12

filter 240:8 279:19

282:14

filtered 32:14,14,19

317:13

filtering 32:15 281:3

282:10 362:5

filtration 262:9 280:10

final 89:4 109:13

160:18 167:16 208:8

241:22 351:3 362:12

411:19 412:14 421:19

finalized 109:4 413:16

finally 77:9 81:22 92:16

109:11 113:7 208:5

241:22 264:9 345:12

345:16 368:1

financial 20:9 119:6,9

find 25:8 76:10 79:8

88:15 103:3 140:1

150:8 159:12 164:19

173:4 182:21 209:16

211:6,13 221:13

231:19 306:20 309:3

309:11,14,18 359:14

375:17 400:3 416:6

436:8

finding 374:15 416:3

finds 111:13 236:4

fine 17:11 67:13 358:9

finessing 251:4

finish 14:8 21:6 116:10

380:19

finished 150:9 152:21

282:16 432:21

fire 97:15

firing 21:9

firm 79:18

firmly 126:3

firms 37:12

first 8:5 20:12 25:21

46:7 83:11 88:9,16,18

106:3 110:22 123:11

127:21 130:15 146:8

153:12 171:17 180:13

194:8 205:1 206:16

218:19 227:18 230:17

234:4 237:13 246:20

246:20 249:2,5 257:6

258:7 265:8 274:13

277:12 278:14,18

279:8 296:17 300:21

306:5 309:9 312:8

321:15 323:11 330:22

334:21 340:6 345:15

355:21,22 357:17

370:21 372:19 386:15

386:22 387:2 396:13

404:13 407:18 408:8

413:9

firsthand 101:3

Firstly 241:15

fish 2:16 20:4 23:13

24:22 82:9,21,22 83:3

83:4 103:2 142:22

143:4,22 145:5

157:22 159:8

fishery 82:18,19

fit 72:12 134:12,15

251:13 259:1 269:8

269:15 425:22 430:5

fits 81:16 222:3

five 78:2 79:21 88:10,15

88:17 89:6 154:2

226:11 254:15 264:1

280:7 294:6 301:17

311:22 360:1 369:12

376:10 399:1 415:9

425:8 442:2,3,11

444:3

five- 353:10

five-year 353:13

fix 303:18

fixate 298:14

fixation 145:15

fixed 113:8 399:12

Flamm 420:2

flash 283:16

flavor 89:1 283:4

335:14

Flavorganics 88:4

flavorless 62:19

flavors 88:21 89:5,12

89:16

flexibility 59:11 417:15

flexible 414:4

flexing 236:21

float 275:7

flock 144:1

flood 262:8

floor 408:22

Florida 3:1 202:4,10

flour 4:10 310:9,12,15

311:20 312:3 313:14

316:15

flow 35:3

flowers 169:7

focus 56:6,6 96:4

194:21 204:6 214:6

216:14 221:3 264:7

355:21

focused 326:16

focuses 95:20

focusing 12:21 98:21

fog 88:11

folks 7:1 104:5 136:12

202:18 205:7 328:6

370:22 385:21 428:19

434:9 443:17,18

folks' 7:9

follow 13:2 48:11,17

54:14 82:13 129:10

147:9 157:8 158:21

165:18 166:5,6
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Neal R. Gross and Co., Inc.

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167:14,17 221:16

244:5 407:16

follow-up 293:9 295:15

383:12 425:16

followed 6:8 17:19

51:14 57:13 74:10

79:14 85:14 87:22

91:6 96:9 107:14

110:11 142:18 171:1

204:1 205:1,11 212:1

246:5 264:19 280:1

281:7

following 109:16 149:1

153:2 160:3 168:19

172:4 175:19 242:16

289:13 324:4 368:19

368:22

follows 118:14

food 11:20 20:16 24:17

25:3,6 27:14,22 28:4

29:9 41:12 47:11

57:21,22 60:2,5,13

61:21 62:3,5,10,14,15

62:22 63:9,13,15,18

63:21 64:2,9,12 66:15

67:10,22 68:6,8,10,10

68:12,17,20,22 69:1

72:5 80:22 82:11,12

102:1,16 107:8

118:20 122:4 140:20

141:4,7,7,11,21 142:2

142:8,15 143:7,14

150:21 206:8,22

208:10 247:13 248:6

255:7 256:2,3 258:10

260:21 261:14 265:8

265:11 274:18 279:6

282:10,15 285:18,19

287:13 288:6 291:17

294:8 298:16 299:11

312:20 335:10,11

336:6,12 338:16

366:17 368:15,17

369:10,21 370:1,2

374:14 379:20 381:19

382:7,11,16 383:2,3,8

384:1 390:4 395:9

421:14,18 424:16

431:11,15 434:17

food's 63:8 65:15

foodborne 286:6

foods 62:4,11 63:7 86:5

155:6 260:18 262:2

283:16 286:22 293:7

302:4,5 310:21 324:6

335:15 382:19 444:4

fooled 276:3

foot 201:14 399:18,21

footbath 397:15

footprint 148:20

force 70:8 76:11 123:11

124:18 125:3 127:19

132:5 140:17 185:21

261:2 427:16

forces 19:6

forcing 251:14 427:13

foreign 67:14

forever 429:16

forget 200:18

forgot 46:7

form 22:17 36:15 207:8

219:5 240:9 300:20

312:10 314:7 318:11

335:19 336:2

formal 258:10

formally 384:2

formation 46:10

formed 307:18

former 443:1,4,20

formerly 258:21

forms 4:11 191:17

259:10 311:18 317:4

343:14 345:6,9,15,15

345:16,17

formula 266:5,9,13,21

275:15 276:12 289:12

325:12,13 326:7,10

formulas 323:18,20

325:8,16,17 326:12

328:14,16,21 329:14

329:15

formulate 109:22

formulated 402:10

forth 111:2

fortification 77:12,13

324:11

fortified 77:14

Forty-four 120:4 121:15

121:16

Forty-three 121:13

forward 54:11,22 62:17

91:20 95:8 103:9

109:21 142:13 240:17

254:12 297:6 315:10

316:2 354:10 357:5

409:2 411:11 413:10

418:3 426:22

FOS 267:12,20 268:6,7

268:9

fossil 39:3 72:6 84:20

233:16

fossil-based 38:19 39:2

40:8 43:7

fostered 124:22

fosters 262:19

found 8:16 10:20 40:21

48:1,2 75:10 87:7

147:5 163:6 210:19

211:8 311:16 356:19

416:9 439:15

foundation 21:13 57:19

142:8 173:15 234:8

foundational 76:14

founded 62:2 265:7

founding 20:21 154:7

four 16:14 246:16

263:18 266:7 369:12

395:18 396:11 409:20

442:6

Fourteen 365:10

fourth 53:10

fraction 68:13 230:12

230:13 327:20

fractionate 41:10

fractions 43:13

fragile 102:2 330:15

423:18 426:10 429:13

435:14

fragile/native 263:11

fragmented 235:15

fragments 264:4

269:20

frame 425:7,8

framework 249:1

251:21 374:13 440:18

Francis 1:20 77:16

126:8 127:16 151:21

219:1 299:10 340:1

399:16 402:5

frankly 272:11

fraud 63:22 66:22

free 144:8 164:1 312:7

409:21

Freeman 2:12 146:7,19

freezing 283:16 286:22

frequently 172:14

176:21 308:17 391:1

fresh 3:12 26:3 96:15

152:20 226:6 244:4

335:17

fresher 148:21

freshwater 102:6

friend 191:20 274:12

276:7,15 438:6

friendly 27:5,14 87:9

172:16

friends 88:15 200:8

304:21

front 223:15,17 260:7

310:3 435:3

fronts 190:11

fructooligosaccharid...

267:12

fruit 100:4 179:2 219:11

219:19 284:16 312:12

317:11

fruition 226:4

fruits 97:21 335:18

frustration 301:22

FSMA 12:3 322:12

fuel 84:20 275:5

fuels 72:6

fulfilled 242:10

fulfilling 59:19

full 89:14 181:1 199:9

199:19 226:12 234:3

278:22 356:11 395:8

fully 50:1 85:5 155:17

224:13 233:6,17

234:17 294:21 339:3

348:12 428:5

fumigants 377:5,18

382:2

fun 258:22 274:18

function 70:11 267:1

270:5 312:10

functional 39:15 281:2

298:16

functionalities 237:16

functionality 112:18

238:1 267:19

functions 216:5 269:22

283:16

Fund 422:10

fundamental 108:15

270:8

funded 217:17

funding 367:1

fungicide 377:4

fungicides 377:19

382:2

funky 32:9

further 7:9 92:13

103:15 136:10 148:5

148:5 161:3 171:22

180:17,21 182:7

191:10 195:17 254:17

259:18 260:8 281:16

313:15 346:3 355:17

356:10 358:3 371:9

399:3 400:9 406:8

411:6,6,13 417:21

Furthermore 147:12

fusion 270:20,22 271:3

271:5,6

future 60:4 66:7 81:20

92:8 94:7 95:4 98:18

99:4 191:1 272:15

398:6,19 400:7

429:15

G
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Neal R. Gross and Co., Inc.

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gain 430:2

gametes 270:20

GAP 22:10

garden 150:14 152:13

gardening 133:16

gardens 70:22 242:22

Garth 2:19 179:9 183:8

183:9,11 393:22

GE 313:8

gear 200:8

gelidium 157:17

gelling 311:4 317:8

318:2

gels 312:12

general 161:2 175:19

184:3 186:15 189:5

198:7 206:3 255:10

260:22 294:12 319:16

343:20

generally 6:13 176:7

188:20 268:7,8

305:10 306:1,3

317:15 326:19,21

327:20 388:1

generate 372:13

generation 8:16 10:19

272:4

generation's 8:17 10:21

generations 60:4 142:6

191:2

generic 338:10

genes 270:15

genesis 435:12

genetic 63:6 271:2,8,12

genetically 269:11

346:11

genetics 108:22 109:17

genome 63:8 65:15

gentler 389:17

gentlest 80:21

genus 354:20,21

geographical 442:22

Germany 54:15 63:14

germicidal 388:21

germinate 241:21

getting 8:5 16:5 20:9

22:10,11 23:11 32:9

83:11 132:13 135:13

148:5 159:22 224:21

231:11 296:15 316:17

348:13 359:21 360:1

409:14 427:5 428:4

440:17 441:16

giant 119:2

gifted 191:20

give 7:5,22 29:8 31:8

37:4 39:18 45:2,8

48:20 64:13 77:22

85:6 88:15 117:21

120:15 165:10 166:3

251:9 274:8 422:8

441:11 443:8

given 9:22 20:18 99:5

137:5 161:20 199:16

261:1 274:8 281:19

294:14 295:2 315:12

345:22 384:19 399:6

399:10 401:4 414:6

gives 168:2 188:4 243:9

249:1 274:17 296:10

305:15 390:9

giving 38:4 61:15

190:11

glad 89:3 200:13,14,15

glands 392:3

global 190:14,16

264:13 265:12 322:1

globalization 64:1

globally 12:19

globe 357:1

glucomannan 310:19

glucose 5:5 390:15,17

391:3,13

glut 299:5

gluten 312:7

glycerin 391:7

glycol 391:7

GMO 115:4,9 134:21

241:21 302:4,4

347:19 351:2,3

GMOs 115:21 302:18

345:18

go 6:20 15:10 16:11

17:14 24:2 31:21 32:3

61:19 67:8 78:16,17

79:4,7 80:4 109:1

126:8 129:13 136:11

142:13 150:9,14

156:5 165:4 179:11

184:16 187:5 189:17

203:8 204:17 250:20

266:2 277:8 306:20

322:18 328:18 332:18

332:21 350:13 359:18

366:12 371:9 374:2

377:2 382:17 383:13

408:17 410:22 417:11

420:13 422:2 427:18

442:18

goal 60:5 81:15 99:10

261:21 355:10

God 203:9

goes 31:20 32:14 89:9

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326:20

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Neal R. Gross and Co., Inc.

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376:7 385:1,8

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infusion 391:3

ingredient 90:16 266:4

294:8 323:6 336:12

369:7

ingredient's 266:22

ingredients 89:2 90:7

112:17 116:1,3

162:21,22 164:3

213:18 258:21 279:4

279:5 299:15 300:14

301:12 302:20 308:4

391:13

initial 289:18

initiatives 433:15

injecting 220:11

injure 108:17

innocuous 206:8

208:10

innocutive 208:16

innovation 81:15

innovative 71:2 92:7

101:22 206:21

input 30:3 82:7,15

136:7 153:16 158:19

159:13 160:1 208:12

217:14 222:16 229:7

314:3 346:1 367:4

375:13 407:9 409:22

inputs 26:10 28:11 30:6

30:7 37:3 59:21 71:19

83:8 86:15,17 118:15

119:12 131:13,18

133:21 136:4 157:20

201:19 208:20 214:15

216:22 217:3,3,4

218:6,21 222:19

227:20 228:1,4,15

234:10 245:9,14

319:16 345:2 354:15

354:21 373:12 380:15

380:22

inquiries 182:22

insects 144:15 147:17

242:5

insert 67:21

inserted 377:7

insertion 63:7 65:15

inserts 259:20

inside 40:14 45:21

47:16,17 48:15

394:18

insight 39:19

insisted 90:13

insoluble 317:13

inspecting 183:13

inspection 54:5 56:19

84:1 181:19 257:15

414:21 415:11 416:21

417:2 433:13

inspections 54:11

113:14 185:6 415:19

416:8 417:19 430:11

430:15

inspector 53:4,16 54:12

54:16 56:7,9,12,14,22

184:17,18 185:11

254:9 255:4 256:18

414:1,8 416:12,20

417:4,11

inspector-on-inspect...

55:13

inspectors 3:7 5:15

51:18 52:5,6,7,19

53:2 55:20 56:1,17

57:2,8 181:16 184:8

184:11 185:6,22

187:10,19 255:2,5,10

255:11,14,16 257:11

413:12,22 416:5,6,10

417:6,18 418:3,9,16

inspired 190:13 267:3

instance 240:5 250:9

instantly 130:14

Institute 2:14 3:3,6 18:1

18:18 153:11 212:4

Institute's 256:3

Institutes 367:1

instruction 254:12

412:8,17 414:14

instructions 383:10

insufficient 63:10

268:13

insurance 329:11,12

intact 238:9,11 263:12

intake 320:4

integral 58:13 339:19

integrated 13:9 242:6

integrating 147:15

integrity 62:5,9,16 64:2

64:8 66:11 71:13

123:16 155:19 158:20

189:12 212:6 231:15

234:9 271:14 297:22

305:14 314:5 317:22

369:6,10 378:12,16

intend 99:7

intended 80:2 81:11

85:10 161:19 369:22

395:17 396:10 400:15

401:16

intensely 275:10

intensive 207:20

intent 9:9 11:13 55:2

59:20 77:7 95:2

146:16 242:10 251:17

383:15

intention 95:1 161:22

intentionally 34:9 37:14

335:12

interact 190:18 370:1

interaction 227:3

422:22

interchangeable

267:13 268:8 276:18

276:22

interest 9:17 97:20

120:18 278:6,8 305:9

306:4 318:9 366:3

interested 27:12 245:19

252:17 307:20 378:6

434:9

interesting 148:16

198:19 350:9 378:2

400:4

interests 433:7

interfere 269:5

international 2:14,15

3:5,7 26:2 51:18

74:15 102:8 246:10

257:12 313:2 317:15

internationally 96:16

264:10

internet 199:3,4 311:16

interpretation 72:17

168:2 172:22 384:10

interpretations 384:6

interrupting 7:1

intertidal 356:5

intervention 109:3

intestines 301:1,5,10

301:13 302:18 303:18

307:1

intrinsic 262:6

introduce 81:6 322:19

introduces 251:16

introducing 278:21

intuition 141:13

inulin 267:14 268:5,10

inulin-oligofructose

265:22 267:7,13,17

267:20

invest 71:4 434:2

invested 121:5 203:12

356:15

investigate 272:16

investigating 356:16

investigation 355:11

investment 148:15

investments 87:13,15

invisible 62:19

invite 357:9

invited 139:11

involved 107:9 145:12

184:7 415:22 433:4

involves 228:15 270:19

involving 270:12

IOA 254:9

iodine 389:10,15,17

IOIA 52:5 54:10 57:6

184:18 187:12

IOIA's 52:9 53:3,21 54:4

IP 348:9,9

IQF 309:21

ironic 436:9

irrigate 242:3

irrigation 147:6

irritated 389:19

ISA 417:7,11

ISO 35:16

isolate 326:17,18,21

327:2,3,14 328:2

330:9

isolated 45:3 294:9

isolates 327:16

isopropanol 389:10

issue 42:1 56:9 62:12

76:19 84:15 85:4

86:10 92:21 125:12

136:2 173:5 177:22

178:22 179:17 187:12

191:16 207:6,7,19

208:14 210:4 225:18

295:19 297:10 306:10

307:6 309:15 339:4

346:20 351:12 356:13

357:15,19 365:20

368:10 370:9,19

374:20 380:21 384:19

385:6 393:17 398:9

413:19 421:20 425:18

427:11,13 428:5

440:13

issued 414:14 416:14

issues 7:17,19 37:5

43:1 51:21 58:4 78:20

88:20 93:22 94:1 95:2

108:20 109:13 116:12

117:7 194:6 203:18

230:5 253:18 257:13

289:14 295:17 307:6

330:17 353:12 366:3

367:10 370:15 392:13
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

469

398:18 422:6 428:3

440:15,18

Istanbul 64:4

it'd 198:19

it'll 68:14 139:17

Italy 67:17

item 266:3 282:7 299:3

304:3 308:18 319:17

329:3 341:18,18

346:2 353:6 361:20

365:5,12 419:14

item-level 62:20

items 90:1,16,17,19

171:16 194:11 275:19

300:16 305:5,12,22

306:12,14 307:22

309:9 319:14 326:5

343:3 349:17 382:17

401:6 406:9

iteration 357:17

Ivermectin 406:19

J

Jackie 2:13 153:7 160:3

160:4,5,8 163:17

168:16

jackrabbits 431:12

Jacksonville 202:8

204:19

jaded 22:16

jams 317:8 321:12

January 291:10

Jason 2:20 3:18 110:11

117:10,11,13 120:14

179:16 232:21 240:19

240:22

Jean 333:6 356:14

409:12

jelly 320:13

Jennifer 2:9 107:14

110:10,11,14

Jenny 187:10

jeopardize 119:8

jeopardy 252:13

Jerusalem 267:9

Jesse 1:15 29:12 332:8

342:13 364:10,11

397:12

JESSICA 2:5

Joan 3:4 8:6,10,12 9:19

10:16 17:7

job 117:1 184:5 308:1,6

385:14 416:17

jobs 119:8

Joelle 1:17 214:11

279:12 280:20 298:5

341:19 370:21 372:18

380:9 382:14

Johanna 3:3 146:2

153:6,9

John 2:8 139:22 268:22

274:4,4,6 277:2,5,15

join 296:9

joining 296:9

joint 51:10 85:22

joke 202:13

journey 143:8

judgement 251:15

Judging 315:3

judgment 405:1

juice 320:4

juices 282:15

Julie 3:16 85:14 87:21

87:22 88:3 91:5,6

jump 278:17

juniper 430:13

jurisdiction 373:20

justice 107:8

justification 155:16

181:11,13,17

justifications 429:4

justify 155:4

Justus 2:19 179:15

212:1 215:5,8,8 219:9

219:18 220:16 221:17

223:5 224:7 225:16

228:6 230:2 232:5,14

K

Kahl 2:19 179:9 183:11

183:11 186:11,13,19

393:22

Kamimoto 2:20 179:16

232:21 240:21,22

243:18 244:3,13,19

245:10,15 246:3

Kansas 430:15

kaput 275:22

Katharina 3:7 17:12

34:3 37:20,21 38:1

keen 188:4

keep 19:7 32:8 46:12

126:3,4 144:1 163:20

230:20 251:22 276:20

297:22 299:4 370:12

399:22 402:20 405:8

435:20 439:1

keeping 20:20 181:10

181:14 335:5 370:18

436:22

keeps 12:2 144:6

230:15

kelp 82:8,12 92:17

157:22 159:9 354:2

kelps 78:8

kept 394:1

Kerrigan 2:21 139:21

257:21 261:12,13

ketosis 391:2,11

key 155:18 217:20

219:10 248:8 307:22

kidding 406:7

kids 330:16 438:8

kill 388:2,4 427:9

killed 275:17

kills 288:4 389:14

kilometers 149:2

kind 14:22 22:4 24:14

45:12 48:3,9 49:3

50:3 121:9 132:17

159:9 165:6 175:14

184:12 199:7 200:18

204:2 209:16 219:14

220:22 221:13 225:11

226:2,3 228:7,9

229:12,17 230:16,17

230:19,20,22 231:21

243:15 273:12 297:18

297:20 298:7 299:13

303:9 307:10,10

310:3 316:6 320:22

338:5,8 368:12 370:1

374:21 375:4 380:8

381:8 382:4 394:1

406:14 407:19 408:17

411:10 414:8 420:3

422:21 429:17 438:1

kinds 200:17

kit 394:2

kitchen 242:20 320:13

322:9,10 394:18

knew 320:9

know 14:20,22 16:10

22:11 23:10,13,17

24:4 25:9 29:19 31:15

31:22 39:20 44:13

66:4,5 73:20 77:20

78:6,12,16 79:6 89:8

94:9 99:19 100:2

105:13,14,20 107:4,6

114:1,16,19 115:13

116:15 122:7 123:21

125:16 127:8 129:3

129:17 130:5 131:6

132:16 133:8,15

134:4,19 135:8,19

138:18 149:10,13

150:22 157:9 158:22

159:4,8,19 164:16

165:8,17 166:1,2,8

169:15 170:16 172:19

174:19 175:3,6,15,19

175:21,22 176:1,3,4,9

176:21 177:5,5,7,14

177:18 178:5,8,10

183:16,19 185:9,16

186:3 191:11 192:17

193:3 194:2,10 196:4

196:11,16 198:22

199:9 200:1,7,20

201:4,12 202:22

203:1,1,2,21 211:11

214:3,7 217:12

220:11,17 222:16

223:12 225:11 226:19

228:7 229:12 232:7

235:16 236:15 239:10

240:6 244:20 245:20

245:21 246:5 250:4,4

251:8,19 252:8 268:5

273:19 275:9 276:5

277:9 295:12 296:7

296:11 297:8,10,15

297:22 298:1,6,11,12

301:4 302:10,21

303:10,12,22 304:15

305:14 306:4,21,21

307:1 308:17,22

309:2,12,13,19 310:2

314:5,12,15,19 316:5

316:6,14,15 319:5

320:1,3,5,15 321:2,11

321:12 322:4 329:19

336:19 338:5,8

347:11 348:16,18

349:2,19 358:22

363:11 372:16,17

378:5 379:1,4,19

381:10 383:22 384:15

384:20 385:5 390:8

390:10 399:6,19

403:3 408:15 410:5

411:1 412:3 420:22

421:5 422:7 423:8

425:1 427:8 428:3,15

428:19 436:11 440:18

knowing 175:4 321:3

349:16

knowledge 193:1,5

204:13

known 71:19 76:1 93:1

142:4 223:1 239:20

258:21 291:14 310:22

366:18 368:5 375:2

378:12 381:3,4

437:17

knows 218:11

konjac 4:10 310:9,12

310:15,17,22 311:17

311:20 312:3,6,9,11

313:9,14,16 314:6,8

315:20,21 316:7,15
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

470

konnyaku 310:22

KOW 239:10,13

Kristen 2:7 96:9 100:11

100:12,14

Kyla 3:9 171:1 179:8,10

179:20 180:1 183:8

kymene 362:17

L

L- 326:9 330:4 333:2

L-methionine 4:12

322:17 323:1,4,15

324:2,17,20 325:6

326:6 327:14 328:3

331:3,11

lab 45:3 46:16 48:12,15

label 12:17 27:16 28:18

28:18 48:14 59:2

70:15 71:9,11,13 73:1

73:4,6 86:2 87:16

170:6 204:12 245:8

245:12 430:3

labeled 47:15 71:8

279:4,22 281:10

300:15 323:18 324:9

325:11,14

labeling 26:7 73:2

141:18

labels 62:6,10,16

141:19 264:9,10

labor 12:5 59:15

laboratory 30:8 41:10

49:5,9

lack 63:11 134:11 267:5

269:20 280:10 294:5

353:17 354:21

lacking 101:3

lamb 301:5

lame 399:20

lameness 397:21

land 14:2 18:9 22:15

37:12 59:15 60:3

87:10 118:18 123:21

124:7 129:22 151:2,7

151:13,19 169:19

206:5 420:20 424:3,9

424:13 426:4 427:14

427:17,22 429:11

430:14,21,21 431:2,3

433:15 438:12,20,22

440:16 441:5

landfill 12:12,12 15:20

lands 191:8 262:10

263:1,1,13 264:8

356:6 420:22 421:2

422:1 430:18 436:5

436:13,15,17,22

437:3,5,9 439:5

landscape 225:3,4,7,20

226:10,18 432:14,19

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440:12

language 55:1 89:11

181:3 185:3 233:14

436:4

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large 23:16 49:3 65:3

66:12 216:2,16

236:16 242:16 253:13

279:18 283:19 308:4

308:4 320:15 337:8

largely 247:16 311:13

337:11

larger 80:9 104:14

105:2 106:9,14,15

351:11 369:15 371:2

373:9

largest 57:21 102:6

143:17,19

lastly 124:17 309:3

late 6:19 385:22 432:21

436:19

Latin 74:20 92:12 354:1

355:2,4,12 359:6

Laughter 274:10 277:7

311:8 322:11 390:11

394:19,22 413:1

launch 308:13

launching 265:8

laundry 284:14

law 12:22 37:9,10 72:8

72:15,18 124:22

125:7,21 128:3

247:13 262:17 395:6

lawful 395:7,12 396:5

lawsuit 90:6

lay 50:19

layer 137:8 250:12

layers 49:4

laying 144:2

lead 108:17 194:6,7

322:22 346:1 354:21

356:15 357:8 366:8

385:13 387:17 405:21

419:19

leader 85:22 218:17

265:10,12

leaders 264:13

leading 276:13

leads 130:12 363:1

leafy 143:21

learn 58:4 72:19 132:5

143:4 190:9 367:5

learned 290:4 306:15

417:2

learning 132:10

leasing 22:14

leave 79:4,7 90:2

167:13

leavening 284:9

leaves 144:6

leaving 15:22

led 116:5 195:7

leeched 147:12

left 8:1 17:1 40:20

308:3

leftover 240:7

legal 436:22 437:6

legalization 169:4

legitimate 59:19

legitimately 146:10

241:11

Lehrburger 2:22 160:4

168:22 169:1 170:10

170:16,21

length 398:16

lens 418:4

Leonardis 2:12 146:5,6

149:17 151:6,20

152:5,7

leonardite 208:15

Leonardo 142:18

lesser 73:6

lessons 247:21

let's 15:3 20:19 60:16

60:17 76:10 158:22

209:19 225:19 375:5

letter 12:22 29:3 262:17

366:5

letting 179:4

lettuce 143:21

level 68:3 92:12 95:17

109:2 188:12,15

201:14 206:19 290:14

380:18 404:11 425:2

426:9 433:7,20 434:5

435:4 437:19

levels 32:1,2 99:14

105:17,20 109:19

116:14 117:2 149:13

149:16 287:15 320:6

336:6 366:21 367:16

367:17,19 381:11

387:12 399:9,15

403:15 435:17

LEWIS 2:4

licensed 395:8,13

396:5

licensing 57:8

lidocaine 5:7 108:2

165:17 400:10,12,13

400:19,19 401:3

402:2,9 405:9

lieu 76:2 94:11

life 106:21 172:9 191:9

214:8 233:8 236:9

269:18 276:16

lifespan 226:12,13

lift 16:11

light 7:22 226:13

lighten 272:21

lighter 14:2

lighting 177:20

lightly 260:22

lignans 215:17

Likewise 270:22

Lima 1:15 45:12 64:19

65:18 278:3,11

279:12 280:14,20

281:22 282:4 283:6

283:12 284:8 285:22

286:12,20 287:20

288:13,22 289:9

290:19 291:12 292:16

293:2,14 295:7,14

296:13 298:5,17

299:10 300:4,8 301:2

302:13 303:13 304:5

304:19 306:8 307:15

309:7 310:8,14

313:20 314:17 315:7

315:19 316:20 317:6

318:15 319:7 320:8

321:5,21 322:13,21

323:14 325:18 328:4

328:12 330:3,13,19

331:7,21 332:3,8,18

333:11 334:5 335:1

338:1,12 339:5 340:1

340:4,10 341:6,13

342:11,22 343:7,9

346:6 347:5,16

349:10 351:10,14,22

352:2,5 353:2,8 358:5

358:8,18 360:4 361:6

361:11,15,17,22

363:15,18 364:21

365:8,11,16 370:20

372:10,16 376:14

377:20 378:18 379:12

380:6 381:1,18

382:14 384:11 385:10

410:2,11 419:7

limit 173:21 287:16

387:14 400:5

limited 59:14 128:20

178:2 251:1 318:10

324:9

limiting 59:5 217:18

299:8

limits 109:7 344:9
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

471

373:6

line 19:8,13 174:1

234:20 244:17 259:6

273:9 431:5

lined 367:15

liners 372:5

lines 101:13

Linley 2:14 17:19,20,22

21:16 23:1

liquid 23:4,11 87:5

131:12,17 207:8,18

207:22 208:4,6

216:18 218:5,13

219:5,8,8 336:2,2

liquids 220:11,15

Lisa 1:15 2:3 41:2 45:10

64:17 278:2,9 333:8

333:10 340:10 341:13

385:17 410:1

list 2:3 4:13,14 78:14

80:9,11 81:10,15 83:3

83:13 89:16 90:8,12

115:13 132:13 136:16

153:20 155:17 158:1

167:3 175:4 194:15

197:21,22 212:10

220:17,21 256:22

257:4,5 265:17 266:3

267:12 268:9 274:14

274:16 275:1,9

278:16 279:2,22

280:4 282:7 283:21

287:5 288:3 294:7

296:16 300:12,17

307:17,20 309:9,17

317:2 323:5 324:19

325:10 326:9 328:8,8

333:9 334:13 336:15

337:12 341:11,18,18

345:3 347:15 351:13

353:16 354:4,7

355:12 357:7 371:16

377:10 378:2 381:21

382:20 386:19 389:8

390:20 392:16 396:19

398:4,7,21 401:7

402:7,21 406:20

listed 77:11,14 80:3

108:4 111:17 120:17

132:12 156:16 181:17

182:18 271:3 279:9

279:21 281:20 317:22

327:3 344:21 345:3

348:10 355:4 362:3

368:3 375:3 379:22

382:18,20 387:5

396:13 397:4

listen 275:10 295:20

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296:10

listing 78:5 89:5,11

90:13,15 111:7,9,10

111:18,22 112:2

113:1 115:5 182:8

183:3 267:11 278:14

279:8 280:18 281:13

282:9 283:10 284:2,6

285:4,9,12,17 286:18

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291:5,19,21 293:6,13

293:19,20 300:21

310:12 313:4,8

315:12 317:4 319:4

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327:14 328:3 333:10

345:5 347:2,13 349:5

388:18 394:6 397:10

listings 4:14 92:11

183:2 353:9,15 354:6

357:6 359:1 360:14

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literally 260:21

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little 16:8 21:22 31:3

39:19 41:6 42:8 55:9

55:15 67:20 68:16

93:17 106:6 148:15

158:21 174:21 184:20

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219:3 225:15 258:7

297:7,13 298:13

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306:10 307:12 320:20

321:2 326:15 332:19

332:20 346:7 367:21

368:7 392:21 399:10

402:15,19 405:1

407:12,15 408:13

410:10 425:1 426:8

441:5 442:7 444:5

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live 62:13 152:12,17

191:12

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livestock 5:2,9 6:8

24:18 109:5 134:16

135:20 160:11 161:4

161:7,17 167:12

180:10 182:5 188:3,6

188:11,19 189:3

246:17 253:1,14

257:12 288:19 386:2

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387:22 389:9 390:3

391:14 395:17 396:9

397:13,18 399:12

400:15 401:5,12,16

406:11 407:1 409:10

411:15 412:20

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109:19 144:17 190:18

190:20 227:9 241:5

241:10,16,17,18

242:13,19 243:2,5,9

243:10 254:8 430:2,9

438:21

load 31:15 45:16,20

272:21

local 18:13 20:16 62:14

102:16 108:2 241:8

247:12 397:9 400:13

400:19 401:2,14,20

located 72:4 102:5

148:6

location 18:10

logical 130:5,12 161:11

252:2 378:15

logo 203:10,17

long 45:15 95:15 109:1

132:12 201:2 237:17

241:5 248:19 259:21

277:10 294:20 303:18

359:17 385:5,8

393:16 404:2 407:3

409:18 437:11 439:8

long-season 13:12

longer 44:21 71:8 97:16

253:6 265:19 274:17

297:17 393:20

look 12:19 33:15 54:5

78:19 82:7 105:3,19

106:5,8,20 135:13

137:11 138:7 139:9

164:20 175:9 178:10

199:22 206:9 208:11

229:7 230:6 240:17

247:8 249:6,10 252:3

254:12 288:21 297:13

309:10 347:19 349:8

371:1 373:10 374:3,7

379:10 380:14,14

381:8,15 397:3 400:7

402:19 418:3 426:13

428:8,18 433:3 434:3

437:22 442:21

looked 45:5 158:1

220:21 375:22

looking 41:18 43:18

56:16 85:8 119:4

120:11 130:8 131:6,7

131:22 137:15 139:15

157:7 158:17 164:12

166:7 214:10 216:12

220:22 268:4 297:9

298:2 304:7 305:5

315:2 340:3 363:13

376:15 413:12 414:7

416:12 425:12 427:19

427:20 433:19

looks 25:20 109:21

163:19 290:13 379:8

379:9

loop 17:15 363:12

loopholes 128:15,17

129:1

loosening 13:4

lose 13:3 70:15 222:7,8

222:8 223:9 275:6

276:1

losing 73:7

loss 206:5

lost 27:8 87:18 276:6

388:22

lot 14:22 38:8 40:20

53:12 56:22 61:3

70:10 74:5 85:3

105:12 115:2 151:2

157:20 166:3 167:22

168:12 171:5 174:12

178:13,20 179:1

186:3 190:12 196:17

201:5 210:20 216:11

223:13 225:2 226:1

228:17 230:5 231:15

257:8 266:6 299:14

299:22 320:1,7,18,19

321:7 322:3 365:19

370:6 374:19 376:7

394:8 409:12 413:13

416:7,22 417:1,2

422:5,17 423:2 424:8

433:19 437:2,17

441:8 442:2

lots 49:7 159:17 166:6

302:16 309:19

Louis 118:5 140:18

love 163:16 252:19

274:11,12 299:17

409:15

low 22:7 318:18,22

403:16

lower 148:20 230:13

327:20

lowering 90:10

lowest 113:3

luck 274:21

lucky 62:13
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

472

Luddites 21:10

lunch 6:7 140:1 179:11

179:16 189:18 193:13

202:2 204:18 245:17

434:7

Lynn 2:11 91:7 96:9,10

96:12 99:15,16,17

100:10

M

mad 275:3 276:1

Madagascar 67:16

magic 118:3

magnesium 4:8 279:16

289:2,4,9 290:11

main 69:22 184:19,20

404:4 436:11,16

maintain 13:1 29:6 77:2

77:6 232:8 280:5

maintained 28:20

260:10 382:21

maintaining 263:2

Majestic 1:9

major 13:12 53:7

372:21

majority 131:20 218:4

220:8 224:11 352:9

360:16 364:9 416:4

418:18

makeup 219:7 271:8,12

making 7:12 37:12

50:18 70:13 71:1

80:12 88:22 214:16

230:5 291:14 292:3

294:1 319:2 320:16

384:15 411:22 415:12

430:20 437:11

maligned 275:16

maltodextrin 335:22

mama 140:13

mammals 109:19 392:4

man 274:11

manage 391:2

managed 190:22

225:14 426:5

management 13:10,11

82:19 92:2 93:8 125:1

127:14 134:2 138:19

144:14 146:12 147:16

161:17 162:11,16

166:15 183:5 242:6

261:16 391:9 397:14

397:20 407:18 432:11

432:16

manager 2:3,13 110:15

146:7 160:9 190:1

308:3

managing 235:6 257:13

377:17

mandate 216:22

mandated 202:7

mandatory 124:21

125:11

manner 93:10 113:17

116:16,18,21 164:13

190:22 369:5

Manual 6:13

manufacture 236:13

manufactured 114:5

281:7

manufacturer 36:12

159:20 273:19 337:15

manufacturers 58:12

58:22 159:13,16

312:10 316:2 317:17

367:5 381:11

manufacturing 84:18

158:17 285:8 292:19

309:12

manure 36:15 83:9

Marco 2:12 142:18

146:1,2,6 149:8

Margaret 3:7 37:20

51:14,15,17 54:19,20

56:11 57:13 187:11

Marianne 61:11 69:11

70:6 73:16 74:3

Marie 2:18 139:21

261:10 264:19,22

marine 4:14 74:19 75:8

78:5 82:17 83:11,12

83:17 91:13,17 92:11

95:4 353:9,15,22

354:3,7 356:1 357:6

360:6,13

marker 63:5

markers 62:20

market 18:8 19:4,6

21:21 39:12 50:9

119:2,6,18 143:10

148:11 173:7 204:8

206:8 208:7 266:9

299:6,7 303:15 304:1

308:15 313:9 328:22

329:1 348:8 349:21

marketed 35:10 311:1

329:15 330:15 348:8

marketers 392:19

marketing 2:21 121:2

241:1 338:8,8

marketplace 94:18

118:10 308:10,20

markets 22:6 148:20

233:7

marsh 102:7

Marty 3:1 179:14

189:17 193:7 202:1,3

204:21

Maryland 8:15 10:19

mass 304:8,14 306:22

310:6 320:17

massage 394:16

massive 20:16 176:14

master 240:4

master's 18:2

mastitis 389:6,14

mat 226:10 227:9

material 24:5,11 35:20

40:7,14 42:3 43:6

49:21 50:18 51:3 63:6

75:1,4 76:3 78:21

79:2 92:14 96:5 97:4

114:3 146:15 154:6,9

157:3 158:3,13,16

159:13 175:3,5

212:15 236:17 237:8

237:10 238:9,11

240:5,9 278:21 280:7

280:16 282:18 283:22

285:4,10 287:6 288:3

288:15 289:7,20

290:1,5,15 292:5

293:17,20 294:5

295:6 298:8 301:7

303:9 317:18 319:19

323:1 333:9,10

334:20,22 337:12,21

338:10,11 347:6,19

351:2 366:15 368:3

368:13,16 369:21,22

381:6 386:22 390:19

392:18,20

materials 2:5 3:3 4:7

5:3 13:5 37:16 38:15

38:15,17,20 39:1,4,6

39:8,17 49:3 74:19,20

75:6,10,19 76:12

78:13 81:9 85:2,5,9

91:17 95:5 96:22 97:7

97:9,14 98:22 110:14

110:21 113:17 129:22

153:11,16 154:4

155:3,13,15,19

157:22 158:11 160:1

161:4 163:8 164:2

167:2 171:21 233:16

233:19,21 258:18

266:13 278:12,15

287:9,13,21 302:6

317:3,13 318:6,14

320:2,7 325:10

335:20 345:19,21

348:9 350:16,17

353:14,16,22 354:3,7

356:17 358:2 359:5

366:4,16 367:7,12

368:14 369:2,3,19,20

371:21 372:4 373:7,8

373:11,12 374:8,8,14

374:17 375:11,13,18

376:1,5 377:3 382:19

386:17 387:2,4,10,18

387:19 388:13

math 217:14

matrix 432:6,14,14

matter 9:13 116:21

134:2 140:4 144:19

145:4 147:8 148:17

149:6 150:15 152:15

205:4 207:6,14

215:21 216:4,7 218:2

226:8 227:5 232:10

272:9,11 386:3 444:8

Matthews 203:11

maturity 223:16

maximum 287:15 336:4

387:13

McEvoy 2:5 35:7

115:17 139:3,12

167:22 350:8 374:1

383:4 384:5 411:14

414:13 423:20 426:13

442:1

McMillan 3:1 100:12

107:17,17 110:6,9

meal 220:16

meals 275:22

mean 33:12 40:19

44:11,19 46:14 67:5

68:15 72:16 74:5

82:16 105:7,12,19

106:11,16 122:6,16

138:17 149:14 151:19

175:18,21 177:8,10

177:15 196:16,16

199:6 200:3,10,13

201:1 225:7 229:12

229:14,17,19 231:4

231:17,22 232:1

238:13 244:10,12,16

253:14 273:20 296:1

296:9 305:4 315:14

316:17 319:22 321:7

330:7,14 338:21

349:4 350:22 371:1

378:14 382:10 403:21

408:19 410:18 422:18

426:10 439:18

meaning 71:22 126:5

131:18 144:6 248:21

meaningful 109:22

means 35:22 71:9
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

473

94:10 124:13 148:20

177:16 179:13 193:17

193:19 269:13 305:7

327:22 411:19

meant 77:13 228:3

408:16

measure 33:4,8 40:12

40:18 252:18 358:1

measured 40:15 210:21

259:21

measurement 48:10

measures 162:2,10,12

164:17 166:22 172:6

247:3 250:10,15

376:20

measuring 211:11

357:20

meat 109:17 303:15,16

304:22 307:2 395:15

396:8

mechanical 237:5

mechanics 257:15

mechanism 76:5

mechanisms 436:22

437:6

media 29:14,17 70:3

124:5,6 129:19 130:4

130:20 131:18 136:4

137:1 147:15 149:21

164:4,8,20 219:7

242:3

mediating 432:19

medical 329:11 330:17

387:8

Medicare 329:9,16

medications 404:3,5

medicine 396:3

medium 28:12,13 70:2

86:18 242:3 244:14

245:2 422:3

mediums 87:5,6

meet 35:11 59:11,18

69:18 70:14 73:11

93:2 104:20 137:17

137:18 148:10 150:21

151:4,12 152:1,3

155:17 173:2 237:10

242:11 325:1,9

355:18

meeting 1:5 6:4 25:9

78:19 88:19 89:15

97:1 104:20 126:22

140:19 160:20 161:1

163:21 188:8 193:21

256:10,11 259:9

261:5 265:16 266:1

278:1,2,17 280:11

311:22 323:11 334:21

362:7 374:5 384:17

413:17 437:17 443:11

meetings 9:10 11:14

70:9 99:8 141:10

Melody 3:2 51:14 57:13

57:15,17 61:1

Melody's 51:15

melons 13:13

member 7:7 18:13

21:19 88:5 123:10

143:1 185:4 261:3

319:5 356:14 385:12

443:15

members 58:2 79:21

88:10 96:21 97:20

98:1,8 100:3 110:19

114:21 139:16 149:3

153:14 154:10 155:4

171:13 187:3 189:7

197:19 205:8,9,14

213:21 215:1 258:3,6

261:14 265:4 379:14

386:6,9 429:2 441:20

441:21 442:2,4,11

443:5,14,21

membership 247:11

memo 9:7,7 11:11,11

172:18 212:19

mention 112:6 366:22

368:1 393:2

mentioned 21:17 47:5

58:8 84:13 103:22

113:22 114:15 138:18

139:5 156:8 199:18

209:11 221:9,18

227:17 234:11 251:6

365:21 372:1 375:12

375:20 376:1,6

382:18 394:3,4

396:21

mere 277:19 385:19

Merell 157:14

Mesh 3:1 179:14 189:17

193:7 202:1,3,3,12

message 27:6 70:16

344:12

messaging 155:18

met 1:9 105:5 106:8

199:17 207:3 212:11

246:6 417:10

metabolite 320:5,5

metal 155:22

metals 36:5,7

Methionine 323:22

326:10 330:5 333:3

method 33:20 49:13,15

49:16 63:20 65:5,16

65:19 66:10 74:7

142:3 191:18 194:19

228:17 269:8 271:3

271:14 285:1 303:17

335:4 337:2,10,21

350:15 425:21,22

methodology 87:1,9

methods 13:9 14:7 26:7

28:6,11 29:7 59:18

60:1 63:10 72:20 74:6

80:21 98:13 115:21

116:5 129:12 140:20

195:16 227:18 269:10

269:11 270:1,2,17,18

337:3 339:18,22

345:20 350:16 358:16

methoxy 318:18,19,21

318:22

methoxyl 318:11

Mexico 71:1 151:10

206:2 209:1

Meyer 3:2 51:14 57:13

57:17,18 61:2,7

mic 88:16 342:15

Michael 2:16 3:4 140:8

142:18,19,21 268:22

269:1,3

Michelle 2:2 17:15

107:13 140:1 179:18

205:15,15 211:16

232:15 240:12 268:18

268:19 332:20 341:9

microbe 227:7

microbes 41:12 146:21

150:16 207:15 233:6

microbial 215:16,22

285:18

microbiologist 33:15

38:5 240:2

microbiology 33:21

145:14

microenvironment

150:7,8

microgreens 128:7

micronutrients 97:8

microorganism 239:4

microorganisms 42:14

388:2,4

microphone 32:12 33:6

301:3

Mid-Atlantic 110:16

180:5

middle 39:7 209:16

221:14

Midwest 2:7 100:15

133:16

Mike 139:22 264:19

269:1 273:3

Miles 2:5 35:7 114:21

123:11 350:7 351:10

383:1 384:4 411:13

412:19 414:12 417:21

423:15,15 426:16,19

429:5 441:22 443:12

Miles's 132:14

milk 266:12,14,15,19

267:3 276:15 284:12

299:5,16 392:7,19,19

395:17 396:10 407:6

milking 390:3,4

millennial 272:4

milligram 336:7

milling 280:2 281:8

million 107:22 263:5

mimic 45:17

mimicking 270:7

mind 128:1 131:7 171:5

204:4,5 299:4 399:22

440:11

minds 233:9

mine 276:15 283:13

284:8 298:19

mineral 29:22 32:1 33:9

mineralization 48:11,14

minerals 324:8,16

326:1,5

minimal 272:14 390:20

392:17

minimize 116:22

272:19

minimizes 12:1 113:18

116:16,19

minimizing 398:2

minimum 12:6 19:6,8,9

213:7,8 256:17

mining 280:1 281:7,17

282:18,22

Minnesota 390:1

minority 410:3

minute 6:15 8:1 139:17

minutes 6:22 7:1 33:2

36:19 63:19 66:14

139:14,17 249:13

250:20 385:19 441:12

444:3

minutiae 201:13

Mirenda 3:3 146:2

153:9,10 156:13

157:11,15,17 158:3

159:7,11

mis-assessing 308:15

misinformation 70:10

267:10

misinterpreted 101:12

215:14

missed 258:15 274:15

275:9 282:4
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

474

missing 196:18 217:21

mission 85:21

mistake 362:22

mistakenly 275:14

mistakes 35:1 308:15

misting 209:15

misunderstanding 68:4

267:6

misunderstood 177:8

234:16

misused 275:13

mix 97:14 135:10

149:22 229:16 230:1

302:18 344:12

mixed 284:19 344:17

mixes 216:19 220:9

mixture 39:12,15 48:19

50:6,21 222:13

mixtures 210:1

model 417:8,11 434:3

moderate 190:6

moderation 60:11

modern 64:21 270:11

337:4 355:4

modification 63:6

modifications 247:18

modified 286:21 346:11

modify 269:11

modifying 269:16

module 56:16

mold 284:16

molecular 62:9

molecule 41:11

molecules 266:17

Molina 3:4 139:22

264:19 268:22 269:3

269:3 273:2,16

moment 61:10 175:2

205:12 258:7 265:1

278:2

money 71:5 73:9 259:6

monitored 427:17

monitoring 359:19

407:20 428:1

monopoly 338:8

Monsanto's 275:6

months 49:12 129:18

141:8 148:21 150:2

164:2 389:21 393:16

406:17

moratorium 141:17

morning 8:6 14:14,15

16:3 38:2,3 41:3

61:16 69:10 74:13

88:9 110:13 117:19

146:5 160:7 179:22

183:19 186:22 189:19

193:8 234:11 301:10

444:1

MORTENSEN 1:16 16:3

16:7 17:4 95:14 96:7

150:19 151:16 239:19

302:14 304:6,20

306:7 332:7 333:15

339:6 340:18 342:1

352:14 358:7,9

359:11 360:18 365:3

378:19 403:9 404:8

404:21 405:3 419:11

432:1

MOSA 2:8,13 3:8,13

100:14,16,19 101:1,9

101:16 102:5 103:8

160:9 162:20 163:19

167:15 187:2,16

188:1 190:1 192:16

MOSA's 188:9,19

moss 146:20 221:22

231:18 242:3

MOSSO 1:17 214:12,14

214:22 279:13 280:21

282:12 298:6 332:5

333:13 340:16 341:21

353:4 361:8 365:1

372:19 382:22 383:12

419:9

mother 42:3

motion 331:2,10,11

333:1,2,2,4 334:4

340:8,10,12 341:8,10

341:10,11,13,17

342:21 351:18 352:7

352:10 360:8,12,13

361:20 364:1,5,7

365:5 418:8,11,15,18

motioned 331:13

motions 419:14

motivation 75:17

Mountain 18:15 444:4

mouth 141:3 390:7

move 17:17 32:6 51:6

54:10 56:8 139:22

144:18 226:15 240:14

259:12 273:13 280:15

282:1 283:7 284:3

286:14 289:1 316:21

322:16 330:21 340:5

351:15 357:4 360:5

363:19 373:12 384:14

409:2 417:5

moved 195:13 290:2

417:7

movement 18:19 20:16

21:13 58:15,16,19

59:7,20 130:19 174:7

242:11 336:11 339:10

381:10 435:11,12

moving 14:2 18:10

192:20 285:16 291:2

293:3 300:9 310:9

334:5 342:22 344:14

353:8 361:11,22

395:2 397:6 401:9

411:11 428:20 441:19

442:6 443:21

mow 24:7

Moxidectin 406:15

MRO 36:10,14

MROs 35:18,22 156:2

159:2 350:9,21

muddies 36:11

mulch 8:22 9:3,6,8 11:4

11:7,10,12,21 12:3,4

13:16,18 14:17 15:19

38:9 39:10,16 41:19

50:2 60:7 172:13,16

172:17 173:6,9

174:12 176:1,18

212:9,10,17,20

213:10,17,20 214:19

233:4 234:2,9 235:12

236:4 237:1

mulches 172:19 173:1

multi-generational

102:11

multiple 99:14 105:20

149:12,15 201:8

262:7 267:8

multiplication 65:14

multiply 47:18

multistory 440:3

Munger 85:20 86:1

muscle 396:2

mushrooms 134:9,14

134:17,20 135:9,19

mycorrhizae 149:20

N

nail 438:1

name 7:6 8:10,12 10:14

17:21,22 26:1 34:4,5

37:21 51:16 57:15,16

61:10,12,13 69:8,11

74:11,14 79:15 85:15

85:18 88:1,3 91:8,11

96:10,12 100:13

107:16 110:12,13

117:12,13 123:8,9

134:3 140:9 142:19

146:3,6 153:8 160:5,6

160:7 168:20 171:2,6

179:20,22 183:10,11

186:22 189:20 193:8

202:3 205:19,21

212:2 215:7 232:22

240:22 246:7 254:5,6

257:22 261:11 264:20

264:21 269:2 274:5

338:16

names 179:14 355:4

naming 95:2

narrative 198:19

narrow 220:6,6 324:21

354:14 381:17

narrowly 354:12

nation 20:17 29:8 321:8

nation's 189:8

national 1:3 2:2,3,3,4,5

4:13,14 18:14 21:18

78:13 80:9,11 81:14

83:2,13 90:8,12

109:11 136:16 149:4

155:17 158:1 167:3

175:4 187:3 189:4

212:9 265:1,2,17

266:3 267:12 274:14

275:1 279:2,22 287:5

294:7 300:12,17

323:5 324:7,19

325:10 334:13 337:12

353:16 354:7 355:12

357:7 367:1 386:19

389:8 390:20 392:16

398:4,7 401:6 442:14

443:5

nations 145:11

nationwide 107:22

native 5:17 52:1 76:16

145:9 190:2 192:17

192:19 262:12,14

263:8 264:11 356:3

419:18 423:4 424:2

424:14 426:11 428:21

430:12,16 435:14

436:5 439:7,21 441:4

natural 22:5 42:13

44:13 48:2 59:15,21

77:2 84:19 86:8 114:6

127:7 144:14 147:13

155:10 228:9 257:9

259:10 264:14 269:14

279:14 280:22 284:18

285:1 301:6 345:16

384:7 397:19 420:4

438:17

naturally 327:9 392:2

394:15

nature 34:20 46:6 74:1

92:14 191:12 208:12

264:3 270:9,21

422:10

Nature's 323:2
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

475

Naturipe 86:2

navigate 220:19 221:4

near 66:7 88:21 151:19

173:1 184:2 435:13

Nebraska 430:16

necessarily 177:7

196:19 245:2 316:11

necessary 25:5 28:7

56:20 112:3,3 155:9

213:4 217:1 325:13

376:20 393:20 399:18

410:5 414:19,20

necessitate 111:9

need 6:14 13:21 14:1

15:1 20:14 25:11,11

29:2 32:6,18 42:5

44:8 60:18 77:9 81:13

97:4,11,13 102:18

125:14 135:12,18

139:22 141:5 147:10

158:7 166:22 178:8

206:9 216:14 217:4,6

217:7 221:18 223:14

227:13 230:14 231:21

236:15 237:15 238:22

239:1,1,1 240:14

246:21 255:20 257:11

272:6 275:4,4,5,21

277:6 288:17 290:13

297:13 307:10 315:10

315:16 316:1,3 321:1

322:5 338:6 344:15

379:21 382:15,20

399:22 402:7 405:11

405:16 408:19 410:13

410:20 411:3 412:3

418:2 423:5 426:6

431:17,20 432:2,21

435:7,19 438:20

440:6

needed 7:2 24:21 39:15

83:5 89:7,19 113:6

163:3 242:8 255:3

259:21 275:19 303:9

315:3 355:17 391:4

404:2,4 408:17 410:1

411:10 416:6 417:6

needing 338:5

needle 259:12

needs 23:13 32:4 43:12

56:18 161:8 164:11

167:3 213:8,17

216:16 220:13 251:4

256:21 297:20 376:7

382:18 400:1 412:17

negative 9:4 11:7 40:22

45:14 46:9,21 93:11

98:7 313:18

negotiated 253:20

Neither 18:21

nematodes 105:18

149:13,17

net 27:21 169:15

Netherlands 434:12

network 219:12 220:2

neutralizer 284:11

never 15:10 20:11

40:21 45:1 46:9,10

48:1 170:18 258:15

277:11 309:17 416:10

416:12 429:11,20

430:17 440:1,2

new 10:21 18:11 58:2

70:19 71:1 79:21

88:10 92:7 125:14

152:1 153:13 161:7

163:1 191:9 192:18

202:18 206:9 208:9

215:13 224:9 258:6

263:16 265:4,6

281:18 283:2 294:14

300:12 308:13 312:2

385:11 397:7 431:11

431:14 441:20,20

442:2,3,11 443:5,14

443:15,20

newcomer 304:6

NGOs 79:19

nice 316:14

nicest 145:2

Nicole 2:11 168:19

170:22 171:1,4

night 297:7

nine 90:1,21 139:17

266:20 311:22 353:15

354:6 394:3 441:12

nine-day 156:19

nine-year-old 200:7

Ninety 403:12

Ninety-five 327:5

nitrate 145:14,15

nitrogen 4:5 35:4 208:6

209:5 232:7 282:2

283:8,10,13,20

no- 126:22

no-till 126:10 127:3

NOC 393:13

nodosum 92:22

NOFA 2:11 171:8

172:13

nomenclature 83:15

non 138:4 241:20

non- 76:5 84:19 111:11

134:20 276:3 279:2

340:8

non-ag 112:5 292:10

non-agricultural

258:19 331:3,12

354:5

non-amidated 4:11

317:4,10 318:20

non-answer 425:14

non-chemist 319:4

non-degradable 38:22

non-GMO 260:6,8

347:7 348:1,7,11,17

348:19 349:17

non-living 63:3

non-milk 77:11,14

non-organic 90:7

111:19 115:22 124:2

164:6,8,17 181:4

260:6 279:3 292:14

292:22 301:14 302:3

315:21 318:14 320:4

376:21 391:6 392:5,8

non-organically 300:13

304:9 316:3

non-soil 135:9

non-stable 216:7

non-synthetic 89:5

111:3,12,14,20

112:10,12 258:18

289:20 290:2 292:6

397:19

non-synthetically

290:6

non-synthetics 279:7

non-viable 63:3

nonagricultural 345:16

noncompliance 187:17

noncompliant 181:6

nonprofit 153:14

nonsynthetic 158:5,9

343:13,18 344:1,3,7

345:2,7

nonsynthetics 343:19

noodles 310:21 311:1

311:11,15 315:20

NOP 9:6 11:10 26:11

28:5,17 29:4 34:16

35:9,12,16,21 36:9

53:6,12,22 54:8,9,10

54:16 57:5 64:4 92:17

93:13 115:16,19

122:17 123:12 124:19

125:3,9,13,22 137:4

141:17 156:3 161:19

167:14 172:18,21

184:9,12 188:10

189:6 192:8 212:19

217:9 254:20 258:3

261:14 263:16 291:10

323:11 324:13 334:15

354:2 366:7 370:7

373:18 383:10,16

392:11 395:12 396:4

413:12 423:22

NOP's 34:17 35:22 70:7

167:20 265:16

NOP-authorized 35:20

Nope 342:7

NOPs 378:7 383:1

normal 88:11

normally 104:22

Norman 3:4 8:6,12,13

9:21 10:2,5,8,16,16

14:10,15,19 15:5,18

16:6,9 17:6,8

north 57:22 151:7

284:17 444:5

northeast 15:13 304:22

432:3

northern 148:22 241:6

389:18 390:1

Northwest 143:12

NOSB 2:2 6:4 9:5,10

11:9,14 25:7 28:16

35:18 37:3 53:5 54:8

60:10 70:13 75:10

76:4 77:5 88:6,18

91:17 92:17 93:13

96:17 98:16 108:11

109:8,14,15,22

114:13 125:12 140:18

154:9 158:11 160:15

161:3 163:1 171:13

173:4,21 183:15

188:10 189:7 190:15

192:8 193:21 212:10

254:19 258:2,6,14

261:14 263:16 264:2

265:15,21 274:8

285:11 287:6 318:18

324:4 326:7,9 353:14

380:11 420:1 442:16

NOSB's 99:6 191:3

212:5

nose 328:18

notable 80:8

note 97:13 139:19

194:15 277:2,5 278:5

289:5 311:10 315:17

318:12 347:12 359:4

366:7

noted 79:4 141:2

245:18 263:4 278:7

280:9 281:14 312:11

313:15 353:15 354:19

355:2,7,10,17 356:8

notes 313:17 344:16

notice 89:3 92:20
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

476

442:18

noticed 225:2 318:17

318:20

noting 354:13 355:4

notion 378:9

November 199:10

noxious 375:18

NRCS 433:19 438:17

NS 2:15 193:9

NSOB 86:9

nuanced 55:10

nucleic 64:22 270:12

270:14 337:5

number 65:3 82:19 97:9

109:12 132:22 136:5

136:8 170:2 183:22

222:1 230:15,18

283:19 304:7 310:13

337:8 339:8 354:11

356:7 362:21 366:8

366:19,20 371:16,22

378:8 395:4 404:11

414:14 440:9

numbers 122:3 230:20

305:20

numbs 400:21 401:21

numerous 80:4 82:17

93:6 348:19 356:22

389:7 390:1 429:18

429:18

nursery 219:18

nurture 204:9 265:6

nutrient 27:19 31:14

32:3 216:1 217:7,21

219:8,8 223:13

324:16

nutrients 19:20 23:3,11

26:8 29:19 30:20

69:21 99:12,13

131:12,17 146:22

147:12 150:5 177:7

209:6 218:7 219:5

266:18 324:8 326:4

nutrition 31:8 194:18

201:16,18 216:8

218:4,13 223:8

265:13 275:21 329:7

nutritional 324:5 325:1

335:14

nutritionally 323:17,20

nutritionist 299:12

nutritions 235:7

nutritious 27:4,14

O

OAKLEY 1:17 21:17

31:11 32:7 94:4,21

103:21 104:6 120:14

122:20 156:6 157:7

157:13,16 174:10

175:8 197:17 209:11

221:6 222:20 224:2

288:14 295:2,16

314:18 328:9 332:15

333:22 341:3 342:8

352:21 357:12 358:19

360:10 361:3 364:18

372:11 380:7 403:1

405:14 419:4 423:14

425:17 435:10

objection 90:9 184:19

184:20 441:18 443:21

observing 417:4

obstacles 440:20

obtain 74:22 112:17

175:7 320:17 336:4

372:7

obtuse 200:1

obvious 255:22

obviously 55:2 69:11

78:5 172:21 201:2

225:8 229:19 295:17

298:15 398:20 408:5

420:10

OCA 263:20

occur 113:14 162:5

270:21 295:19

occurred 9:12 11:16

occurrence 248:3

391:11

occurring 48:2

occurs 432:4

October 266:1 334:9

oddly 308:17

odds 191:6

off-the- 66:15

offer 47:12 51:9 86:7

101:4 149:5 196:15

255:2 259:5

offering 86:2 266:9

offers 101:22

Office 444:4

offices 374:16

official 383:16

officially 74:3

Officials 247:10

offline 106:1

OFPA 19:1,8,13,17 20:7

20:18 29:4 35:22 93:3

93:19 125:11,13,15

125:18 126:4,11,13

131:6 134:10,12

135:10 138:4,4,4,7,10

138:12 139:1 155:12

158:12 216:21 374:7

378:1 423:16 429:4

oh 29:12 32:13 37:17

69:1 115:13 178:8

186:8 198:18 243:18

257:17 274:12 282:4

321:15 322:21 331:5

352:2 358:8 361:15

363:9 365:16

oil 67:16 75:13,14

111:14 115:9 280:9

281:6 283:4 327:7

336:3 344:10 346:9

346:17 348:9 372:3

376:6

oil-free 283:10

oils 111:3 112:4 115:2,2

115:4,9 179:1 279:11

279:21 346:11

okay 17:4 30:5 33:19,22

41:14 47:20 49:19

81:5,9 84:9 89:22

96:7 100:1 104:6,19

112:14 126:9 130:18

130:21 139:12,13

140:7 153:9 157:16

179:7 186:12 198:18

199:12 204:21 211:5

211:18,21 214:4

221:17 238:5 239:6

240:16 244:8 268:20

306:7 319:22 323:15

329:22 330:20 338:2

343:7,10 351:21

352:3,6 360:11

363:17 365:18 386:11

386:14 387:6,17

390:19 392:1 393:9

395:1 400:9,18

401:19 405:3 406:4

406:13 409:1 419:21

426:16 435:6 438:15

440:8 442:1 443:12

okra 309:15,19

old 70:21

older 193:2

oligofructose 268:6,7

olive 336:3

OLPP 410:4,12

Olympic-sized 63:1

OMI 36:18

OMRI 35:14,15,15 36:2

36:16 95:8 153:10,13

153:14,20 154:1,8

155:2,14,22 156:1,2

157:21 159:15 212:21

213:9 349:3

OMRI's 153:19 154:7

OMRI- 132:11

OMRY 234:15

on-deck 8:7

on-farm 299:12

on-sight 415:19

once 20:5 23:14 71:8

82:22 83:8 135:2

150:9 158:3 235:19

251:15 288:8 290:4

328:7 377:12 401:20

one-year 46:2

OneCert 3:17 123:10

134:8

ones 135:15 201:11

208:1

ongoing 163:1 187:9

256:20 257:10

onset 400:20

Ontario 146:8

OP 262:18

opaque 35:14

open 81:15 107:13

147:14 211:16 227:10

229:15 240:12 279:15

280:1 281:7 327:15

330:5 337:18 346:4

350:5 358:3 370:5

381:7 408:21 409:18

409:20 429:3 436:20

opened 255:1

opening 363:8 379:10

379:17,19

opens 365:21 409:21

operated 8:14 10:18

operating 52:20 104:1

operation 77:3 132:2

143:18,19 164:7,13

164:14,22 181:18

183:14 220:1,12

252:12 253:6,14

257:9 322:7 376:19

operations 2:18 19:4

20:11 57:7 77:18

98:11 99:8 101:14

104:3 110:16 123:13

127:1,11 132:17

133:3,18 148:12

153:22 160:10,11

162:20 180:5 188:2,3

190:1 192:18 204:9

228:14 248:15 305:15

312:16 391:2,6

397:22 399:19

operator 112:9 124:13

181:1,21 250:8

253:14,20

operator's 252:6

operators 74:21 75:21

76:9 112:8 252:10

operators' 190:5
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Neal R. Gross and Co., Inc.

477

opined 275:15

opinion 50:12 84:21

93:2 110:4 137:18

166:9 295:11,12

305:11 409:11

opinions 11:18 93:16

117:22 149:5

opportunities 148:16

257:8 398:18 439:1

opportunity 20:19

61:15 64:10 74:5

91:19 128:17 140:15

141:6 142:13 143:3

149:5 160:14 171:15

201:7 215:10 233:3

241:2 254:17 265:15

303:21 322:6

opposed 33:4,9 114:4

183:2 260:17 273:10

327:13

opposing 291:19

opposite 188:20 322:4

427:13

opposition 118:4

281:10 283:21

optimal 239:13

optimistic 277:21

optimize 49:16

optimizing 235:21

opting 109:13

option 13:21 59:1

204:14 221:1,1

275:22 302:22

options 429:1

OPWC 96:21 97:18 98:3

100:3

oral 395:7

orchards 434:21

order 7:2 8:22 10:12

11:4 25:5 31:22 32:4

32:16,19 178:9

206:15 255:21 257:6

273:6 297:21 304:17

380:10 395:7,13

396:5 420:14 434:20

ore 284:18

Oregon 143:1

organic 1:3 2:2,3,4,6,7

2:9,11,12,20,21 3:1,3

3:7,9,10,20 5:9,17

12:14,17 13:1,4,7,19

13:20 14:5 15:6,15,16

18:6,11,16,18,22 19:3

19:12,18,20 20:1,7,8

20:21 21:5,13 22:3,11

22:16,19 23:2 24:14

24:16 25:6 26:5,6,7

26:10,12,14,21,21

27:2,3,7,16 28:1,2,3,5

28:6,10,17,18,20,22

29:2,7,8,19,20 34:7

34:12 35:10,12 36:3

40:14 43:20 44:4

45:17 51:18,21 52:1

54:9 57:20,21 58:1,9

58:15,21 59:5,9,10,20

60:5,6,14,15,19,20,21

62:3,10,10,14 63:7,13

63:14,15 64:9,12

67:16 69:13,16,18

70:14,15 71:5,8,11,13

71:16,18 72:21 73:2,3

73:7,12,13,21 74:15

76:1,6,8,15,16 77:8

79:19 80:2,10,20 81:3

81:5,12,16,20 82:15

83:3,4,8,20 86:2,4

87:11,16 88:22 90:10

90:14,17 91:1,18 92:1

92:9,15 94:14 96:13

96:15 97:21 99:1,3

100:20,22 101:19,21

102:3 103:1,12

104:22 106:20 108:7

108:20 109:4,11

110:15 111:4,17,21

115:10,21 117:16,18

117:21 118:22 119:3

119:5,7,16,19,22

120:3,4,6,8 121:12

123:2,13,15,18 124:1

124:2,3,9,11,15 125:1

125:21 126:3,5

127:14 128:5,12

130:9,15 132:16

133:4,6,17,22 134:2,3

134:5,18,21 135:4,7,7

135:14 137:9 138:18

140:12 141:7,9,9,12

141:19 142:8 143:6

143:19 144:5,11,16

144:18,19 145:4,6,13

146:9,10,11 148:3,8

148:10,12 149:1,4

150:15 152:2,8 153:3

153:10,17 154:10

155:6,11,19,20

158:16 159:21 160:16

160:17 161:17,21

162:10 163:22 164:7

164:13,14,19,21

168:19 169:12,17,18

170:4,5,13 171:8,9,10

171:12 172:14 173:15

174:7,19 176:15

180:2,10 181:2 182:5

183:13 184:11,17

185:5 187:2,3 188:5

188:10,17 189:2,5,12

190:3,4,9,12,14,16,17

190:19 191:3,4,8

192:1,2,4 193:10,16

194:5,9,14,18,22

195:22 196:20,21

198:13,14 202:4

203:3,15 206:12,16

207:2,5,6,10,12,14,18

207:20,22 208:3,6,7

209:6 215:21 216:4,7

218:1 220:2,20 224:4

224:16 225:19 227:5

233:20 235:5,10

241:4,10,11,15,18,20

242:2,4,11,12,13,19

243:2,21 244:2 245:9

245:13,14 248:10,16

249:17 250:7,15

253:12 258:2,5,9,12

259:10,13,15 260:17

260:18 261:13,14,15

261:22 262:2,14,17

262:18 263:14 264:1

264:6,9 265:2,2,8,10

265:20 266:5,8,11,21

267:2,14 268:10

269:6 271:14 272:7,7

274:7,12 275:5,22

276:5,11 279:5,5

284:14 289:11 292:2

293:1 296:16,17

297:15 299:5,7,8

300:15,19 301:13,20

302:9 303:10,15,18

303:22 304:22 305:9

305:14 306:5,16,19

306:20 307:19 308:4

308:5,18 310:7

311:17,20 312:3,11

312:17 313:1,5,10,14

314:5,9 315:20,22

316:11 317:17,20,21

317:22 318:5,7

320:17 321:13,19

322:7 323:6,18,19

324:6,7,9,22 325:11

325:11,14 326:15

327:2,4,5,11,15,17,18

327:21 330:6,18

335:20 336:18,20

337:16 338:17,22

339:1 343:14 344:2

345:8,15 347:22

354:3 355:14,22

366:16 367:4 368:14

368:16 369:6,10

371:5 372:9 374:21

376:19,21,22 378:12

378:16 379:15 381:22

382:9 384:7 386:20

389:9 391:2 392:19

393:1,11,18 394:2,8

399:19 406:11 407:4

408:1 411:15 415:6,7

415:13 416:4 419:18

420:14,21 421:10,14

421:18 422:2 423:9

424:3,22 428:14,17

429:15 430:3 431:1,2

434:22 435:12 436:6

437:8,15,15 442:14

443:5

organic's 275:7

organically 8:18 9:2

10:22 11:6 28:14

100:6 141:21 202:18

203:9 242:8 243:10

244:6 305:2 309:14

369:6 421:3

organics 19:9 20:10,15

20:18 25:16 72:9,10

72:15 118:10,13

119:1,12 120:10

196:4,5 212:6,12

224:14 229:2 245:19

274:15,16 335:3

organics' 276:7

organisms 40:4,6,14

42:15,18,21 43:14

45:4,7 47:11 215:16

227:9 269:12,16

288:5

organization 74:4

153:14 235:10 285:6

312:20 313:5

organizations 155:13

247:9 309:5 315:15

347:7 435:4

organized 198:21

origin 314:15 379:22

383:22

original 9:9 11:13 18:18

59:20 94:21 95:1

107:3 242:10

originally 43:7 187:6

247:18

originating 285:1

Ortega 3:5 179:15

205:11,18,21,22

208:22 209:21 210:11

210:16 211:4,7,18,21

221:6

OSP 104:20 138:13
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Neal R. Gross and Co., Inc.

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OTA 89:9 260:16

outbreak 162:3

outbreaks 63:13 162:15

outcome 47:5 254:11

outcomes 366:20

outdated 72:17 414:6

outdoor 19:5 108:20,21

108:21

outdoors 253:16

outermost 59:8

outline 182:2

outlined 6:12 254:16,19

outlines 28:7

outputs 71:19

outreach 76:8

outside 37:15 159:14

242:21 288:16 437:14

440:17

outskirts 148:7

outstanding 109:12

over- 177:21

over-application

217:19

over-audited 217:15

over-complicate

178:13

overall 13:22 119:16

197:1,7,11,22 206:7

224:10 229:6

overburdened 217:16

overcrowding 108:16

overlap 353:16

overlaps 216:10

overlooked 76:21

overly 81:11 95:4

oversight 35:15 417:7

overuse 392:7

overwhelming 381:16

overwhelmingly 195:20

owner 88:4 307:22

owners 438:19

ownership 437:3

OWS 235:10

oxidation 283:14

oxygen 222:8 231:6

239:22 283:13

oxymoron 134:5

oxytocin 5:5 110:5,5

391:16,18 392:1,2,8

394:15,20

ozone-depleting

283:18

P

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

6:1

p.m 205:6 386:4,5

444:9

Pacific 143:12

package 89:17

packaged 244:6

packaging 4:18 244:1

260:13,18 283:15

286:21 335:10 366:4

366:15 367:7,11

368:14,16 369:20,22

373:7,8,11,21 374:8

374:12,14 377:3,17

382:1,5,18

packed 242:14 433:6

packing 369:1

pages 80:4

pain 108:10

painful 108:9,13,18

109:3

pair 63:4 65:11,13

pairs 269:20

palm 317:11

paper 169:5,6 199:1

243:22 271:22 273:22

paper- 67:3 273:16

paper-based 273:10

paperless 257:15

papers 210:20 256:12

paperwork 67:12 75:21

paragraph 279:7

280:18 285:16 387:7

388:16 390:17 391:18

397:8,8 400:12

parallel 273:17,21

parameters 182:3

248:19 252:1

paraphrasing 248:1

parasite 161:20 250:2

parasites 162:7,12

parasiticide 161:9

166:20 182:3,17

183:3 397:9 408:9

parasiticides 5:9

161:10,15 165:13

166:9 171:18,20

182:4,9 246:15

247:18,22 248:9

406:11 407:19 408:3

408:19

parcel 102:10

parent 266:6

parentheses 77:12

287:17

part 7:14 11:22 12:2

18:19 42:1,22 50:11

54:21 55:21,21 56:2,2

57:10 73:5 82:11 93:4

104:14 105:2,9

106:13,15 115:7

116:2 122:7 127:2

132:15 138:13 163:1

164:8 184:21 242:6

253:13 270:22 272:4

318:1 319:16 321:6

337:5 339:19 375:2

381:8,13 384:3,10

395:9,11 401:12

419:22 421:11 424:2

442:17,18

partially 46:18 267:5

participate 373:1

participated 317:14

participating 424:22

participation 256:7,8

particles 238:16

particular 97:13 99:11

100:8 102:10 215:13

219:4 226:10 229:5

240:5 305:6 323:12

particularly 75:22 97:7

109:16 207:22 312:6

354:20 368:2 370:9

375:6

partner 85:19 298:21

partnering 434:4 435:3

partners 47:10 67:14

partnership 154:8

436:20 437:10

partnerships 437:7,22

438:2

parts 39:21 62:22

106:22 138:22

parturition 391:19

393:15

party 272:20

pass 16:12 115:17

234:13 259:8

passed 89:14,16

181:21 325:22 326:8

404:22

passes 333:1 334:4

341:8 361:20 365:5

419:14

passion 80:18 81:22

passionate 143:15

242:17 255:12

pasta 311:3,19 312:7

pasture 162:15 246:19

253:15 421:5

pastures 432:8

Pat 2:21 139:21 257:21

261:10,10,12 264:17

264:18

patchwork 356:22

path 103:9 219:15

pathogenic 288:5 388:2

388:4

pathogens 286:6

389:15

pathologist 18:4

pathology 18:3

paths 438:1

patient 160:18

PAUL 2:4

pause 175:13

pave 22:12

paved 20:21

pay 262:1 274:19

PCO 110:15 112:1,15

113:15 114:10 180:4

180:6,13,20 181:9,22

182:21 394:3

PCR 65:3,16 271:9

337:7

pears 97:16

peat 146:20 215:15

221:22 231:18 242:2

pectin 4:11 316:22

317:4,7,10,14,16,19

318:4,8,10,11 319:5

320:13,16 321:8,14

321:18 322:2,3,7,14

394:17

pectin-containing

317:11

pectins 317:22 318:5

318:19

pediatric 323:18,20

325:8,16 326:12

peel 318:11

peels 304:11 317:12

319:11 320:19

peer 52:11 55:6 185:6

186:16 254:13

peer-reviewed 93:6

peers 55:5

pelleted 130:2 220:11

pellets 220:15

Pennsylvania 2:9 3:9

110:15 180:2

people 7:5 10:11 14:20

16:18 17:17 22:9,16

26:21 60:4 70:19

80:22 95:7 107:9

119:11 120:15,15

127:5 128:15 132:22

135:21 145:9 178:6

183:18 185:14,16

186:18 192:2,19

200:12 204:11 222:17

249:22 268:5 275:2

291:22 296:11 297:1

299:17 306:18 319:2

321:13 330:5,11,17

338:5 359:2 366:1

384:22 399:13 402:20
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percent 60:21 120:1,2,4

120:6 121:13 148:8

172:20 173:2,7 181:2

195:1,14,14 200:12

201:3 203:15 209:19

210:3 212:20 217:12

219:4 221:11 222:5

223:3,6,10 224:4,9,19

226:6 229:13 230:17

231:1 237:10,11,14

264:5 266:20 272:8

325:11 326:20 327:6

432:4,5 439:15

percentage 23:3,10,18

49:20 170:14,15

174:14 177:6 214:1

216:2 217:18 223:21

224:5 230:14

perennial 126:21 131:9

223:19 226:17 227:12

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175:15 179:4

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184:1 235:22 236:6,8

238:1 413:11 415:17

416:11,15 418:9,16

performing 185:5

432:17

period 99:5 108:6

124:12,12 130:16

156:19 160:19 261:1

262:15 374:5 395:16

395:18 396:8,10,15

400:14 401:15 425:11

426:19

periods 247:17 403:11

perishable 307:3

permanent 22:13

permanently 162:6

253:3

permission 35:16 121:3

permits 6:15

permitted 4:15 7:10

285:8 362:2 428:12

peroxide 382:12 389:11

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persistent 59:4 389:16

person 117:16 202:7

413:14 416:16

personal 7:12 52:4

62:12 184:1 200:4

295:11 305:11 308:12

329:3,12

personally 106:7 371:3

385:13

personnel 5:14 413:11

418:9,15

persons 7:5 415:10,18

perspective 79:1

201:17 260:15 424:19

pertaining 182:16

183:2

pertinent 214:9

perverse 427:11

pervert 37:16

pest 144:14 147:16

165:7 166:14 242:6

287:2 407:18 432:11

432:16,19

pesticide 59:4 319:10

320:5 379:6

pesticide-related 369:2

pesticides 194:11

302:5 313:12,15

316:6,10 318:13

394:5

pests 147:17,20 179:3

242:9 432:16

petition 11:17 12:16

61:20 269:19 278:21

310:2 323:3,4,12

324:18 334:6,8,11,14

334:15,21 335:9

398:15

petitioned 110:21 212:8

305:10 309:10 323:2

323:16 324:20 331:11

333:3 341:12 398:13

petitioner 309:13 335:2

337:14 343:4

petitioner's 337:7

petitioners 310:1

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petrochemical 344:6

petroleum 14:21 41:9

41:11 42:3 43:11 44:6

175:20 176:5,13,14

176:20 178:21 214:4

214:15,17,18 233:13

236:16,18 237:8,10

237:14

petroleum-based 14:17

15:4,8 49:21 174:14

pH 284:14

Ph.D 2:3,4 18:2

pharmaceuticals 272:2

phenol 371:18

philosophical 58:18

philosophy 80:20 81:16

phone 66:7 199:2

phosphate 77:10,12

293:11,12,13 294:8

294:19 296:22

phosphates 4:9 293:4,6

293:11,15 294:7,11

phosphoric 293:17

382:12

phosphorous 299:17

phosphorus 25:1

297:12

photo 215:19 443:11

phrase 154:17

physical 108:9,18

109:3,7 327:22

388:21

physiological 403:10

pick 303:3

picked 225:7,8

picking 174:21

picture 235:16 238:13

pie 204:7

piece 175:12 223:8

piece-by-piece 381:17

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44:6 174:21 225:12

259:1 260:12

pile 50:17

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55:14 59:8 94:11,16

102:2 144:13 162:1

162:12 166:13,22

168:9 196:21 237:7

249:5,20 250:1,14

273:7 309:3 370:6

377:14 404:13 406:14

414:3 430:4

placed 369:7

placenta 392:15 393:19

places 44:15 95:15

130:6 165:5 339:16

415:4

plan 77:8 87:14 93:9

105:1 161:22 166:21

179:10 220:5 250:8

250:14,16 253:13,15

408:1

planet 72:7 189:9

planned 162:2 198:13

planning 68:1 433:8,20

434:5,10 435:5

plans 162:1 223:14

plant 18:2,3,4 20:5

23:10,16 31:4,8,9

32:3,4 75:14 92:4

111:3,14 112:4 124:9

134:15 144:16 147:1

152:17 154:13,14

193:17 217:22 232:7

232:10 241:17,20,21

242:2,21 243:9,10

244:6 279:10 299:13

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137:9

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124:15 129:11,20

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136:17,19 137:1,11

163:11,17,21 164:6

164:18,19 249:8

433:22

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28:13 30:17 33:9

40:22 69:19,21 70:2

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102:22 103:5 122:20

124:11,14 135:19

136:2 137:16,22

138:5,16 146:10,19

147:3,11 148:1,13

150:4 151:15 154:18

156:16 158:6 173:22

219:19 224:1,22

227:12 242:19 267:9

439:21

plaque 443:4

plastic 13:16 16:12

44:6 172:17 174:21

176:15,16 225:6,13

226:12 243:22 371:20

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platform 118:20

play 280:21

players 21:11

playing 133:9 188:15

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please 6:19 10:15 19:5

19:7 32:12 33:5 60:8

64:13 89:18,21

105:21 107:12 139:8

141:19 145:19 179:18

205:2 213:13 215:19

234:19 240:17 257:4

409:21

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Neal R. Gross and Co., Inc.

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plenty 206:20 210:14

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point 15:5 19:17 25:15

41:16 42:20 43:15

67:10 117:15 121:5

136:12 141:2 178:22

214:8 239:16 245:16

252:20 253:5 263:18

270:4 292:18 299:19

304:17,17 343:12,21

343:22 349:4 354:9

356:4 371:14 373:14

378:2 383:2,7 399:17

412:21 414:7 437:20

441:1

pointed 94:19 284:13

335:8 337:1 345:4

354:16 356:1 414:9

pointing 380:17

points 140:19 180:8

248:8 325:20 336:10

policies 204:3 383:10

383:20

policy 2:13 6:12,12

57:18 160:8 172:18

212:19 258:13 383:8

383:17 384:1,6,10

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polled 96:21

pollinating 434:22

pollinator 196:15

pollute 147:13 200:15

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poloxalene 167:3

182:18

polyculture 424:17

polyethylene 12:4

15:19 234:12

polymer 40:2,2,10

44:20 45:5 47:12

236:7 237:14

polymer-degrading

45:4

polymerase 270:6

polymers 38:6,7,12

39:13 44:16 50:5,14

175:6 233:5 237:4

polyvinylidene 362:20

pomace 318:12 319:11

ponic 104:1

pool 63:1 224:13 255:4

309:4

poorly 217:17

population 198:8 206:4

206:7 294:12 392:10

435:13 438:7,9

populations 227:8

330:16 359:20

porch 19:5

pork 144:2 301:5

port 64:4

portion 124:21 278:1

327:8 441:11

pose 290:9

posed 246:16 409:20

position 55:6 89:10

103:4 155:2 269:4

367:18

positioned 160:15

positive 54:3 60:19

98:7 185:18

possibility 71:6 103:22

113:9 115:3,8 131:7

374:11 375:16

possible 46:14 48:13

49:22 50:12 51:12

58:19 60:9 82:22

109:10 118:21 131:22

132:18 138:15 146:16

177:15 192:12 201:4

236:13 266:10 269:13

285:5 294:11 314:4

354:1 375:6 438:1

possibly 35:12 157:22

220:19 275:12 307:13

393:14 437:7 439:4

post 25:7 198:20 199:9

199:19 201:11 389:5

390:3 391:19 393:15

post-birthing 392:12

post-planting 174:4

post-term 88:18

posted 291:10 334:14

353:18 362:13

postpone 64:14

pot 129:19 130:4,8

136:19 137:10 150:6

152:22 242:1 243:5

potable 382:10

potassium 4:9 291:2,5

291:13 292:1 293:12

potatoes 13:14 144:1

potential 94:7 98:17

102:20 103:1 133:4

163:5 180:18 182:13

209:12 311:11

potentially 108:8 157:2

302:16 329:13 330:2

346:14 366:21 369:19

426:1 427:16 428:8

pots 146:20 150:12

152:8,8 173:22 227:5

227:6

potted 241:4,10,15

242:13 243:2,9

potting 130:9

poultry 109:5 188:11

189:3 253:17 324:1

411:15

powder 291:16 296:17

297:2,16,21 335:19

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PowerPoint 8:3 9:18

practical 24:16 25:6

180:15 192:7 223:22

255:21

practicality 159:22

practice 93:2 134:19

144:14 235:7 274:13

359:17 368:21 376:18

405:21 407:17 408:18

410:20 427:19 428:10

428:11,13

practices 9:1 11:22

12:20 13:2,5 19:20

20:7 25:5 26:10 28:11

28:20 77:1 81:8 97:15

99:1 100:22 109:5

144:15 183:5 188:11

189:3 190:8 197:8

218:9 220:5 241:7

245:1 283:1 335:5

356:17 411:15 427:2

428:9 431:2,4 432:17

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pragmatic 255:12

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pre 389:5 390:3

pre- 306:18

pre-contracted 306:17

preamble 137:20

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Prebiotics 266:18

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190:22 375:4

precede 190:8

precedent 71:12 163:13

182:13

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440:1

predators 147:20

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223:20

preferable 185:11

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185:5

preference 84:19

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256:12,13

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176:10 407:16

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42:21 60:1 61:16

65:21 66:4 107:21

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443:3

presentation 17:13,15

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210:13 256:12

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441:19

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208:11

President 2:17,20 3:6

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397:15 408:20 427:2

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366:10

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329:1

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392:18

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213:21,22 225:8,20

229:13 253:2 274:21

274:22 314:19 332:18

351:12 366:2 409:9

425:7 430:5 437:15

problem 15:10 20:13

22:2,15 51:1 81:14

140:2 172:22 184:4

200:10 271:16 272:13

297:12 310:5 339:14

339:19 340:3 413:20

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401:3,10,14,19,20

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procedure 172:5

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108:13 388:19 401:5

402:3

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39:19 43:2 44:12,13

46:20 55:13 65:16

66:14,17 116:2

158:10,17 160:18

163:2 164:15 181:20

213:12 214:16 240:3

261:3 270:8 271:1,6

281:11 286:11 288:12

288:17 292:3 299:9

304:7 307:21 320:14

346:18 381:9,16

388:11 414:22 416:1

417:2

processed 279:4

300:15 301:1 303:16

304:10 319:19

processes 169:3

206:18 210:9 231:8

269:14 270:18 285:8

292:9,19

processing 258:12

265:20 279:10 282:17

283:4,14 286:2 287:1

290:11 299:13 301:12

304:12,17 320:18

382:6 390:5

processor 66:13

111:13 143:7 170:1

170:18 313:5

processors 335:17

367:6

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12:2 15:6 27:9 35:7

41:11 60:2 63:5 73:22

75:1 80:22 94:5 96:13

96:15 97:10 98:8

119:3 123:3,4 145:2

148:9,10 151:18

194:10,14,22 198:12

203:9 219:19 241:19

270:20 287:2

produced 92:5 94:13

116:4 169:18 193:10

267:8 282:18 284:17

284:22 290:5 292:14

300:13 304:9 316:19

326:21 327:21 369:6

392:3

producer 38:6 67:2,9

149:19 181:12 219:11

226:6

producers 58:22 81:12

102:5 111:19 119:10

165:11 169:16 171:11

171:12 172:15 182:5

188:16 195:22 221:15

273:8,14 307:18

316:16 336:5,5 394:2

394:3,9 407:1,9

408:14 409:18 421:17

422:18 436:14

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producing 25:3 60:13

206:22 208:10 217:1

product 14:17 39:11

41:22 50:3 66:5 94:13

114:5 131:2 148:21

158:8 159:19 174:14

175:1 176:5,13,14,20

214:5 220:19 226:11

241:12,13 243:1

245:8 270:10,15

271:13 283:14 294:3

298:2 300:19 302:8

307:4 327:4,5,19

338:16,18,18,22

339:2 347:8,22 351:3

369:7 380:19 381:22

382:9 398:12 407:4

411:7

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13:19 16:15 19:6,13

26:20,22 28:3 59:9

60:12,14 77:1 82:15

98:5,12,20 99:1

100:20,22 101:4,7,8

101:13,14,17,18,21

101:22 102:3,15

103:17 117:20 118:5

118:12,14,16,22

119:5 120:2,3,3,5,6,9

123:5 124:15 130:10

138:5 143:14 145:13

146:12 151:3 153:17

155:6,10,20 158:18

161:5 164:8 169:13

173:9 190:3 191:8

206:10 207:21 215:11

215:20 218:19 219:20

224:4 226:3,7 227:20

228:2 229:2 234:21

235:2 251:8 253:4

261:15,16 262:15,19

263:6 264:1,7,8,12

269:6 285:6 289:10

293:21 301:20 302:9

303:22 306:14 309:21

313:10,13,16 317:9

319:15 336:19 337:2

337:16 339:18,22

351:4 354:3 373:11

380:16 386:21 389:9

391:14 392:5,8 393:1

406:12 415:6,13

419:19 420:15,21

421:10,14,18 424:3

424:10,14,16 428:8,9

429:15 438:11 442:22

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productive 99:2 207:4

products 3:6 35:11

36:13 42:13 44:6 46:8

47:21 50:9 63:13 71:7

71:10,14,17 73:2

75:16 77:11,14 81:7

82:21 89:6 91:13 92:7

94:5,17,19 97:11,14

98:1 115:10,21 116:4

123:13,18 132:1,12

144:4 153:19,20

154:13 156:8,16,20

157:2,6 169:6,8,18

170:5 175:20 196:7

197:14 200:22 212:4

212:18 213:11 222:2

229:4 234:22 241:18

242:17 243:8 265:9

267:3 269:7 272:7,10

279:4 281:14 282:16

282:16 284:11 299:9

300:14,15 305:16

308:13,16 311:17

312:8,11 314:8

315:21,22 317:9,20

320:7 323:6 324:9,22

325:10 327:2,12,15

327:17,18 329:8,18

330:6,15,18 335:19

336:2,18,20 348:3,17

348:19,21 349:1

354:15 366:16 372:22

376:21,22 378:3

379:15 397:19 403:17

professional 256:9

324:12

professor 205:22

proficient 255:17

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program 2:2,3,4,6 7:15

52:11 53:4,22 54:6

55:22 89:18 109:11

110:14 126:3 136:11

147:16 168:1 171:8

189:5,10 203:11

222:11,14 242:7

248:16 254:14,20

265:3 324:7 326:1

345:19 383:9,15,19

384:3,5,7,8 413:19
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125:14 154:18 345:5

429:15

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36:5 37:16 59:22

98:22 100:21 123:21

124:6 129:12,22

155:7 164:1 265:18

355:14 368:15,20,21

368:22 376:18 377:1

377:5,10 378:3

405:20,20 425:6

428:10

prohibiting 148:22

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115:22 260:17 299:1

345:21

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196:14

promotes 146:13

261:17 262:20

promoting 146:18

147:21 191:9 264:14

305:9 428:20

prompt 162:8

promptly 205:2

promulgated 135:17

pronounce 157:12

propellant 283:17

proper 127:3,6 235:20

properly 170:6 185:7

368:9

properties 39:8,9 50:5

50:10,15 237:5

267:16 279:15 281:2

281:4 283:18 298:16

property 440:15,16

proportion 236:16

proposal 4:12,12,13,14

4:15 5:14 52:4 53:8

54:21 76:16 91:22

99:6 112:15 128:18

154:12,16 180:9

184:21 254:16 259:8

259:18 260:2 263:16

325:22 328:6 343:12

344:15,17,20,21

345:5,13 351:16

353:21 354:9 357:4

360:6,13 362:1,13,13

363:2,20 364:5

365:13,17 370:18

372:12 384:16 404:17

409:3 411:3 413:10

417:22 418:8,15

422:20

proposals 78:19 91:19

160:21 322:17 326:3

440:22

propose 57:6 77:5 78:9

125:14 185:2

proposed 101:4,5

108:5 111:1,8 180:16

181:2 259:19 324:14

347:21 355:7

proposing 100:20

Proposition 368:4

proprietary 149:22

338:10

propylene 391:7

protect 64:6 191:1

248:3 263:10 376:22

420:19 421:8 423:5

435:19

protected 421:3

protecting 146:17

264:13 271:14

protection 190:6

226:21

protects 63:20

protein 294:1 323:21

325:2,5 326:17,18,19

326:21 327:2,3,8,14

327:16,19,21 328:1

330:9

proteins 48:3 269:22

281:5

protocol 165:18 244:5

408:17

protocols 244:22

407:21

proven 31:3 35:6

provide 62:20 66:9 86:5

95:6 96:18 100:7

154:4 159:17 163:3

195:5 215:10 237:15

237:18 247:22 272:18

312:9 329:6 351:7

374:4

provided 53:19 93:6

122:22 185:6 195:8

351:6 417:15

provides 37:10 118:19

153:15 188:12 254:22

267:18

providing 25:6 99:11

108:14 182:4 242:18

422:11

provision 138:10

324:18

proxies 202:11

Proxy 7:9

prudent 346:2

pruned 227:12

pruning 227:11

public 4:2 6:6,10,11

7:11,14 27:11 28:1

84:16 92:21 93:4

120:10 153:20 155:22

165:8 169:10 205:9

215:10 229:14 234:18

248:4,7 256:12 267:6

277:18 283:19 284:13

285:3 287:4 289:19

289:22 290:10,22

291:18,20 292:11,12

293:18 296:2 299:4

301:15 305:17 306:2

312:1,4 313:3 315:9

317:16 320:11 337:1

337:11 339:7 343:15

343:21 344:14 346:20

353:14,19,20 354:11

356:11 358:22 362:10

362:16 363:7 372:13

374:21 383:17 386:7

386:9 390:21 392:18

392:21 393:8,9 398:1

401:1 403:3 410:11

413:14 414:10 420:1

420:10,12 422:7,17

426:18 437:2 442:7

443:6

publication 256:13

publish 49:13

published 137:21

153:19 289:8 324:14

411:20 413:18

pull 10:2,5 71:16 106:3

343:11 344:16

pulled 203:16

pulling 107:7 203:22

pulp 169:5

pumilus 149:18

purchase 194:17 197:7

197:13,20 198:11

201:9

purchased 34:11

198:13 200:4 265:11

purchaser 348:7

purchasing 308:18

329:12 338:6

pure 2:22 160:4 169:1,2

209:7 210:22 244:11

301:10

purest 240:9

purified 32:20 326:20

327:9

purity 51:22 62:21

260:9

purpose 165:1

purposes 122:5

push 83:22

pushed 177:15

put 12:14 31:6 54:21

55:5 78:18 94:11,15

111:1 114:14 126:10

126:18 152:22 178:19

186:6 203:9 207:14

209:3 227:11,19

243:22 251:17 252:12

257:6 277:10 290:21

295:11 299:19 309:9

347:22 351:8 357:21

394:15 398:7 406:2

406:13 410:19,20

413:10 421:11 422:1

425:9 430:13 437:5

puts 112:11 439:10

putting 15:8,19 56:16

176:4 223:17 425:10

puzzle 259:1

pyrophosphate 293:12

Q

QAI 74:17 75:6,16

77:18 246:22 254:7

254:11,21

qualification 56:7 414:9

qualifications 53:16

57:6 415:21 417:10

418:4

qualified 185:4 309:5

416:6,21 417:8,18

418:2

qualify 161:18 178:9

248:22 337:9

quality 2:14,15 3:1,5

27:22 54:5,12 74:14

77:3 202:4 213:12

218:21 246:10 256:2

256:3 312:21 325:13

414:21

quantify 29:14 30:6,7

81:10

quantifying 113:5

quantities 132:7

quantity 314:7,11 399:2

quarter-acre 143:16

quaternary 382:7
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

483

question 37:9 45:13

46:8 47:1 48:20 66:11

82:5 84:12,14 92:2

95:12 99:18 100:8

106:1,4 114:20 115:7

115:15 120:8 121:10

125:8 137:14 157:8

160:1 170:12 176:8

176:13 177:1 194:8

194:13 195:12 196:3

196:12,13 214:2,12

217:20 221:10 224:2

227:21 228:11 236:19

236:22 237:9 238:4,7

238:19 244:19,20

245:6,16 246:20

247:6 252:20 257:18

268:15 273:6 274:1

292:4,22 300:3

302:19 306:22 321:14

328:14,21 330:1

347:10,18 348:13

349:13 350:3,9,13,20

351:9 359:13 363:6

369:8 371:10 373:17

374:2,6 382:22

383:13 402:6 403:18

406:3 423:14 425:15

425:20

questionable 34:19

questioning 313:1

questionnaire 198:20

questions 7:4,8 14:12

21:15 23:2 29:12

36:21,22 37:19 41:2

42:9 47:3 48:21 49:19

54:19 61:1 64:16,17

73:15,17 77:15 82:3

84:10 87:18,20 91:5

94:2 95:9 99:16

103:19 105:5,7,21

110:2,8 112:15

113:21 137:3 142:17

145:18,19,21 149:6,8

156:4 163:11,15

170:9 174:9 175:18

183:7 186:5,8 189:13

195:5,7 196:2,9,17,18

198:21 199:14 200:11

200:17 201:6 203:7

204:20,21 208:18

211:20 213:15 216:12

216:15 218:15 219:1

227:15,21 233:9,10

236:10,12 240:18

243:13,16 246:16

249:11 257:2 259:7

261:9 264:18 267:22

268:4 273:3 277:1,4,6

280:14 281:22 283:6

284:2 285:12 286:12

287:8 288:13,22

290:9 291:1 292:17

294:22 295:21 306:11

307:10 309:6,11

314:3 315:5 318:16

328:5 337:19 346:5

358:6 363:8 368:10

371:17 372:7 384:21

388:12 402:5 406:2

409:20 443:16

quick 84:12 210:18

214:12 308:19 311:9

325:17 366:14 444:2

quickly 19:22 84:2

88:12 162:13 179:9

218:7 235:20 307:14

quite 34:9 129:10,15,16

160:20 176:21 227:19

251:20 259:15 272:11

299:20 308:16 380:21

401:1 402:1 420:1,9

quote 26:19 36:12

256:4 269:10

R

rabbis 255:7

rabbit 380:1

race 364:4

radiation 116:5

radically 142:9

rain 238:14

raise 24:18 144:2 378:1

raised 69:18 70:1 84:14

108:7 117:7 203:18

289:15 345:19 369:15

370:15 428:19 430:8

raising 54:11 140:20

141:20 142:8 299:2

399:14

rambling 425:14,18

Randolph 3:5 69:7

74:10,13,14 77:19

78:2,11 79:12

random 199:5,6,15

range 80:1 108:8 154:4

288:5 309:20

ranges 401:5

rapid 308:19 400:20

rapidly 231:3 235:12

252:7 423:7

rare 429:13 439:7

rarely 393:1

raspberries 224:17,18

raspberry 226:6

rate 218:12 222:5

298:15

rates 230:7

rationale 92:2 154:20

368:18 404:7

rations 391:9

raw 318:6,14 345:18

re- 89:4 281:12 288:2

313:3,7 315:11 394:5

re-colonizing 439:20

re-injected 32:2

re-inoculated 32:20

re-list 282:22 292:12

311:22 313:19

re-listing 97:6 110:5

280:8 281:10 286:4

292:13 312:19,21

396:14 401:7 402:2

reach 142:6 232:17

reached 97:1 210:2

304:14

reaching 174:20 196:19

313:22

react 147:18 245:8,22

255:15

reaction 270:7

read 36:17 56:18 111:3

140:17 175:11 179:14

183:16,17 203:6

232:6 358:17 361:13

362:20

readily 19:15 222:6

234:5 406:22

reading 346:12 358:11

378:20

readings 29:17

reads 282:9 286:18

287:12 289:4 291:5

293:6 310:12 317:4

388:18

ready 10:14 205:15,16

278:9

reaffirmed 26:17

real 140:21 142:14

200:22 230:10 292:4

357:3 418:5

realistic 298:15

reality 27:1 218:9

realize 193:2,12 218:2

realized 272:3

really 6:16 21:19 22:15

43:5 45:17 46:2 56:6

56:17,19 58:5 67:16

67:17 100:6 103:15

107:2 114:15 134:4

135:20,22 136:1

165:1 170:3 177:22

178:14 183:17 185:18

185:20 186:19 193:18

193:22 194:13 196:19

196:20 204:16 214:7

214:9 220:18 221:3

221:18,21 223:12

224:10,14 225:22

230:9 231:7,9,16

232:10 237:21 244:21

244:22 249:22 250:21

256:15 274:18 275:3

277:14 292:21 301:16

301:19 302:1,11,15

310:5 314:12 338:9

339:2 356:12 358:11

358:17 359:14 367:12

368:9 369:8 370:4,7,8

370:14 371:11 374:1

382:3 384:17,21

385:20 399:20 402:7

402:20 403:2,19

417:1 422:11 423:3,5

424:7 429:2,10,22

435:2,7,12 440:4,4

442:9,9,10 443:16,17

rearrange 140:2

reason 65:9 71:16

75:11 90:3 181:5

311:9 404:12

reasonable 13:5 173:5

213:9 252:2

reasoning 94:10,12

reasons 165:14 216:13

256:1

recalcitrant 87:6

101:10 131:19 215:14

217:8

recalcitrants 86:13

recall 383:1

recalls 62:5

receive 28:8 103:10

162:8 182:22 299:4

312:18 401:1,5

413:22 420:9 426:17

received 28:22 97:9

104:4 187:16 280:6

281:12 282:21 287:4

289:16 291:20 294:17

296:2 312:2 317:17

317:21 318:9 323:3

334:9 343:15 344:17

345:22 353:19 362:16

374:19 396:16 398:2

receives 64:4

reception 444:3

recess 205:3 443:10,22

444:7

recipes 299:14,20

recirculated 30:4 31:17

31:19
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

484

Recirculating 2:10

69:12 143:1

reclaimed 148:14

reclassified 289:20

290:2,15 292:6

reclassify 349:11

reclassifying 290:18

recognize 41:12 255:18

441:20 442:11

recognized 63:2 102:8

recognizes 255:9

recommend 28:16 87:3

263:16 289:14 333:10

369:17

recommendation 61:17

70:13 87:4 92:11

118:8 128:13,15

152:15 172:7 173:8

252:9 254:19,21

255:9 258:17,20

263:21 265:22 298:21

324:4,11,13 326:9

412:1,6,15 426:22

recommendations

109:9,14,16 110:1

128:21 155:5 160:19

203:6 217:11 254:15

305:21 412:4 415:22

recommended 35:18

158:22 171:19 305:6

336:5 341:15 345:10

recommending 344:20

412:5

recommends 353:21

reconsider 52:13

record 7:6 8:11 9:14

10:15 17:21 34:4

37:22 51:16 57:16

61:12 69:9 74:12

79:15 85:15 88:2 91:9

100:13 117:12 123:8

140:5,10 142:20

146:4 153:8 155:22

168:21 171:3 181:10

181:14 183:10 188:9

205:5,20 215:7 246:7

266:2 329:4 335:5

345:20 386:4 444:9

record- 273:13

recorded 342:15

recording 181:11

records 132:15,17

recreate 440:5

recreated 439:17

recycled 148:14

recycling 32:9 72:3

146:15 147:6 214:18

red 8:2 92:8 94:7,13,20

154:18,22 156:9,22

157:9 354:18

redefined 26:13

reduce 103:1 217:2

218:21 227:20 228:4

283:14

reduced 206:4 406:17

reduces 12:1,5,11

264:3

reducing 102:2 194:11

reduction 197:11

403:22

redundant 163:7

refer 161:15 182:19

338:17 347:9 351:16

352:7 356:9 359:2

360:5,13 363:19

364:5,11 418:15

refereed 353:6

reference 75:13 134:11

167:2 256:5 324:15

369:1

referenced 168:5

260:11 426:19

references 161:13

166:17 235:9 378:3

referred 361:20 365:5

419:15

referring 211:1 270:13

318:21 426:3

refers 102:22 211:3

reflect 12:18

reflects 174:6

refocus 53:15 414:8

refrain 7:11

refrained 121:4

refrigeration 72:6

refused 35:16

regard 64:11 108:1

138:8 161:4,9 166:14

166:16 190:21 373:5

regarding 74:18 75:12

77:10 154:11 163:4

180:8 181:10 183:1

187:18 207:18 208:14

214:14 233:10 235:8

285:7 311:10 312:2

regardless 34:21

regards 137:19

regenerative 19:19,22

362:4

regime 223:21

region 22:20 110:17

180:5

Regional 444:4

regions 148:22 310:18

register 89:21 442:18

registration 256:5

regrettable 376:11

regs 346:12

regular 20:4 25:12

162:14

regularly 18:15 70:18

392:6

regulate 178:6 191:16

192:6 217:9 218:7

247:13 399:11

regulated 381:20

regulation 28:6 34:8

72:8 76:18,20 173:18

234:6 235:5 259:22

262:18 324:10 410:19

421:13,15,17

regulations 29:4 35:12

36:3 59:10 80:12,15

81:3 115:20 125:14

128:4 135:16,18,20

139:1 141:16 158:4

168:3,4,7,8,9,10,11

172:2 182:1,2,14

204:1 355:19 384:8

392:11 395:10 412:10

414:16 416:18 423:16

423:19

regulator 66:13 284:10

regulators 62:7 191:14

regulatory 64:7 142:2

159:12 180:16 258:4

259:19 260:5,15,19

269:21 373:6,19,22

374:7,11,13

reinforce 29:6

reinvent 255:20

reinventing 142:2

reissue 370:12 385:3

reiterate 180:7 260:5

371:15

reiterated 398:2

reject 60:17

relate 190:18 367:17

related 138:3 161:17

188:5 227:21 302:11

325:22 326:3,4

343:15 367:2 368:2

370:2 371:20 372:4,7

376:6 381:6 397:15

397:21

relates 76:13 414:22

415:15 416:17

relating 64:13

relationships 320:3

relatively 224:9,18

relax 392:6

relaxant 396:2

release 146:22 147:16

242:5 394:15

released 261:4

relevant 76:15 135:22

256:10 266:16 328:2

366:21 376:16

reliable 200:14

relieved 385:13

rely 136:5 207:21

423:10

relying 108:18 176:21

250:1 423:12

remain 68:7,9 69:17

73:12 280:4 437:9

remained 268:9

remaining 90:21 119:10

283:21

remarks 7:12 187:10

remember 19:5 20:14

21:12 102:19 186:17

191:22 224:3 309:16

322:12 348:22 398:11

403:22 404:9 423:21

443:15

remind 125:13 133:13

139:10

reminder 7:22 278:13

300:16 328:5 444:2

remote 8:3

removal 12:14 13:16

remove 213:2 265:18

267:4 279:20 280:5

280:10 281:5 284:16

305:22 312:1

removed 19:19 68:10

101:10 266:3 294:5

305:5,6 317:13

393:21 396:22

removes 77:6 226:14

removing 75:13 85:5

118:9 119:1,5 305:12

398:19 436:16

renewable 21:3 169:14

renewal 89:16

rented 18:9

reoccurrence 172:11

repeat 52:12 115:6

125:6 245:11 377:8

replace 118:21

replacement 398:16

replacements 375:18

replacing 19:22

reply 125:21

report 198:19 199:10

199:19 212:21 234:16

289:6,8,16 291:9,9

293:8,10 294:17

302:1 323:7,10

334:18 366:9 372:2

reported 280:12 281:19
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

485

reportedly 389:14

reports 43:18 56:19

154:2,3 213:9 309:1

represent 43:21 58:10

201:15

representation 198:7

represented 58:17

representing 69:13

193:9 318:4

represents 58:21 163:2

reproducing 270:5

reproduction 375:3

reproductive 368:5

378:12 381:4

request 54:4 116:3,8

181:7 202:9 234:19

289:6 291:8 294:16

348:1 366:9

requested 113:9 281:16

285:5,7 286:7 288:9

289:15,19 334:19

356:9 388:9 417:5

requesting 35:21 261:3

288:2

requests 36:18 113:15

323:4 334:11 370:11

385:2

require 67:2 72:9

106:19 108:20 109:3

112:16 114:17 134:17

159:15 164:9 180:21

221:11 256:6 259:9

260:19 273:8 392:19

412:7

required 20:7 98:22

157:3 159:14 174:3

181:3,7 235:4 270:9

273:15 312:10 324:10

requirement 54:1 125:5

125:11 159:12 173:3

213:3 223:3 256:17

259:21 260:6 300:18

304:4 413:21 415:1

requirements 28:7,15

37:13 59:12 75:18

91:2 105:4 126:22

137:17,18 156:1

168:6,13 181:15

234:5,13 237:11

242:11 254:18 255:22

256:15 280:11 325:1

415:15 441:2

requires 66:17 83:8

124:22 132:15 172:10

172:19 333:7 352:9

364:9 395:12 396:4,8

400:14 401:15 412:11

412:15

requiring 75:14 80:10

83:20 113:2 248:3

research 2:16 18:5

46:13 47:10 74:17

76:8 78:12 91:11 92:8

146:7 149:21 157:19

211:16 218:17 219:21

228:8,10 266:7

294:15 296:20 375:15

381:5

residents' 235:8

residual 287:14,16

387:12,13

residue 46:10 113:10

319:18

residues 40:20 49:17

319:10 379:7

resilience 262:9

resin 362:17 372:4

resins 376:6

resisting 53:13

resolve 176:4 428:5

resolved 86:11 164:12

165:2

resort 165:13 408:9

resource 93:8,12 145:6

154:9 241:8 308:8

439:8

resource-smart 71:4

resources 59:14,15

64:7 73:3 77:2 146:15

154:5 257:9 262:20

308:22 417:6 420:4

438:18

respect 59:14 91:21

92:10 243:16 276:11

385:7

respectfully 259:17

respond 55:16 106:1

252:7

responded 195:2

408:11

respondents 195:17

responds 206:22

response 62:8 64:20

136:3 268:17 296:3

responsibilities 415:12

responsibility 55:20

112:11 167:20

responsible 15:7

118:17 146:22 190:22

296:15 374:12

responsibly 415:10

responsive 385:1,2

rest 20:6 41:7 204:18

343:2 407:9

restate 126:15

restoration 440:10,11

441:3

restore 391:4

restoring 263:2

restrained 88:18

restrict 75:11 81:12

327:19 355:18

restricted 94:6 428:11

restricting 119:2

restriction 154:20

restrictions 233:19

262:16 317:16

restricts 395:6

result 27:21 70:13 99:2

162:15 171:20 343:4

resulting 36:3

results 9:4 11:8 361:14

433:14

resumed 9:14 140:6

205:5 386:4

retail 121:22 122:2

371:4

retailer 66:12 68:2

retailers 58:22

retain 278:16 401:6

438:11,12

retained 392:15 393:19

retaining 15:16 84:13

260:1 287:5 438:22

retired 384:3

return 386:9

returned 8:16 10:20

reuse 378:9

reusing 72:4

reveal 184:9

reverence 430:11

reverse 108:3 395:14

396:1,6

review 3:3 6:11 36:13

112:20 139:6 153:11

153:16 154:6,9 157:4

157:21 158:8,10,20

159:6 163:2,6 164:9

164:20 181:20 192:13

210:18 211:3 234:20

260:20 261:5 265:17

281:11,16 282:22

286:8,10 288:10,16

289:7,13,17,18 291:7

291:18 294:13,15

296:4,8 305:13,19

315:4 319:17 323:8

334:20 343:16 344:19

347:3,6,13 353:11,13

354:2 356:8 362:6

366:14 367:9 368:9

374:16 388:9 390:22

397:17 402:8 411:17

415:18,20 417:3

437:16

reviewed 75:5 79:1

153:18 245:17 281:9

282:20 283:22 285:10

287:6 311:21 323:9

323:12 326:3 347:3

349:17 366:10 376:8

reviewer 56:13,18 57:1

57:9 254:7 348:20

reviewers 57:3,9 186:1

reviewing 78:21,22

296:5 347:1,2 379:20

reviews 78:17 254:13

372:2

revise 259:9

revised 372:12

revising 54:6 161:21

184:13

revision 417:16

revisions 260:3

revisit 234:19

revolution 141:11

rework 179:19

rhizosphere 206:19

210:10

rhyme 277:6

rice 1:18 54:20 56:3,5

134:8 135:1,6 136:3

152:8 163:16,19

178:19 257:3 310:15

311:3,9,18 312:7

315:1 332:12 333:19

340:11,22 342:5

347:18 348:4 349:7

352:18 353:10 358:3

360:22 364:15 413:7

413:9 417:21 418:6

419:1,16 423:13

425:16 426:16 429:6

430:6 431:22 435:6

436:7 438:3,14 440:6

441:8

rich 34:5 146:21

Richard 3:14 8:9 17:10

17:11 25:22 34:2,3

37:18 203:11

Richardson 333:6

356:14 357:16 359:4

Richardson's 358:20

right 6:3 10:3,12,14

17:13 30:13 34:21

65:6,18 68:18 72:4

82:10 91:5 94:16

95:21 103:20 104:16

116:7 128:19 145:22

150:3 151:14 176:14

177:12,14 192:4

195:1 205:7,17 214:7
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218:13 221:20 222:12

238:8 259:4 276:16

277:18 278:11,18

279:13 280:15,21

282:1,7,12 283:12

284:3,5,8 286:14

289:1 291:2 292:10

293:3,14 299:8 300:9

300:11 310:9 316:20

322:13,15,18 332:20

334:5 339:5 340:4

341:10 342:22 344:14

348:15,18 349:10

350:17,22 353:8

357:19 361:11,22

363:22 364:3 365:11

371:13 377:17 383:4

385:22 386:18 387:7

388:13,15 398:22

400:11 406:5

rights 440:16

rigorously 133:11

rinse 286:3

riparian 432:7 434:2

risk 64:3 123:15 172:9

248:4 252:18 253:2

257:9 294:9 379:3

414:4

risk-based 53:2

risks 71:13

road 371:2 380:1

roadmap 165:11

robust 109:20 296:7

365:19

Rocket 2:21 241:1,4

244:4

rocks 70:3

rockweed 93:1,18

Rocky 18:14 444:4

Rodrigo 3:5 179:14

189:17 204:22 205:10

205:12,18,19,22

221:6

role 55:7 376:3 433:12

433:12

roll 16:16,17

rolled 16:13

rolling 15:19

ROMERO-BRIONES

1:18 210:7,12 211:2,5

252:15 253:8 328:13

328:20 329:17,22

331:18 332:2 334:2

341:5 342:10 351:20

353:1 361:5 364:20

419:6 436:8

rooftops 148:14

room 20:14 28:2 136:10

193:15 433:6

root 30:18 124:4 130:17

131:2 136:21 200:22

267:18

rootball 31:4

rooted 80:19 126:3

226:20

roots 124:5 216:15

226:21

rope 246:12

rosemary 75:13

Rosse 3:6 179:15 205:1

205:11 211:22 212:2

212:3 213:19 214:6

214:20 215:1,4

Rossi 205:18

rotating 126:12,17

rotation 13:10 23:5,22

104:21 126:17,22

134:12

rotations 24:10 126:12

127:1

rough 50:18

round 45:3 86:3 241:19

280:6 296:8 312:8

362:9 442:15 443:8

route 136:12 166:10

routine 25:12 161:10

172:5 182:3 408:6

routinely 388:4 408:5

row 145:8

rug 203:16,22

rule 54:6 77:5 89:4

93:20 109:5,9,13

131:4 132:15 137:20

138:4,11 161:5,7

165:5,20,21 166:1,3

166:10,17 167:18

172:21 177:10 188:11

188:12,19 189:1,3

217:9,12 257:12

263:18,21 324:14

326:2 376:17 409:6

411:19 412:1,7,11,17

421:12,16,19 427:1

rulemaking 89:19

rules 13:4 28:19 118:14

124:2 125:13 126:20

319:1

rumor 22:4

run 7:3 8:2 179:10

183:12 197:12 219:12

385:5

running 9:17 72:3

331:5 431:13

runoff 118:18 144:8

238:14 239:3

runs 275:17

Ruth 3:15 179:15 215:6

232:20 233:1 239:19

S

safe 14:11 62:19 63:19

142:13 256:3 269:19

287:16 334:10 387:14

safer 62:11 86:8

SafeTraces 2:18 57:14

61:14,21

safety 62:3,15 64:12

118:20 122:5 200:16

248:7 255:7 256:2

288:6 338:17

sage 424:9

sagebrush 430:12

431:8,9

sake 66:19

salads 243:20

sale 336:19

Sales 2:20 241:1

salmon 203:18

Salmon-Safe 144:5

salt 220:4

salted 301:11

Sam 3:17 117:11 123:7

123:9 127:18 131:5

134:6 139:3,14

sample 33:13 46:13

48:18 68:19 199:5

241:16

sampled 68:4

samples 48:6 49:1

sampling 46:16 198:6

359:19

sanctions 192:13

sand 174:1

sanitize 388:1

sanitizer 288:4 387:8

sanitizers 286:8,10

288:10,16 381:20

382:10 388:10

sanitizing 285:20

287:13,22 387:11,19

satisfy 216:21

sauce 367:15

sauces 300:6

sausage 301:20 302:9

303:2

sausages 301:6 312:12

save 204:18

saves 11:22

saw 45:14 90:15 128:11

128:15,16,16 175:12

363:12 410:3 413:18

413:20

saying 15:9 73:19

166:12,16 167:12

197:18 204:4 222:22

245:13 273:21 288:9

290:20 302:16 337:20

349:18 393:22 427:6

435:21

says 13:20 70:18 72:9

77:1 125:22 126:4

127:3 136:16,22

141:14 210:14 315:10

351:2

scales 426:10

scan 121:22 122:2

scarce 148:4

scarcely 193:18

schedule 6:17,18 33:2

139:15 140:3 179:19

189:16 277:20 385:19

385:19 412:22 413:3

441:13

scheme 224:10,18

Schlegel 3:7 17:12 34:3

38:1,1 41:13,15 42:11

44:11 45:19 47:8 48:1

48:9 49:7,11 50:2

51:8,12 234:11

239:16 240:2

science 3:4 13:6 18:2

234:8 258:11 297:6

science-based 12:19

93:8

Sciences 269:4

scientific 32:7 38:11

92:2 93:6,15,17 94:10

94:12 122:17 353:17

scientist 41:4 65:8

276:13 296:20

Scoles 3:7 37:21 51:14

51:17,17 55:16,18

56:21 187:12

scope 98:2 158:13,20

159:14 184:3 255:17

256:18 286:11 288:11

293:10 347:1 349:5,9

370:4 388:11

scopes 184:19 256:19

Scott 1:18 54:19 129:5

132:21 134:7 163:15

178:17 184:19 257:2

310:14 313:20 314:19

340:11 347:16 353:9

358:5 413:7,8

Scott's 137:14 347:17

scouting 242:5

scrambled 90:5

screen 126:18 246:18

251:5

screening 198:10
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

487

199:14,16,17

Scroll 341:9

scrolling 391:22

scrutinizing 93:16

sea 2:16 83:17

seal 160:17 169:17

188:17

Seaplants 91:12 93:5

search 311:16 429:3

season 225:9 235:18

seasonal 144:1

seat 278:9

seats 205:9,14 386:7,9

seawater 289:5,21

290:7

seaweed 82:1 137:19

354:18

seaweeds 84:3 137:15

138:9 154:17,19,22

155:1 156:21 157:4

second 6:4 8:15 10:19

50:11 54:2 61:18

105:22 115:7 123:19

172:12 176:8 181:22

194:13 224:2 238:7

247:6 252:20 253:9,9

280:21 296:8 328:20

351:19,20 352:8

353:11 360:9,10,12

362:9 364:1,2,4 406:3

418:12,13

secondary 285:18

seconded 331:10,14

333:4,5 340:11,11

341:14 364:8 418:14

Secondly 234:14

secretary 1:15 88:8

443:2,4,20

secreted 282:13

section 76:20,21 90:2,8

97:5 125:18 138:10

161:6 181:10 269:9

279:1 280:18 282:8

283:10 284:6 285:16

286:18 291:5 293:6

300:12,13,17,22

310:12 323:5 334:12

353:21 368:19 386:19

395:4

sections 234:20 379:18

432:7

sector 98:8 119:8

265:11

sedation 395:14 396:7

sedative 396:2

see 14:13 27:9 38:15

46:3,19,21 47:11,15

48:18 49:17 54:14

55:5 66:8 73:20 86:20

89:3,22 92:6 94:15

101:5 105:10 114:1

120:20 127:8 138:21

140:21 145:20 150:2

151:18 156:5 157:4

158:2 162:21 163:6

167:11 178:4 190:7

195:1,19 196:4,17

198:19 199:1,13

201:9 206:12 214:5

231:9 234:22 235:17

246:18 256:20 257:8

260:5 277:12 294:4

303:11 307:11 315:21

316:1 321:1 328:2

340:4 346:20 359:21

363:3 370:22 371:3,8

379:15 405:6 409:2,9

420:12 431:2,12

434:12 435:8 436:14

444:6

seed 51:21 76:16 130:1

130:2,2 131:1 136:15

137:8 180:10 181:2,4

181:12,18 242:18

259:15 260:6,9

seeds 241:21 439:7

seeing 71:7 200:20,21

272:9 280:15 282:1

283:7 284:3 285:13

286:14 287:9 289:1

293:3 300:9 310:9

316:21 322:15 330:11

330:20 388:13 395:2

397:5

seeking 103:11

seen 19:3 85:2 116:11

192:16 203:8 219:22

225:14 314:8 315:20

320:3 384:1 389:22

402:13 417:9 420:6

431:8

segment 422:20

segregate 303:17

SEITZ 1:19 15:12 66:21

114:19 115:8,15

132:22 273:5 274:2

332:11 333:18 340:21

342:4 346:7,19

352:17 360:21 364:14

375:12 395:22 403:21

404:9,15 418:22

select 259:6

selection 249:9 253:18

self- 59:6

self-selected 199:7

sell 22:18 41:22 100:4

143:10 152:2,12,16

203:10 315:20 407:3

seminar 256:9

senator 366:6

senators 366:7

send 70:16 193:3

199:10 211:7,15,18

352:11 360:15 418:8

418:19

sending 160:21

senior 185:4,6 254:7

sense 65:13 103:8

122:14 142:11 178:7

197:2 228:10 233:8

244:15 295:5 305:15

308:5 321:19 370:3

374:18 385:3 404:10

437:1 442:8

sensible 112:16 345:1

sensitivity 336:4

sent 185:15 232:14

275:17 363:3 366:7

sentence 14:9 21:7

210:8 377:14,22

sentiment 316:1

separate 58:18 72:22

73:6 122:9 136:2

138:13 216:17 222:11

260:11 267:11 284:20

320:11 324:18 354:6

separated 236:6 244:1

335:11 441:6

separately 241:12

292:12

separating 86:21 101:7

244:11

September 434:13

sequence 337:9

sequestration 262:8

263:7

seriously 167:15

serve 59:6 88:13 180:2

216:7 233:7 442:12

served 88:5,7

serves 216:4

service 18:5 264:16

442:7,10 443:7,8

services 2:7,20 3:2

183:13 202:5 246:9

262:7 433:14

servicing 433:9

serving 215:21

session 6:5

sessions 254:22

set 37:13 66:9,9 91:19

100:7 101:1 133:8

148:12 212:11 213:8

247:16 268:6,8

404:12 420:3 429:10

429:21 431:6

setting 105:4 106:4,9

106:15 163:13 182:13

190:13 421:15

settings 102:17

settled 10:11

seven 18:9 96:14 120:6

142:6 280:7 400:16

401:17 403:12,13

severe 59:16 119:6

shaking 42:6 330:11

shallow 226:20

share 11:18 118:6

122:1 140:15 156:11

194:7 241:2 258:7

shared 179:3 193:20

sheep 397:16,22

sheets 75:5 412:16

shelf 66:16 314:8

shelf-stable 300:6

shells 282:13

Sheraton 1:10

shifting 56:6 71:15

ship 241:17,19

shipped 242:14

shipping 72:6

shirataki 310:21 311:1

shooting 229:21

short 4:12 61:17,17,19

62:18 63:17 64:5 99:5

124:12 156:19 160:20

185:17 223:10 256:7

261:1 269:5,15

303:19 334:6,12

335:1,3,6,9,13,16

336:6,8,13,16,22

337:2,9 340:8 341:11

short-term 400:20

401:21

shortage 322:1

shortened 108:5,5

404:18

shorter 148:19

shortfall 296:4

shout-out 88:14

show 92:8 119:11

206:15 258:15 408:2

showed 195:4 251:5

showing 210:20 314:10

367:13 369:21

shown 31:2

shows 211:12 235:11

381:5

shrimp 203:9,17

shrinking 81:14

side 15:22 56:17 209:7

246:12 311:10 322:4
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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325:4 338:19 357:9

360:3 371:4 399:6

sides 140:21 141:3

427:10

sight 276:2

sign 6:14 351:6

sign-ups 6:15

signal 92:22

signatories 89:13

signed 443:4

significant 119:9 123:3

181:15 209:19 212:16

218:20 226:13,19

228:13,18,19 296:2

significantly 102:10

195:21 253:5 267:19

silent 260:7

silica 281:1 282:13

silicates 279:17

similar 24:4 137:14

138:12 141:19 150:7

195:12 208:5 211:13

220:21 229:4 285:1

298:22 301:18 315:4

319:13 336:21 376:2

380:2 407:14,17

similarity 86:20

Similarly 271:9

simple 125:5 126:4

174:6 178:1,14

simpler 426:9

simplified 335:6

simply 30:2 34:6,17

40:9,17 48:13 126:5

182:15 270:7,13

355:8

simultaneously 142:7

sincerely 188:22

single 220:1 258:15

294:8 420:12 435:18

sir 8:12 364:17

sister 244:3 265:6

sit 121:2 205:10 386:7

386:10

site 105:4 106:8 187:18

206:10 218:16 226:14

site- 59:11

site-specific 206:21

sitting 225:4 326:8

431:10

situation 9:7 11:11

162:3 173:11 175:16

184:13 218:16 303:3

321:11 431:17

situations 44:1,5

161:18 391:3 393:6

six 143:8 301:17 368:11

404:19 415:17

skew 122:2 196:17

skill 185:10

skills 66:17 184:11

skim 156:14

skin 389:4,17

skip 17:9,12 282:7

Skolaski 3:8 183:9

186:22 187:1

slack 427:8

slaughter 395:17

396:10 400:16 401:17

403:13 404:19 407:5

slaughtered 403:13

sleep 186:6

sleeve 394:15

slice 204:8

slide 6:20 38:3 80:3

124:20

slides 8:4 197:4 201:10

slight 55:12

slightly 89:2

slippery 175:21

slivers 432:5,18 433:1

433:8 435:1

slope 175:21

slow 332:21

slower 332:19

small 35:1 40:3,3 43:8

48:6 95:22 148:13

224:10,14,18 294:18

299:12 316:12

smaller 49:9 223:20

268:8 269:20 307:5

381:12

smallest 266:10

smart 10:8

smartly 25:11

Smith 3:9 171:1 179:22

180:1

smoothies 294:2

sneak 249:13

so-called 38:21

social 108:16

socially 191:5

society 107:19 272:5

soda 24:21 284:19

sodium 4:6,6,8,9 5:4

77:10,12 284:4,6,9

285:13,18 286:1

287:19 293:3,6,12,13

293:14 294:19 296:21

297:2,11,16 298:22

301:11 387:16 388:5

389:10

soil 12:1 14:18 18:2

19:21 20:3,6 21:2

23:17 26:14,20,22

27:8,9,10,17 28:12,17

29:15 30:20,22 31:5

33:13 36:8 37:16,17

37:17 38:6 40:1,14

41:12 42:4,14,17,18

42:21 45:5,7,21 48:6

49:3,9 69:19,20 71:22

72:9,10 77:3 86:16

87:7,7 104:21 105:19

113:18 116:12,15,17

116:19 117:3 118:4

118:18 124:22 125:2

126:4,17 127:13,15

128:6,20 130:19

133:10,15,18,22

134:1 135:2 138:17

138:19 142:7 144:21

145:13,14,14,16

146:14 147:4,5,11

149:19,20 150:2,3,4,5

150:10,11,14,15

151:5 152:22 153:2

163:22 170:19 173:14

174:2 175:10,10

176:5 177:6,17,19

178:2,9 193:17

194:16 196:7 197:11

200:12 201:15 203:3

206:6 207:4,16,20

210:2 213:12 214:10

216:3,5,6,21 217:8,13

218:1,3,14,18 219:7

222:11,13 224:15,21

225:19 226:20 227:3

227:10,14 228:5,8,13

228:16 229:1 233:10

235:2,6,8,19 236:3

237:2,12 244:1,13

245:1,21 261:19

262:7 263:8 398:3

399:9,14 428:20

soil-based 28:9 102:3

131:20 133:5

soil/compost 229:16

soils 43:19 45:3 48:18

49:17 80:18 126:12

170:5,14,14 206:5

211:14 222:17

sold 173:22 244:1

328:22,22

sole 148:2 220:9

solely 223:8

solid 146:20 208:4

215:20 216:18,19

218:13 230:10

solubility 30:21

soluble 31:7 97:8

238:15,17,20 239:7

310:19

solution 27:19 81:13

173:5 178:14 209:3,4

217:8 302:15 340:3

solution's 284:20

solutions 61:22 101:22

303:15 309:3

solve 309:1

solvent 346:13

solvents 346:8

solving 142:14 339:19

somatic 210:21

somebody 15:9 402:16

somewhat 87:19

159:13 296:15 298:4

310:1 338:7 373:17

414:6 420:6 421:1

422:3,21

soon 60:9 109:10

213:21

sophistication 271:21

sorry 10:9 31:11 32:13

33:7 51:7 57:14 61:9

116:8 117:16 134:7

135:5 160:4 167:8

170:11 186:5 198:18

199:6 210:5 214:13

238:10 245:10 279:9

282:4 322:21 344:15

358:8 361:15,16

365:16 380:4 404:14

404:16 409:4,9

430:22

sort 81:9 135:10 164:22

209:13 223:21 244:12

251:16 298:10 359:8

370:18 403:10 407:21

428:22

sorting 360:1

sorts 150:22

soul 21:12

sound 12:19 112:16

142:8 146:18 147:19

434:14

sounds 149:14 200:1

322:5

soup 367:14 378:22

source 39:3 41:9 42:3

43:6 61:21,22 62:21

63:9,18,21 84:18

111:13 115:4,10

148:2 208:3 214:8

216:8 218:2 221:4

223:7 301:20 339:15

344:8,10,11 348:22

355:8,22 367:12

383:16 431:14

sourced 74:22

sources 83:8 84:19,20
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Neal R. Gross and Co., Inc.

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113:2 114:6 135:7

207:22 208:6 209:5,6

220:9 233:16 267:8

312:3,6,9 313:2,9

379:7

sourcing 308:3 355:22

southern 142:22

southwest 18:8

sovereignty 102:1

soy 115:3,9 284:15

323:21 325:5 326:16

326:18,19,20 327:2,3

327:8,13,16,19 328:1

330:8 350:1

soy-based 324:22

space 72:3 108:21

192:1 200:7

spaces 262:13

spaghetti 311:19

speak 7:17 32:11

117:20 150:20 246:12

248:6 275:1 295:12

348:6

speaker 8:5

speakers 9:18 139:19

speaking 7:10 26:4

87:19 170:1 246:13

special 88:14 243:1

440:4

Specialist 2:2,5

specialized 185:10

species 74:22 75:7,11

78:15 79:6 93:10

94:20 95:17,22 96:1,5

109:18 188:6 192:22

353:17 354:13 355:3

355:6,13 358:15

359:22 360:1,2

398:10 429:13 434:19

434:21,21 439:7

specific 47:6 59:12

96:2 101:17 106:22

112:18 131:11 132:13

137:20 181:11 182:16

186:18 194:16 206:10

213:20 214:20 256:18

256:20 325:5 337:9

355:13

specifically 131:4

138:3 161:14 183:22

185:9 186:15 187:7

190:8 225:18 231:22

246:15 247:20 374:15

397:14 426:6

specification 75:5

specificity 188:13

358:12

specifics 182:14 218:8

specified 279:5

specify 75:7 91:22

114:15 156:9 172:21

specifying 213:6

spectrum 30:10 43:21

102:14

spend 73:9 359:15

spent 107:2

spirit 29:3 262:17

splendid 186:2

splicing 67:21

split 293:18

splitting 131:8

spoke 133:8 187:12

317:19 318:4,7

326:13 359:12 394:7

spoken 9:10 11:14

spontaneously 87:19

spray 23:19 25:13

spread 162:6

spring 265:15

sprout 63:14

sprouts 128:7 203:4

SQF 256:4

squad 21:10

squash 13:13

St 118:5 140:18

stability 102:11

stabilize 291:17

stabilizer 284:11 311:5

stabilizing 294:2

stable 47:14 215:21

216:4 230:12

staff 2:1 34:16 52:14

115:16 137:5 185:1,4

258:3 261:14

stage 238:8 269:18

stakeholder 295:3

303:11 422:19,19

stakeholders 184:9

261:6 353:21 357:22

405:7 411:9 413:15

stamp 133:6

stand 117:19 203:1

standalone 420:8

standard 19:7,8,9 60:13

82:11,14 83:1,6,7,10

127:22 133:4 139:8

165:6 226:2 235:7

367:18 368:22 375:1

376:18 407:17 408:18

410:17,20 424:5

standardized 101:1

standards 1:3 2:4 18:20

20:20 21:5 29:7 40:16

43:4 69:18 70:15

73:12 80:2 82:6,17,18

84:1,6 90:11 98:21

101:17 104:21 106:8

107:1,4 109:19,20

131:9 132:18 142:3

149:4 152:2,4 161:6

161:14 174:5 178:7

187:4 234:3 263:17

265:2 317:15 357:1

442:14 443:5

standing 193:12

standpoint 219:22

252:6 303:5

stands 245:3

Stanley 2:14 139:20

246:5 254:3,4,6 257:1

257:2,18

start 8:10 9:20,21 10:7

10:13 34:3 37:21

38:13 51:15 57:15

61:11 69:8 74:11

79:14 83:14,15 85:14

88:1 91:8 96:10

100:12 107:2,16

110:12 117:11 123:7

139:18 140:9 142:19

146:3 153:7 160:6

168:20 171:2 177:5

179:10,12,20 183:9

189:20 205:14,19

215:6 239:2,5 241:20

249:6 254:5 257:21

261:11 264:20 269:1

269:2 272:9 274:5

277:11 278:12 279:1

306:18 322:6 331:9

331:16 333:8 340:13

341:19 352:10 364:10

386:1,17 387:6

410:17 423:11 428:1

started 7:21 8:5 11:17

17:1 18:6 140:8 143:9

202:17 205:8 228:8

363:13 386:8

starting 205:2,10,17

218:2 322:17 409:22

443:22

starts 178:7 277:22

360:17 418:20 440:16

444:3

state 15:21 17:21

146:18 171:12 246:6

247:12 262:18 337:15

368:4 423:21 424:8

438:17

stated 212:20 269:19

286:9 318:10 345:20

statement 169:21

270:11 319:9

statements 184:15

399:8

states 27:3 84:4 86:3

96:16 102:7 113:16

143:18 160:10 170:3

184:21 188:2 261:15

264:2 335:2 414:16

415:3 422:13 428:9

static 355:3

stating 117:14 286:4

288:3,3 344:18

387:22

statistics 122:22

status 15:17 123:18

statute 34:8 374:3

384:8 425:5,12

stay 54:3 179:18 181:8

396:19

stays 237:7

step 83:6 166:21

315:16 316:2 355:21

441:7

Stephen 3:13 186:21

189:14

Stephenson 3:11

140:11,12

steps 75:4 142:12

172:10 315:10

Steve 1:16 3:6 41:2

43:16 78:3 103:20

105:6 116:9 120:13

121:8 126:8 127:16

129:5 149:8 174:9

175:17 179:15 189:22

198:16,18 205:1,11

205:18 211:22 212:2

229:10 243:14 244:9

291:12 292:16 315:7

318:16 321:5 338:13

339:5 352:11 358:6

399:4 400:4

stewards 236:2,3

stewardship 233:11

433:10

stick 372:14 394:18

stimulate 208:9

stock 124:3,4,15

129:11,20 130:5,9,14

130:18 131:3 136:17

136:20,21 137:11

163:11,17,22 164:6

164:18,19 407:5

stocking 109:17

stocks 169:5

stomach 328:19

stop 6:22 33:1 47:1

49:20 66:19 84:8

178:17

storage 283:15 286:21
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

490

287:3 377:3

stores 143:11

stories 185:14

story 390:12

Stowe 89:15

straight 122:12

straightforward 112:7

strain 119:7

strategy 397:20

straw 3:4 8:13,14 10:16

10:17 235:13

strawberries 204:14

224:15

street 22:4

strengthen 160:17

strengthening 180:9

stress 147:22 191:4

Stressors 108:16

strict 29:6

strictly 167:17

strip 421:5

stripped 87:15

strive 20:22 217:2

striving 80:21

strong 20:20 50:18

241:6 283:3

strongly 89:18 151:18

173:20 263:15,20

436:3 438:6

struck 358:17 378:20

420:10

structural 223:8 229:18

231:15

structure 215:22 222:8

223:10 237:4 279:15

279:18 376:4

struggle 218:14

struggles 18:16

struggling 42:10

177:11 229:19 272:16

359:20

studied 95:15 148:13

267:1

studies 45:14 93:7,15

151:1 223:13 298:19

366:19 367:2,13,22

study 27:2 298:21

stuff 203:5 275:4

363:13 440:19

styles 72:13

subcommittee 4:3,20

5:2,12,20 6:8 74:18

100:17 111:2,6 112:1

112:22 113:8 117:8

154:11 160:21 259:17

277:22 278:3,9 286:9

288:11,15 290:14

291:8 294:16 295:5

295:13 303:1,7

314:21 331:2 333:4

336:14 340:12 341:15

346:3,19 350:5,14

351:17 352:7,12

353:7 354:10 355:6

356:9 357:2 360:7,14

360:16 361:21 363:4

363:21 364:7,11

365:6 385:12 386:2

386:12 388:10 406:2

413:7 418:10,19

437:21

subcommittee's 52:4

154:16 180:9,11

246:17 334:20 355:11

385:16

Subcommittees 357:18

subject 37:6,9 108:4,8

117:20 140:14 210:18

300:17 351:9 354:8

420:6 433:5

submissions 372:7

submit 36:13 106:1

107:12 229:12,14

232:2,3

submitted 61:2 80:1

89:10 180:6 183:21

186:14 187:13 283:20

313:5 334:9,14,16

subsequent 181:4

substance 35:6 123:21

267:5,17 292:15

295:4 317:2 323:8

344:13 345:7 369:5

376:18 378:11,15,17

380:14 425:22

substances 4:3,15 5:3

34:22 36:5 59:22

90:11,14 108:1 124:7

132:10 155:8 160:13

162:19 163:4 182:9

182:18 207:8 208:14

214:17,19 258:20

260:21 265:18,19

268:13 279:3,20

289:22 327:19 351:13

362:1,8,10 363:20

364:6 368:21 371:2

377:1,10 379:21

380:2 381:19 382:17

383:8 386:16,20

425:6 437:16,19

substantial 75:3 87:13

87:14 248:4 252:18

253:2

substantive 353:19

substitute 376:11

substrate 119:13 135:7

146:20 206:17 209:2

209:8,11,17 214:15

215:20 220:4 221:7

222:12 304:9 351:3

substrates 134:17,21

134:21 135:3,14

207:10 216:18,18,19

subtropical 310:18

success 190:6

successful 99:12

255:11 415:14

successfully 297:16

succinct 7:16

sudden 204:4 248:2,11

248:21 249:21 252:17

Sue 1:13 33:1,5 66:19

67:18 103:20 104:9

170:12 257:2,17

430:6 431:22 435:7

435:21 438:3

sufficient 174:2 311:14

312:9 339:21 415:4,5

415:12

sufficiently 53:6

sugar 391:4

sugars 169:8

suggest 118:2 127:21

252:21 253:10 436:4

suggested 53:4 102:21

260:3

suggestion 92:3 251:22

suggestions 127:20

252:19

suggests 101:9

suitable 148:3

suitcase 254:8

sulfate 5:6 397:6,11,13

398:7,9,17,19 399:1,6

399:11

summarized 314:19

summary 325:17 398:1

summer 409:14

sun 226:12

sunset 4:3 5:3 89:4

90:1,2,22 96:22 97:7

110:21 163:2 172:13

278:12 280:6 286:11

288:12,16 289:13,17

293:10 294:13,15

296:7 305:13,18

307:21 312:16 315:6

317:2 322:16 343:5

343:16 347:3 353:11

353:13 355:1 362:6

386:16,22 388:11

390:21 396:15 401:13

403:7 406:9 411:8

Sunsetter 278:21

sunsetting 97:5

superficial 123:17

supplement 312:12

318:2

supplementation 324:5

supplemented 335:6

supplements 168:8

169:7 289:12 311:11

supplied 97:3

supplier 98:3 321:12

suppliers 314:6 317:18

392:20

supply 62:16 64:2 75:5

96:20 97:2,21 123:14

267:14 296:4 312:22

314:2 315:5 321:9,20

336:10 348:17

support 26:4 52:7 53:1

78:13 86:9 92:13,16

93:18 97:6 100:19

103:14,16 142:7

146:9 161:2,5 166:2

166:12,19 172:3

173:18 177:2,8,9

188:21 189:2,4

196:14 204:14 255:3

259:13,16,19 280:8

280:11 283:3,20

286:4 288:2 289:7

291:7 298:20 308:18

312:19,20 313:6

315:2,6,11,18 323:8

325:4,13 334:19

387:21 401:7 402:1

403:3

supported 52:9 75:15

285:3 290:1 313:3

345:12,14 394:5

supporters 107:22

supporting 262:3

281:12 293:20 326:14

supportive 165:20

301:18

supports 101:16,18

114:2 181:22 263:15

263:20 265:16

supposed 34:6 362:19

363:16 393:7

supposedly 72:22

sure 17:22 21:8 23:7,9

32:16 42:15 43:5 44:8

45:22 48:22 69:5

78:21 85:16 114:10

115:16 134:14 142:21

156:13 162:9 171:4

205:13 213:19 214:1

227:19 240:8 261:12
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Neal R. Gross and Co., Inc.

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316:6 320:18 329:20

339:3 348:21 373:21

374:2 384:1 398:10

404:6,15 406:6

417:17 423:20 426:13

426:21 428:5 431:5

438:9

surface 215:22 238:17

279:18 285:19 382:8

390:5

surfaces 287:14 379:20

388:2

surgeon 52:20,22

surgery 389:3 390:3

surgical 388:19 389:12

surprise 441:17

surprised 132:3,5

174:15 186:19

surround 253:2

surrounding 144:7

261:18 262:5 437:8

survey 194:4 199:17

200:21 245:17,18

surveying 359:19

432:11

surveys 119:11 196:11

197:19 312:17 432:3

suspect 302:20

sustain 190:20

sustainability 59:19

78:8 83:16 85:9 93:3

95:1 147:10 157:20

208:12 272:6 355:16

355:20 356:13,18

357:3,15,19

sustainable 60:1 73:20

74:1 82:6,11 87:8

93:10 143:14 145:13

146:11 159:1,5 191:6

206:10 241:7 253:6

355:8 356:17,22

357:1 358:2 433:6

sustenance 142:1

Suzanne 3:1 100:11

107:14,15,17

swab 66:14

SWAFFAR 1:19 23:1,19

23:22 99:17,20 100:1

121:9,13,16,19 126:9

126:16 127:2,10

167:8 250:19 251:1

277:9,14 286:1

287:21 288:18 323:15

328:16 332:10 333:17

340:20 342:3 351:15

352:16 360:5,20

363:19 364:13 365:7

386:14 387:4,17

389:1 390:14,18

391:15,21 394:21

395:1,20 397:5,12

398:5 399:3,16 400:3

400:18 401:19 402:22

403:8,19 404:14,16

404:22 405:5,17

406:1,5 408:21 410:7

411:5 412:19 418:13

418:21

Sweden 211:9

sweeping 20:16

sweet 13:13 275:8

swimming 63:1

swine 109:18

switched 318:19

synonymous 270:17

synthesis 239:20

synthetic 5:9 24:20,22

25:10 76:6 86:7

112:10 154:15 155:7

155:14 165:13 171:18

171:20 175:5,5 176:5

176:6 243:4 258:18

292:8,11,19 301:7,8

302:22 320:1 324:7

331:4,12 332:1 340:9

340:14 344:1,3,5

345:2,3,17 346:8

354:17 377:4,18

378:16 379:22 386:20

389:7 406:11

synthetically 154:13,19

154:21 156:17 158:7

290:6

synthetics 24:15 25:4

112:5 155:16 285:17

389:9 392:17

syrups 282:15

system 7:22 19:12

29:14 30:19 31:13,18

31:21,21 48:21 69:21

77:8 81:5 92:15 94:15

103:7 105:1,3,3,9

106:14 126:10 127:7

143:17,20 144:11,20

145:2,5 146:12 149:9

149:15 161:21 162:11

164:1,9 196:14

200:19 207:3 208:2

208:13,19,21 209:4

210:1 218:3 219:4

226:3,7 228:15

235:11 244:12 249:19

250:14 253:12 261:16

261:18 262:19 273:7

273:11,14 298:22

408:1,7 414:3 442:18

systematic 30:3

systems 19:13,14,18

21:1,3 53:14 81:8

82:17,19 86:13 92:9

98:20 99:13 100:18

100:20 101:18,21

102:15,16 103:15,18

104:1,12,14,15

105:18 106:13,18

125:4,9,10 126:11,14

127:7,12 128:12

129:3 130:11 132:7,8

133:12 141:4 143:14

143:15 147:13 173:16

173:19 191:4,17

207:17,21 209:1

210:22 211:12 216:5

216:17 218:1,9,18

219:6 224:9 227:18

229:9 231:4 249:18

250:1,1,7,16 251:9

257:16 392:8 442:22

T

table 100:6 227:19

242:18

tackle 142:2

tackling 51:20 76:19

tail 108:13 201:2

take 6:15 16:9,15,16

32:4 33:13,13,15,21

34:16 38:10 42:18

44:21 45:21 47:11,12

47:15 58:3 72:19

73:15 91:18 109:12

139:16 142:12 155:2

157:1 168:9 169:7,8

186:5 205:8 215:19

247:21 251:21 258:6

259:17 265:1 326:11

343:5 346:2 350:3

365:13 369:16 375:4

383:15 385:22 397:3

410:6 422:1 426:13

427:15 439:10 441:9

443:11

taken 31:7,19 40:4

172:10 218:4 252:21

253:10 260:12,22

292:20 347:4 375:17

397:2

takes 16:14,18 20:6

31:1 32:15 66:14 71:5

130:6 167:15 276:5

277:10 341:19

talk 16:7 17:14,15 38:4

38:11 40:16 48:17

80:17 88:20 133:13

140:14 178:20 179:18

183:22 187:7 215:12

237:1 249:1 274:19

373:16 386:16 393:7

393:8 405:8

talked 41:3 222:17

230:3 321:12 336:15

373:15 393:13

talking 57:1 122:7,11

141:3 177:5 185:13

187:22 193:16 221:7

228:18 229:17 250:13

370:22 438:16

talks 425:5

TAP 302:1

tape 16:18

targeting 433:13

Tartar 291:15

tartrate 4:9 291:3,6,13

292:1

task 70:8 123:10 124:18

125:3 127:19 132:5

140:17 185:21 216:16

261:2

taught 20:22

taxonomic 156:15,21

271:4

team 268:16 308:14

tearing 192:19

teaspoon 178:9

teat 388:20 389:5,12

teats 389:19 390:3

tech 271:18

technical 3:3 43:18

78:17 153:10 154:1,3

154:5 234:15 255:1

258:4,12 261:5 289:6

289:16 291:9 293:8

294:16 296:3 302:1

308:8,22 309:1 323:7

323:10 334:18 353:12

366:9 372:2 397:17

technique 14:4

techniques 26:13 28:3

70:21 71:4 270:13,14

271:10 415:6,13

technologies 65:1

337:6

technology 2:22 44:16

44:17,18 45:1,9 67:2

169:1,2 236:3,5

237:18 271:10,17

272:18 273:10,15,18

273:20 337:8 338:4,6

teeny 275:3

tell 30:9 31:11 77:17,19

156:7 202:13 218:19
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Neal R. Gross and Co., Inc.

492

220:3 223:5 224:5

229:22 231:3 308:12

371:5 405:12

telling 308:2

tells 86:15 231:11

temperature 231:8

232:9 239:1

temporary 128:6

141:17 181:8

ten 34:12 118:17

119:17 139:17 226:11

230:17 231:1 360:1

432:4,13 439:15

ten-minute 386:1

tend 200:18

tenets 436:16

tenfold 378:21

tens 34:13

tenure 19:7

TER 234:17

term 32:8 92:17 101:9

101:11,11 161:3,11

172:1 180:12 182:10

182:15,20 215:14

246:14,21 247:1,7,9

294:20 303:18,19

326:19 337:4 376:11

terminology 337:3

terms 31:14 65:19

66:22 84:2 134:10

135:1,6,13 137:14

185:12 195:14 196:3

200:6 238:14 268:8

301:15 307:22 313:7

313:22 355:16 368:6

376:3 414:18 416:7

416:19 442:15,21

terrible 70:16

terribly 86:16

test 29:13,15,21 30:7

33:11,12,14 43:5

44:18 45:15 46:2 47:4

48:14,21 68:1,3 213:3

234:13,22

tested 31:2,22 32:16

45:2,6 213:7

testified 133:1

testimony 51:7 58:14

61:6 69:4 79:11 85:13

145:21 153:6

testing 29:18 30:3

31:14 40:21 45:22

46:3 68:19 155:22

172:7 230:7 234:4

272:20 336:9

tests 29:16 30:9 46:16

46:18 47:4 48:5,10,12

49:5,5 231:10

textile 337:14

texture 236:20 294:2

thank 14:12 17:4,7,8

21:15 25:18,18 29:10

29:11 32:12,22 33:19

33:22 34:1 36:20

37:18,19 38:3 41:1

43:16 45:10 46:22

51:5,11,19 52:1 54:18

56:2 57:11,12,17 58:5

60:21,22 61:5,7,14

64:14,15 67:19 69:1,3

73:14 74:9 77:14,15

77:17 79:10,12,20

82:2 84:7 85:12 87:16

87:20,21 88:12 91:3,4

91:5,10 94:4 95:9,10

96:8 99:14,15 100:10

103:19,21 104:9

107:11,13,20 109:8

110:1,2,8,9 113:18,20

115:19 117:5,6,8,9

121:19 123:6 129:4

134:6 137:13 139:13

140:3 142:15,16,17

143:2 145:18,21

149:3,7 150:18 153:5

153:5 156:4,6 157:18

160:2,2,13 163:12,14

165:3 167:6 168:15

168:15,17,22 169:10

170:6,8,9,20,21

171:13 174:8,10

179:6,7,21 183:6,7,8

183:15 186:4,7,8,20

187:3 189:9,13,14

190:1 192:15 193:6

193:11,18 196:8,9

201:20,20,22 202:20

204:21 205:3 208:17

211:20 213:13,14

215:3,9 218:22,22

219:2 228:6 232:13

232:18,18,20 233:2,8

234:7 236:9,10

239:17,18 240:11,15

240:16 241:2 243:11

243:13,18 244:8

245:5 246:1,1,3

249:12 252:14 253:8

253:22 257:1,17,18

261:7,8,9 264:15,17

264:18 265:1 267:21

267:22 268:2,20,21

273:1,2,4 274:3,8

277:1,4,15,16,17

278:20 279:11,12

280:17 281:22 283:6

285:15 286:17 287:11

289:3,9 291:4 292:16

293:5 300:11 301:2

302:13 310:11,15

313:20 317:1,5

318:15 322:22 328:11

334:8 335:1 340:7

342:18 343:2 351:10

353:10 365:15,18

385:14,17 388:15,22

390:14,16 391:17

395:3,19,20 397:7

400:11 401:11 405:3

408:21 412:19 413:3

413:9 423:13 441:14

441:14 443:6,13,19

443:19,20

thanking 110:19

thanks 54:20 56:9 69:5

79:21 95:11 96:7

100:9 116:6 151:19

156:13 183:20 192:14

199:20 204:17 211:21

215:4 254:2 257:4

268:15 273:5 280:19

282:11 283:11 284:7

285:21 286:19 287:19

289:8 291:11 293:13

301:1 310:13 323:13

334:22 343:8 358:5

385:11 387:16 390:17

391:20 397:11 400:17

401:18 405:3 409:12

417:21 426:16 431:22

438:3 442:1

thefarmingfish.com

143:5

then-Acting 203:11

theory 327:3

therapeutic 391:19

392:12

THICKE 1:20 77:17,22

127:18 152:1,6 219:2

219:16 220:14 299:11

332:16 334:1 340:2

341:4 342:9 352:22

361:4 364:19 399:17

402:6 419:5

thickener 311:4

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thing 15:8 31:5 33:16

33:17 48:3 63:4 65:9

83:16 105:11 126:9

172:12 176:11 186:4

186:18 192:4 194:20

222:2 230:10,16

236:14,20 257:6

308:11 329:3 338:2

338:15,20 367:11

405:8 407:21 409:8

425:7 429:8 430:2

433:18 439:3,9

things 14:21,22 18:21

41:6,21 43:18 53:11

53:17 57:4 61:3 78:6

78:9 80:18 128:7,14

128:16 133:14 134:4

136:16 139:5 164:12

165:12 166:15 168:4

168:12 185:19 186:15

196:18 222:12,18

225:1,14,16 226:22

228:20 230:8 231:12

231:14 237:21 238:18

239:1 248:7 250:13

252:9 253:19 298:9

299:19 303:4 329:2

359:9 363:13 373:12

380:2 382:4,13

405:16 408:8 423:11

435:3 438:16 439:6

440:9 441:3 442:19

think 12:16 14:19,22

17:11 24:19 25:8,14

26:21 41:4 42:1,2,5,7

44:5,21 46:12 51:2

54:22 55:2,14 56:5,7

56:22 65:7 74:2,4,6

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Neal R. Gross and Co., Inc.

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traceability 62:1 123:12

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trail's 273:22

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trained 52:19 185:7

trainer 254:10

training 52:5,10 53:16

53:21,21 56:7 57:6,8

129:17 154:5 185:21

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412:17 414:9

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124:11,12,14 129:10

129:13 130:15 264:1

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144:17 241:22

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Neal R. Gross and Co., Inc.

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Neal R. Gross and Co., Inc.

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287:15,17 292:21

301:10 311:6,14

317:12 382:10 387:12

387:14

water-based 28:6

watercress 137:16

143:21 203:4

watered 126:6

watering 90:10

waterlines 388:5

waterways 144:7

Watts 3:15 179:15

215:6 232:20,22

233:1 236:18,22

238:10,12,19 239:8

239:12,15 240:1,16

wave 2:18 66:7 264:22

wax 68:12,12 335:17

way 8:17 10:21 20:22

22:12 33:3,8,11 35:10

46:5 60:1 67:8 68:10

76:11 96:4 109:1

115:12 122:3 125:17

137:11 142:14 144:21

159:12 194:18 206:21

207:16 217:22 218:7

220:21 222:9 223:18

225:10 237:8 270:6

274:19 305:12 306:3

307:17 357:3 370:1

378:5 381:8,16

383:18 389:22 392:12

394:14 399:9 407:13

425:10 426:5 427:15

427:20 428:4 441:6

ways 12:4 14:2 81:18

126:21 141:20 208:10

288:7 412:2 427:5

we'll 6:5,5,7 7:21 8:1

9:19 10:7 17:15 24:7

25:20,21 32:6 56:5

79:8 129:6 140:2,7

151:21 159:12 167:7

178:17 179:11,11,18

193:13 201:11 205:10

205:17 240:17 278:4

278:15 279:1 280:15

282:1 283:7 284:3

286:14 289:1 329:4

331:16 333:8 385:22

386:16 387:6 409:22

411:1,3 440:6 441:10

443:10

we're 9:18 10:12 16:19

16:21 17:9,17 20:2,3

20:15 22:14,19 23:7

24:11 33:1,2 38:2

46:15 51:6 55:9 56:1

57:21 58:9 61:20

66:19 70:12 74:15

78:21,22 91:12 107:6

130:1 131:6 133:1

143:6,11,14,17,22

145:11 151:1 152:16

164:22 169:2 174:22

176:14,20,20 177:11

191:14 205:7 214:9

223:18 226:5 229:19

230:4,5,7,14,22

231:11 232:2,2 243:4

245:1 249:18 254:11

259:16 261:3 278:11

278:17 279:7 280:17

302:3 304:7,14 310:3

310:6 315:2 320:22

322:16 330:20 331:19

332:19 340:5 349:10

353:11 369:16 372:17

374:2 377:9 379:4,5

382:4 386:8,11,18

397:7 411:2,6,11

414:7 420:19 421:8

430:20 436:9

we've 8:18 9:2 10:22

11:6 19:3 52:12 53:12

78:11 80:1,6 104:4

105:12 143:7 154:3

159:4 164:7 165:8

170:18 176:19 188:20

191:13 193:15 197:18

210:12 230:3 233:13

242:10 246:6 255:1

260:3 281:12 282:20

301:9 307:8 318:19

320:3 321:12,16

347:4 356:7 414:1

429:10 435:6

weaken 275:14

weapon 275:13

wear 186:3 248:13

weave 274:13

web 274:13

webinar 51:10 77:10

224:3

website 25:8 143:5

291:10 323:11 334:15

weed 12:1 13:9,11,21

15:15 42:7 226:21

237:18

weeding 13:11

weeds 227:1

week 8:17 10:20 23:14

121:20 150:2 339:7

413:18

week's 403:17

weekly 25:12

weeks 23:14 189:1

weigh 201:8 261:6

384:4

weighed 60:15

weighs 197:6

weight 311:6

weird 157:13

Weisman 3:16 85:14

87:21 88:3,3

Welch 117:11

welcome 6:3 58:2 79:20

88:9 170:10 188:12

257:19 258:6 265:4

296:9 386:14

welfare 107:6,18

108:15,20 109:13,21

188:22 257:12 393:5

402:3 403:4 410:16

410:21 411:15

well-being 172:9 191:1

198:1

well-known 153:19

well-vetted 164:15

Welsch 3:17 123:7,9,9
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Neal R. Gross and Co., Inc.

497

126:15,20 127:5,12

128:2 129:7,16

130:22 131:21 133:7

134:14 135:5,12

136:14 137:19 138:7

138:21 139:10

went 9:14 140:5 203:20

205:5 278:5 297:2

321:10 358:15 386:4

444:9

weren't 72:14 176:16

343:4 436:13

West 311:2

western 430:12,15

wetland 102:8 192:20

439:10,11,12

wetlands 439:14,17

440:18

WFA's 263:18

whatsoever 209:15

wheel 255:21

whiny 275:3

Whitcher 3:18 110:11

117:13,14 121:1,12

121:15,18,21 122:13

122:16 123:1

white 135:9

whites 291:17

WhiteWave 393:19

wholesale 22:6 98:8

143:10

wholesalers 2:11 96:14

97:1

wicked 274:13

wide 97:12 100:4 154:3

184:10 288:1,5

widely 153:21 208:7

268:10 403:2

wider 165:15 418:4

wife 140:13

wild 78:8 82:12,13 93:3

137:21 138:1,8,9,14

138:16 262:13 263:15

263:20 355:18 422:9

426:11 439:4

wild- 157:21

wildlife 196:15 262:9

422:10

willing 229:11

windfall 119:10

wine 281:6,14 283:3

291:14 292:3 304:12

336:2

winemaking 292:7

winter 13:13 151:9

152:19 389:21

Wisconsin 187:2

296:21 394:9 439:9

wisdom 140:16 191:21

wish 220:5 320:9

wishes 35:5

wit 191:21 274:12

withdrawal 108:6

395:15 396:8 400:14

401:15 403:11 406:16

withdrew 8:21 10:3,6

11:3

withholding 247:17

404:18

witness 184:9,22 185:3

185:7

Wolf 3:19,19 74:10

79:13,16,16,16 82:16

84:9 85:1

wonder 114:7 390:8

wonderful 14:11 95:10

439:2

wondering 21:22 56:14

104:2 120:19 131:10

150:19 156:10 159:3

159:10 174:16 175:6

177:2 302:21 338:3

377:6,9 382:4

wood 215:15 222:1

wooded 432:7

word 19:21 22:16 26:14

77:6 83:13 129:8

233:13,14 354:2

wording 137:21 138:12

186:9 345:11 346:15

346:16

words 206:13 258:22

351:8 432:6,18

wordsmithing 251:20

work 21:11,13 29:3

39:22 51:19 54:9 55:9

58:6 67:14 75:3 76:10

79:20 86:1,9 91:2

99:7 100:16 120:21

121:1 123:2 124:18

127:18 144:9 159:3

163:6,12 171:14

183:19,20 187:4

188:9 189:4,6 190:4

191:8 192:3 206:4

211:10,10 215:9

217:22 219:20 223:13

232:11 233:1 246:20

254:16 258:3 259:18

265:3 276:14 349:6

358:20 359:18 367:2

370:7 377:11 380:12

394:8 409:13,13,22

411:1 412:13 414:10

416:5,13 417:4,20

423:16 425:7 426:6

workable 101:6

worked 18:3 96:17

210:17 266:8 296:16

400:21 401:22 423:21

workers 86:7 144:13

working 11:20 18:17

21:1 37:3 38:5 39:16

51:3 52:7 56:15

102:19 109:22 191:22

230:22 256:11,19

258:11,16 372:3

410:17 418:3 434:10

workload 75:20

works 79:18 91:1 97:19

125:12 219:4 229:20

359:16,21

workshop 256:8

workshops 433:5

world 29:8 44:14 46:14

52:6 84:1 91:15 198:1

207:21 271:18 276:14

316:9 349:20 422:9

422:13 424:16 429:19

436:1 437:15

world's 60:12 85:22

207:1

worms 141:12 260:14

365:21 379:8,17

380:13 381:7

worried 70:12

worries 177:21

worry 62:15 171:7

371:6 404:1

worst 46:3

worth 22:7 85:8 425:3

435:17

wouldn't 130:3 176:7

195:20 202:16 249:17

249:18 290:21 330:7

338:17 385:4 405:20

406:6 421:21 428:5

wounds 389:4

Wow 274:11

wrap 382:15 440:7

441:11

wrapping 435:8

wrestle 184:4

wrestled 203:21

wrestling 149:10

write 121:10 351:5

405:12

writer 140:13

writing 52:12 61:4

411:2 413:14

writings 140:18

written 19:1 72:15

83:10 104:22 106:2

115:12 137:4 156:7

180:6,21 183:16,21

186:10,13,14 187:13

192:11 204:2 259:4

259:20 260:4 395:7

395:12 396:5

wrong 15:10 197:10

wrote 186:18 288:10

357:16

Wyard 3:20 139:21

254:4 258:1,1

X

xylazine 167:3 182:19

395:15 396:1,1,7,17

397:1,3

Xylitol 169:9

Y

yam 310:16

yeah 16:3 23:7 24:2

32:5 38:3 46:20 48:20

49:11 55:17 56:3 91:7

95:14 104:17 105:5

105:22 106:17 114:12

115:19 120:21 130:22

150:19 151:16 158:19

167:22

year 17:2 56:8 86:2

90:20 119:16,16

124:13,16 129:14

130:15 148:22 181:4

181:7 226:11 241:19

272:8,17 282:20

291:11 294:17 325:21

353:11 404:17 414:1

417:13 421:15 425:8

year's 80:7 254:13

411:8

year-round 151:8,11

years 8:20 9:3 11:2,7

18:9 34:12 46:9 52:10

53:13 62:13 63:14

71:21 86:5 87:12

88:17 89:1,6 118:13

121:7 133:19 143:8

145:10 154:2 169:15

184:18 190:3 210:17

212:8 226:18 233:13

242:15 254:8 258:13

264:1 266:7 271:1

297:17 376:10 392:22

409:11 414:15 417:12

420:2 424:6,10 425:5

428:1 432:13 436:10

436:19 439:14,16,19

442:6,17

years' 13:8 57:20

yeast 348:2
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498

yellow 8:1

yesterday 6:18 41:4

58:8,14 86:12 193:16

193:22 195:6 278:6

328:17 339:8

yields 27:21

yogurt 299:15

young 18:14 21:18,20

23:10 70:19 148:16

223:15

Yup 121:13

Z

zero 37:11 104:4

118:18,18 149:1

311:2,2 332:22 334:4

341:8,16 342:20

353:6 361:19 365:4

419:14

zinc 398:6 399:1

Zurich 49:15

0

0.06 45:20

1

1 336:6

1,200 180:4

1,750 199:15

1.0 45:21

1.5 119:16

1.6 263:4

1:30 179:12 205:2

1:31 205:6

10-20 50:8

10:52 140:5

100 63:3 97:3 172:20

173:2,7 181:2 201:3

203:15 212:20 219:4

226:6 237:9,11,14

325:11

100% 44:3 45:2,8 49:22

51:2 95:21

104.20 324:15

105 430:5

10th 194:15 334:16

11 90:21 264:9 280:5

281:12

11:07 140:6

12 123:2 148:21 194:15

438:8

12-3 9:6 11:10

12:14 205:5

12:15 179:11

1200 110:16

124 234:21

13 264:9 272:8

13C 47:14

13th 418:10

14 200:12 224:3 281:12

282:21

14th 334:9

15 12:7 46:8 66:14

118:13 256:6,14

332:22 334:3 341:7

342:20 353:5 361:19

365:4 419:13

15-1 9:7 11:11

150 269:20 434:21

150-member 18:7

152 234:21

1550 1:10

16 282:21

16% 119:17,22

160-fold 46:5

17% 119:20

1760 234:18

18 63:12 90:20

180 434:21

19 432:4

1972 202:17

1983 8:15 10:19

1985 171:11

1986 8:19 11:1

1992 63:12

1995 324:3 390:20

392:17 396:13

1997 154:7 237:14

19th 411:16

2

2 378:8

2,000 160:9 188:1

2.3 119:19,21

2.5 107:21

2.8 63:16

20 1:7 13:8 33:2 45:3

52:10 86:5 89:1

169:15 200:11 210:17

217:11 230:18 254:8

258:13 386:15 432:5

200 353:14

2000 135:16

2001 191:3

2002 26:11 135:17

2003 258:14 265:8

2005 88:6

2006 90:5 265:9

2007 34:16

2008 263:6

2010 88:6 128:13

2011 53:5 57:5 254:19

255:9 280:3 325:21

2012 8:20 11:2 263:7

323:10 325:20

2013 258:20 265:11

2014 26:17 63:12

212:11

2015 89:14 266:1 280:4

281:9 282:20 283:22

285:11 287:6 289:13

289:18 291:18 294:14

303:9 311:21 322:2

343:17 396:14

2016 289:8 293:9 323:3

334:9 353:20 413:17

418:10

2017 1:7 89:4,22 187:7

261:5 265:15 281:11

292:18 305:18 334:17

343:16 356:10 396:15

2019 4:3 5:3 97:6

278:12 386:16 401:13

2027 53:6,18 184:14

187:22 254:12 413:12

413:18 416:14 417:16

205 395:11

205-204 180:16

205-204a 181:1

205-238 161:6

205-601J1 154:15

205-603 182:18

205.105 100:21 102:21

425:20

205.2 269:9

205.200 76:21 77:6

205.203 235:5

205.272 368:19 376:17

205.501(a) 415:2,16

205.501(a)(21) 414:16

205.603 386:19 390:17

397:8

205.603(b) 400:12

205.605 75:19 116:1

279:1 285:16 334:12

335:21

205.605(a) 111:7,11

112:3 344:21

205.605(b) 111:9 323:5

333:3 341:12 362:4

205.605a 279:9

205.605b 287:12 290:3

205.606 111:10 116:1

300:13 317:3

21 184:18 324:15 395:9

22 188:2

2205.2 234:6

23% 121:11

238d 161:7

24 121:6

25 62:13 198:8 439:13

439:16

250 160:11

26 8:20 11:2

278 4:4

280 4:4

282 4:5

283 4:5

284 4:6

285 4:6

286 4:7

287 4:8

289 4:8

29 234:20

291 4:9

293 4:9

3

30 133:19 143:11

198:14

30% 131:16

300 4:10

3012 36:9

310 4:10

316 4:11

322 4:12

334 4:12

343 4:13

35 385:19

353 4:14

36 164:2 281:20

361 4:16

365 4:18

37 154:3

370 4:20

37220-17-0 310:13

38 394:4

386 5:4

390 5:5

391 5:5

395 5:6

397 5:6

3rd 323:3

4

4,800 153:19

4.2.1 181:10

4:00 183:18

4:20 385:21

4:35 385:22 386:4

4:45 386:1

4:47 386:5

40 24:9 57:20 139:14

148:8

40-acre 143:6

400 5:7

401 5:7

406 5:9

413 5:15

419 5:18

423 5:20

444 5:22
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45 198:9

5

5:55 444:9

50 209:19 210:3 221:11

223:3,5,9 229:13

230:19 311:6 424:6

424:10

50,000 201:14

500 199:16 436:10,19

5029 136:5,13

53 63:15

530 395:9

59983 395:5

6

6 4:2 341:16

601 83:14 97:5

602 158:6

605 345:21 350:16,17

605(a) 89:5,12

605.205(b) 323:16

605a 285:9 290:3,16,18

606 88:21 89:22 90:2,8

90:20 91:1 111:17,19

112:1 115:13 304:2

305:6,22 306:10,12

307:9,13,22 309:8,22

319:13 327:3 335:21

345:5,21

65 198:8 363:13 368:5

650 271:16

6512 428:8

6513 137:15

7

7 387:10 395:11 435:13

70 152:6 403:12

700 171:12

8

8:30 1:10 443:22

8:33 6:2

8:36 9:14

8:43 9:15

80 326:20 432:3

80% 14:17 19:4

81 195:1,14

86 234:21

9

90 400:14 401:16

403:13 407:2 432:3

90% 40:17

900 160:11 188:19

91 195:14

95% 96:3

99 264:5
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

500

Board Meeting

USDA National Organic Standards Board

04-20-2017

Denver, Colorado
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1

 U.S. DEPARTMENT OF AGRICULTURE

 + + + + + 

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 MEETING

 + + + + +

 FRIDAY

 APRIL 21, 2017

 The Board met in the Majestic Ballroom

of the Sheraton Denver Downtown Hotel, 1550 Court

Place, Denver, Colorado, at 8:30 a.m., Tom

Chapman, Chairperson, presiding.

PRESENT:

TOM CHAPMAN, Chair

SUE BAIRD

HARRIET BEHAR

ASA BRADMAN

JESSE BUIE, Secretary

LISA DE LIMA

STEVE ELA

DAVE MORTENSEN

JOELLE MOSSO

EMILY OAKLEY

SCOTT RICE

A-DAE ROMERO-BRIONES

DAN SEITZ

ASHLEY SWAFFAR, Vice Chair

FRANCIS THICKE
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STAFF PRESENT:

MICHELLE ARSENAULT, NOSB Advisory Board

 Specialist, National Organic Program

LISA BRINES, Ph.D., National List Manager,

 National Organic Program

PAUL LEWIS, Ph.D., Director, Standards

 Division, National Organic Program

MILES McEVOY, AMS Deputy Administrator

JESSICA WALDEN, Materials Specialist,

 National Organic Program
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 C-O-N-T-E-N-T-S

Welcome/opening Remarks:

 Tom Chapman, Chairman. . . . . . . . . . . . 4

Crops Subcommittee . . . . . . . . . . . . . . . . 4

Sunset Materials

 Chlorine . . . . . . . . . . . . . . . . . . . . 4

 Herbicides, Soap-Based . . . . . . . . . . . . . 6

 Biodegradable Biobased Mulch Film. . . . . . . .14

 Boric Acid . . . . . . . . . . . . . . . . . . .19

 Sticky Traps/Barriers. . . . . . . . . . . . . .22

 Copper . . . . . . . . . . . . . . . . . . . . .26

 Humic Acid . . . . . . . . . . . . . . . . . . .30

 Soluble Boron Product. . . . . . . . . . . . . .40

 Micronutrients: Sulfate, Carbonates,

 Oxides, Silicates of Zinc, Copper,

 Iron, Manganese, Molybdenum, Selenium

 and Cobalt . . . . . . . . . . . . . . . . . . .47

 Vitamin B1, C and E. . . . . . . . . . . . . . .52

 Lead Salts . . . . . . . . . . . . . . . . . . .54

 Tobacco Dust . . . . . . . . . . . . . . . . . .55

Proposal: Strengthening the Organic

Seed Guidance. . . . . . . . . . . . . . . . . . .57

Proposal: Marine Algae Listings. . . . . . . . . .65

Discussion Document: Aeroponics/Hydroponics/

Aquaponics . . . . . . . . . . . . . . . . . . . .72

Materials Subcommittee Update. . . . . . . . . . 179

Policy & Development Subcommittee Update . . . . 181

Deferred Proposals/final Votes . . . . . . . . . 187

Subcommittee Work Agendas Update . . . . . . . . 191

Other Business/Closing Remarks . . . . . . . . . 200

Adjourn. . . . . . . . . . . . . . . . . . . . . 207
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1 P-R-O-C-E-E-D-I-N-G-S

2 8:33 a.m.

3 CHAIR CHAPMAN: Okay. Good morning,

4 everyone. Welcome back to the NOSB meeting. We

5 will come back into session now.

6 First up in the morning is the Crops

7 Subcommittee and, Francis, if you are ready, it's

8 yours.

9 DR. THICKE: Thank you, Tom. So

10 first, we are going to look at the Sunset

11 materials. And I believe all of these Sunset

12 materials were reviewed in 2015, so these are on

13 the accelerated schedule.

14 And the first three are chlorine

15 materials and we will have -- we are going to

16 combine these in our review. And, Dr. Brines,

17 would you read into the record the information?

18 DR. BRINES: Yes. Thank you. So we

19 are starting under Section 205.601 of the

20 National List, Synthetic substances allowed for

21 use in organic crop production.

22 (a) As algicide, disinfectants and
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1 sanitizer including irrigation system cleaning

2 systems.

3 (ii) Chlorine materials for pre4 harvest used, residual chlorine levels in the

5 water in direct crop contact or as water from

6 cleaning irrigation systems applied to soil must

7 not exceed the maximum residual disinfectant

8 limit under the Safe Drinking Water Act, except

9 that chlorine products may be used in edible

10 sprout production according to EPA level of

11 directions.

12 We have one:

13 (1) Calcium hypochlorite.

14 (2) Chlorine dioxide.

15 And (3) Sodium hypochlorite.

16 Thanks.

17 DR. THICKE: Thank you. And I guess

18 I'm the assigned lead for all three. These are

19 materials that are registered with EPA as

20 pesticides or disinfectants, sanitizers. They

21 tend to be highly caustic and a concern for

22 occupational exposure. Acute exposure to high
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1 concentrations can cause eye injury and skin

2 problems. Ingestion can cause gastrointestinal

3 irritation.

4 So they are not really benign

5 materials, but they -- the comments indicated

6 that they are widely used and they are necessary

7 that they are used as -- for a wide range of

8 uses, including sanitation of equipment and work

9 surfaces, maintaining functioning irrigation

10 systems and preventing the spread of disease.

11 There was -- there are also some

12 comments that these materials are hazardous and

13 that we should look at alternatives and

14 suggestions that we should look at a

15 comprehensive review of sanitizers to see when

16 these are needed and when they may not be needed.

17 And there has been some discussion

18 here with the NOSB on that.

19 The next material is herbicides, soap20 based. Well, first of all, I should ask, anybody

21 have any comments or questions about the chlorine

22 materials? Okay. 
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1 MR. BRADMAN: One comment. Well, two

2 actually. One is just anecdotally in the work

3 that we have done with farm workers and packing

4 house workers in the Salinas Valley, we often

5 hear complaints from workers about exposure to

6 bleach-related products.

7 In fact, sometimes they will complain

8 more about that than experiences with pesticide

9 residues in fields and things like that. So at

10 least in the worker population, there is

11 definitely concern about that.

12 Another piece is that EPA is going

13 through a fairly comprehensive process reviewing

14 disinfectants and sanitizers. A lot of that is

15 related to childcare, schools and things like

16 that, but there might be a base of information

17 that is now residing in the Safer Chemicals

18 Program at EPA that will be relevant also to food

19 safety.

20 DR. THICKE: Oh, thank you. That's

21 interesting information.

22 MR. BRADMAN: Thank you.
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1 DR. THICKE: Any other comments? Yes,

2 Ashley?

3 MS. SWAFFAR: So I also know quite a

4 little bit about chlorine materials. You and I

5 are always the chlorine folks. And I just want

6 to say how I feel about chlorine materials. Yes,

7 there are alternatives like with hypochlorous

8 acid and things like that, but when I look at

9 chlorine materials, I think of very small farmers

10 and their availability of some of those

11 alternatives.

12 And we want to produce safe food for

13 our customers and I just think, you know, these

14 chlorine materials are pretty readily available. 

15 I know on my farm I can go to any dollar store,

16 Walmart, anything and get bleach products, so I

17 look at these chlorine materials as availability

18 for small-scale farmers. So just wanted to say

19 that.

20 DR. THICKE: Good point. And in dairy

21 situations, there are -- some alternatives are

22 not as effective as chlorine. Thank you. Yes,
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1 Joelle?

2 MS. MOSSO: I just want to echo that

3 from a food safety perspective, right now, there

4 is not any sanitizers that are, you know,

5 replaceable for chlorine in all situations at

6 all. And it would be considered critical to food

7 safety as well as compliance with other

8 regulatory bodies for food safety, FSMA, being

9 the --

10 DR. THICKE: Right. And I think if we

11 were to do an over -- a comprehensive review, we

12 would want to look at where it is required by law

13 and where it is needed and where it may not be

14 needed. Any other comments on chlorine?

15 Okay. So we will move on to the herbicide

16 soap-based. And, Sue, I believe you are the lead

17 for that.

18 MS. BAIRD: Yes.

19 DR. BRINES: I'll stop you while I

20 read it into the record.

21 DR. THICKE: Oh, sorry.

22 MS. BAIRD: Oh, yes.
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1 DR. BRINES: It's all right, Francis,

2 you can't see my hand here.

3 DR. THICKE: You're behind me.

4 DR. BRINES: We'll get it. All right. 

5 So we are moving to paragraph (b):

6 "As herbicides, weed barriers, as

7 applicable (1) herbicides, soap-based - for use

8 in farmstead maintenance (roadways, ditches,

9 right of ways, building perimeters) and

10 ornamental crops."

11 Thank you.

12 MS. BAIRD: Now me?

13 DR. THICKE: Yes.

14 MS. BAIRD: Hi. Okay. My topic is

15 Sunset for herbicides, soap-based. Soap-based

16 herbicides generally are comprised of a fatty

17 acid component with carbon, hydrogen and oxygen

18 atoms that have been bonded with either potassium

19 or ammonium counterions.

20 The potassium salts include individual

21 soap salts, such as potassium laurate, potassium

22 myristate, potassium oleate and potassium
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1 ricinoleate. And they are produced by a process

2 known as saponification and that's probably one

3 that most of us, even lay people, know that term.

4 The ammonium nonanoate on the other

5 hand is produced through room temperature

6 reaction of aqueous ammonia or ammonium hydroxide

7 with those fatty acids.

8 There were, for me at least,

9 surprisingly quite a few comments on this. We

10 had 25 total comments comprised from farmers,

11 farmer groups, certifiers and actually industry

12 people. And we heard overwhelmingly 22 of those

13 25 comments were in support of retaining the

14 herbicide soap-based on the National List.

15 Three of those that were against it

16 were concerned about a study that had been a

17 technical review study that had been done that

18 showed that it could impact earthworms and some

19 of the other soil-based systems. It was shown

20 that there could be runoff in water and if it is,

21 it might particularly harm some of the water22 based systems.
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1 We heard yesterday public comment that

2 someone said that that technical review was based

3 on an old data and that there has been new data

4 released by EPA that shows that their new

5 technology no longer impacts those organisms. So

6 that's it.

7 DR. THICKE: Thank you, Sue. Any

8 questions or comments on soap-based herbicides? 

9 Emily?

10 MS. OAKLEY: So in reading the public

11 comments, I think I mentioned this to one of the

12 stakeholders, it seemed that some people, some

13 farmers might be using them in off-target ways. 

14 Do you have any thoughts on that?

15 MS. BAIRD: Yes. And I would verify

16 that. As an organic inspector, I have seen that,

17 especially, out in the grain fields perhaps

18 Nebraska, Kansas that they -- because it was

19 already listed, they thought that that meant for

20 all types of production and we did -- I have run

21 across two or three large grain farmers that were

22 using it as a complete burn down of those fields
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1 prior to replanting.

2 They have real issues in that part of

3 the world with water. In fact last year, this

4 year they have lots of rain, but last year they

5 were at a level of rainfall that was less than in

6 the Dust Bowl Age.

7 So they are looking for ways to not

8 turn that soil. And so they were using it. In

9 fact, I think there is -- some of the commenters

10 actually asked that we take the annotation off of

11 it because of that reason. Yes?

12 MS. OAKLEY: I also thought one of the

13 farmer commenters in the public comments

14 referenced that they might be using it within

15 orchards as well. So I think, you know, this is

16 something that might need a little more

17 conversation when we go back and review it

18 further in our Crop Subcommittee.

19 MS. BAIRD: Yes. Thank you.

20 DR. THICKE: Thank you. Any other

21 comments? Okay. Thank you, Sue.

22 MS. BAIRD: Thank you.
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1 DR. THICKE: Then we will go on to

2 boric acid. Lisa? Oh, I'm sorry, biodegradable

3 biobased mulch film is next.

4 DR. BRINES: Okay. Thank you. So we

5 are still under paragraph (b) moving to (2)

6 Mulches. The listing is biodegradable biobased

7 mulch film as defined in Section 205.2, must be

8 produced without organisms or feedstock derived

9 from excluded methods. Thank you.

10 DR. THICKE: Harriet, are you the lead

11 on that?

12 MS. BEHAR: Okay. So biodegradable

13 biobased mulch films were approved for placement

14 on the National List without detailing how much

15 of the non-biobased content was allowed. So we--

16 and there was an NOP guidance document, I'm sorry

17 I don't have the number right here, that then

18 said that it had to be 100 percent biobased.

19 So we thought we would get a TR, since

20 we knew that the Sunset was coming up, to see if

21 we could address the issue because currently

22 there are no biodegradable mulch films that are
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1 biobased. There is a paper mulch that is fully

2 biobased and biodegradable. And it is already

3 listed.

4 So to say that there is no

5 biodegradable mulches out there, when it's mulch

6 films really that we are looking at.

7 DR. THICKE: No 100 percent, right? 

8 No 100 percent biobased?

9 MS. BEHAR: Yes. No. I'm not sure

10 about the paper. The paper might be 100 percent

11 biobased.

12 DR. THICKE: That's what I mean, there

13 are some that are partially biobased, correct?

14 MS. BEHAR: Yes.

15 DR. THICKE: Yes.

16 MS. BEHAR: But this -- the one that

17 we are talking about here, the mulch films --

18 DR. THICKE: Oh, okay.

19 MS. BEHAR: -- are -- do contain

20 petroleum polymers.

21 DR. THICKE: Yes.

22 MS. BEHAR: And that other one is a
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1 paper product that is all biobased.

2 So we did get a lot of comments about

3 this. The policy is Memorandum 15-1. I just

4 found it here. That the NOP said it had to be

5 100 percent.

6 So since there is nothing on the

7 market, there is somewhat of an issue at the

8 Sunset for us to review. Are we putting a

9 product on the list that doesn't actually exist?

10 You can see it as a way to encourage

11 someone to try to manufacture something that

12 meets the standard that we have or others would

13 say we need to either change the annotation or

14 work with the NOP on having them rescind that

15 memorandum and do something else.

16 So I think as you know, we did have a

17 lot of verbal public comments. We also had quite

18 a few written public comments with many of them--

19 some saying just retain it and hope that we can

20 eventually get someone who can meet this fully

21 biobased biodegradable standard. Others saying

22 that we should find a way to be able to provide
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1 this product for use to organic producers.

2 We have also heard from organic

3 producers that really want to use it and from --

4 when this was first put on the National List, it

5 was a lot of farmer comment of how they would

6 really like it and there were many very well7 respected organic farmers that said they have

8 dropped their organic certification strictly

9 because they cannot use this product currently in

10 organic production.

11 So I think we are trying to find

12 something, but one of our issues with trying to

13 convince the NOP to change their policy menu --

14 memo is that we need to have a reason for that

15 change. They have a reason for putting that memo

16 out and so we would need to come up with reasons.

17 And that's why we asked for a

18 technical review and we asked a variety of

19 questions in that technical review to help us

20 possibly put forward a recommendation to the NOP

21 about changing.

22 And so if we were going to say oh, we
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1 think that 20 percent biobased is good enough and

2 this is because there is this research, there is

3 no damage to the soil or, you know, there is no

4 residue of heavy metals, you know, all the

5 questions that we ask that it is fully

6 biodegradable, but the TR was inconclusive

7 because this is a fairly new product and right

8 now we are two years into a 5 year research at a

9 university to be able to tell -- maybe answer

10 some of these long-term effects on the soil.

11 So we are kind of a little bit in a

12 quandary. However, here we did have quite a bit

13 of public comment, especially from the

14 manufacturer, where we -- I feel like I learned a

15 lot more, I hope other people did, too, about

16 this product that it is -- that the polymers are

17 fully biodegradable. I don't think there is

18 actually-- I think the research even found that

19 as well.

20 But the question is how we feel about

21 a petroleum-based product even if it fully does

22 biodegrade into the soil. So our question would
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1 be at Sunset are we just going to relist as is? 

2 Are we going to relist and then come forward with

3 a change and annotation or are we going to relist

4 and try to work with the NOP on changing that

5 policy memo?

6 So that's where I see kind of our

7 three choices and I would say that we have not --

8 the Crop Subcommittee will be discussing that

9 further.

10 DR. THICKE: Thank you, Harriet. Any

11 other comments or questions from the Board? 

12 Okay. So we will move on next to boric acid.

13 DR. BRINES: Thank you. So we are

14 moving to paragraph (e) As insecticides

15 (including acaricides or mite control). And the

16 listing is boric acid - structural pest control, 

17 no direct contact with organic food or crops. 

18 Thank you.

19 DR. THICKE: Okay. Harriet, I believe

20 that's you again, is it?

21 MS. BEHAR: Yeah. I like things that

22 begin with Bs.
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1 Okay. So boric acid is used to

2 control ants and roaches mostly in pack houses

3 and fields, since this is crops, listed in the

4 crops, so we are really talking about handling. 

5 And we did get a few comments. Some certifiers

6 said that it really wasn't used in crops. Some

7 industry commenters really wanted to be relisted

8 and that it is used quite a bit, especially in

9 the pack houses.

10 And we did get a few comments about

11 changing the annotation that it would be used

12 only as a bait in traps or in gel formulations,

13 because there is an issue with it when it is in a

14 powder that it can be a respiratory irritant.

15 So that's it.

16 DR. THICKE: Any other comments?

17 MR. BRADMAN: Just a quick comment. 

18 I do a lot of training around structural pest

19 control and for the California DPR Structural

20 Pest Control Board and we encourage the use of

21 boric acid as an alternative, just because it has

22 a much lower acute toxicity and we also encourage
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1 use in bait and gels in non-dispersive methods if

2 it's in a powder only in a void, an inaccessible

3 void or a thing like that. Similar to like

4 diatomaceous earth.

5 So this is something that we encourage

6 for, again, structural pest control, including

7 childcare if it's in a bait and gel form.

8 DR. THICKE: Thank you, Asa. Any

9 other comments? Harriet?

10 MS. BEHAR: So I'm just wondering if

11 we should in the Crop Subcommittee be looking at

12 a change in annotation perhaps? Would you

13 recommend that?

14 MR. BRADMAN: I think I need to learn

15 a little bit more about that.

16 MS. BEHAR: Okay. So we will just

17 discuss that further. But this might be another

18 item that we are looking to improve the

19 annotation.

20 DR. THICKE: Something we can discuss

21 in committee. Thank you. Any other comments on

22 boric acid? Oh, Steve?
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1 MR. ELA: I would just say following

2 Asa, I think it is an effective material and I

3 was -- in terms of the annotation, I think the

4 gel or form makes a lot of sense. I just heard

5 Asa say, you know, there are places and traps and

6 things that you can't get a gel or -- thing into,

7 so powder could be -- I don't know how we can

8 address that per se, but it sounds like that

9 could be something we might not want to restrict. 

10 Especially for ant control, it gets -- you know,

11 being able to put it in powders or in a powder

12 form in a crack can be very useful.

13 DR. THICKE: Thank you. Sue?

14 MS. BAIRD: Yes. I do a lot of

15 inspections of the large vegetable pack houses

16 and I see it used in the cracks a lot. They are

17 doing it like a crack and crevice type thing. So

18 I do see it being used in vegetable pack houses.

19 DR. THICKE: Okay. Thank you. 

20 Anybody else? All right. We will move on to the

21 next material is sticky traps/barriers. And that

22 is Emily.
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1 DR. BRINES: Okay. All right. So we

2 are continuing on to -- in paragraph (e), the

3 next listing is Sticky Traps/Barriers. Thanks.

4 MS. OAKLEY: Thank you. These are

5 typically used for pest control and monitoring in

6 limited quantities and in confined areas, such as

7 tree trunks. These products are of low toxicity

8 and while persistent, they are unlikely to

9 contaminate the surrounding environment.

10 And in this most recent review that

11 happened a year ago or so, there was widespread

12 support for the continued listing of sticky traps

13 and barriers. And as a permitted synthetic given

14 both their availability and their effective

15 control, they have been in use for a long time

16 proceeding the NOP standards as well in organic

17 production.

18 And we received widespread comment in

19 support of these from farmers, from certifiers,

20 from handlers. They are used in the fields, in

21 greenhouses, storage and in other areas. 

22 There was a comment by a citizen that
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1 they are inhumane and they can sometimes trap

2 non-target insects, which is certainly

3 unfortunate. I think hopefully they can be used

4 in a way that avoids that.

5 One commenter asked if we would

6 explore the possibility of an annotation that

7 might say must be used in a way that prevents the

8 capture of non-target animals. So that's

9 something that we could explore. Hopefully

10 people are already doing that, but an annotation

11 might encourage that further.

12 Are there any questions or comments

13 about it? Yes?

14 MR. BRADMAN: I just had a question. 

15 Besides it's out there also, I would assume, used

16 as monitors, but I know they are used, you know,

17 for example, cockroach monitoring in food

18 facilities. So is that used separate from

19 insecticides? You know, in insect control use or

20 was it all bundled up in here?

21 MS. OAKLEY: Yeah, that's a good

22 question that I actually had while reading the
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1 comments, so I'll either defer that to Francis or

2 someone else who has the answer for that. Scott

3 looks like he is nodding his head.

4 MR. RICE: Yeah, sticky traps are used

5 for monitoring in orchards and other production

6 areas and greenhouses to see when a certain pest

7 pressure level has been hit.

8 CHAIR CHAPMAN: Utilizing this

9 listing? Like this listing is what is

10 authorizing that use. Is that correct?

11 MR. RICE: For crops, yes.

12 CHAIR CHAPMAN: Yeah. 

13 DR. THICKE: Steve?

14 MR. ELA: Yeah, I would echo that this

15 is what we would use, traps, were -- and they

16 would be imperative to our whole Insect and

17 Disease Control Program, because we put traps out

18 and then only spray follow-up sprays if we need

19 to, based on these traps. So they are a pretty

20 critical part of the orchard system for sure.

21 MR. MORTENSEN: They are also critical

22 in glasshouse biocontrol deployment for
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1 monitoring pest/insect dynamics.

2 MS. OAKLEY: Yeah, and they are

3 definitely used in a way to help minimize

4 pesticide applications.

5 DR. THICKE: Okay. Any other

6 comments? Okay. Thank you. Next we have two

7 coppers and we are going to combine them, because

8 the comments pretty much overlapped. And, Lisa?

9 DR. BRINES: All right. I'll read

10 them both into the record. We are under

11 paragraph (i) now As plant disease control. The

12 first listing is coppers, fixed. Copper

13 hydroxide, copper oxide, copper oxychloride,

14 includes products exempted from EPA tolerance,

15 provided that copper-based materials must be used

16 in a manner that minimizes accumulation in the

17 soil and shall not be used as herbicides.

18 And then the second listing also under

19 paragraph (i) is copper sulfate. Substance must

20 be used in a manner that minimizes accumulation

21 of copper in the soil. Thank you.

22 DR. THICKE: Thank you. Steve?
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1 MR. ELA: So copper fixed and copper

2 sulfate were reviewed and approved for continued

3 use during the October 2015 NOSB meeting. 

4 Coppers continue to be an important tool for

5 organic producers as part of the comprehensive

6 approach to disease management in many crops.

7 For example, copper products became an

8 integrated part of fire blight control in pome

9 fruits after antibiotics were removed from the

10 National List. And I can vouch for that as a

11 tree fruit grower. 

12 Copper is on the list of exemptions

13 for synthetic materials in OFPA. The biggest

14 concern with coppers is that they can -- that

15 maybe growers are over-using copper sprays and

16 that copper can reach high levels possibly in the

17 soils. There is -- were some comments that

18 copper residues were visible on the harvested

19 portions of crops and that was a concern.

20 So there was in public comment a

21 discussion of whether an annotation could be

22 considered that would read no visible residues
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1 are allowed on harvested crops. The public

2 comments support copper use in general, but

3 several say that we should ask for alternatives,

4 encourage research, map out current use on the

5 varied crops and how it is applied.

6 One -- a couple of comments noted that

7 we should have the farmers document in their

8 organic plan the Worker Protection Standards used

9 when -- were noted when they apply coppers.

10 Certifiers have commented that

11 enforcing the no visible residue on harvested

12 crops could be very difficult, because that would

13 mean the certifier would have to be there at

14 harvest and that functionally could be very

15 difficult. So generally, I would say that while

16 those public comments were concerned about the

17 over-use of copper, that addition to an

18 annotation was pretty loudly rejected by the

19 certifiers as being impractical.

20 DR. THICKE: Okay. Thank you. Any

21 questions or comments? Harriet?

22 MS. BEHAR: Do you know if there is
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1 any research being done to find an alternative to

2 this product?

3 MR. ELA: I mean, I think there is

4 always research being done to find alternatives

5 to anything. I can't speak specifically to

6 copper. I mean, you know, there are a number of

7 bioproducts on the market like for fire blight

8 control that, you know, are aimed at that same

9 functionality.

10 But, you know, at this point, if you

11 look at like Washington State recommendations out

12 of fire blight, copper is the mainstay of that

13 program starting off and then you add the

14 biocontrols on top of that afterwards. 

15 I know, you know, personally I can say

16 for tree fruits, there are no alternatives, at

17 this point, for -- if you look at Cytospora and

18 Coryneum blight and some of these other, you

19 know, fungal bacterial diseases, it's the go-to

20 product.

21 Not to say that something isn't being

22 researched, but, at this point, those are the
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1 functional -- it is the functional thing.

2 And I should note that, you know, EPA

3 has noted that -- you know, it's -- we are really

4 looking at a soils issue, not a human toxicity

5 issue. It's a safe material to use as far as

6 humans go, when we are looking at soil build-up.

7 A number of the certifiers noted that,

8 you know, they are really not seeing that soil

9 build-up from copper use.

10 DR. THICKE: Okay. Any other

11 questions or comments? Okay. Moving on to humic

12 acids. Dr. Brines?

13 DR. BRINES: All right. So we are now

14 moving to paragraph (j) As plant or soil

15 amendments. And the listing is humic acids

16 naturally occurring deposits, water and alkali

17 extracts only. Thank you.

18 DR. THICKE: Steve, I have you down

19 for lead. Is that right?

20 MR. ELA: No.

21 MR. BRADMAN: No, I think I'm the

22 lead.
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1 DR. THICKE: Oh, Asa. I'm sorry.

2 MR. BRADMAN: Yeah.

3 DR. THICKE: Thank you.

4 MR. BRADMAN: At least I'm prepared. 

5 So this is actually my first topic here. So

6 humic acids. I'll go through this and actually

7 there is a lot of interesting comments related to

8 this.

9 But so humic acids are usually

10 manufactured from oxidized lignite. Lignite is

11 kind of a -- I heard it described as brown coal

12 or somewhere between peat moss and bituminous

13 coal. It is used as a component of traditional

14 fertilizers.

15 It doesn't provide additional

16 nutrients to plants, but it affects soil

17 fertility by and proving access to micronutrients

18 and increases cation exchange capacity and

19 therefore relates to mineral availability. And

20 it also improves soil structures and stimulates

21 soil microorganisms and may provide some trace

22 elements.
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1 In reviewing some of the literature on

2 crop production, there are some studies that show

3 increased production in potatoes, grains, things

4 like that when it is used.

5 Commercially available humic acids are

6 derived again from coal-related materials,

7 extracts from non-synthetic humates by hydrolysis

8 using synthetic or non-synthetic alkaline

9 materials are permitted, including the use of

10 potassium hydroxide and ammonium hydroxide.

11 Humic acids are derivatives -- humic

12 acid derivatives are on the National List with

13 the following annotation. And I want to -- we

14 should all note this: Naturally occurring

15 deposits, water and alkali extracts only.

16 It was looked at in 215. There were

17 not any public comments at that time that really

18 raised any serious questions about it. And the

19 comments from that period are -- show a lot of

20 support for this material.

21 In terms of the comments that came out

22 for this time around, there was kind of some
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1 interesting discussion about it. There were 13

2 comments. 3 were opposed to this material, 1

3 emphatically. And then there were again 10 in

4 support.

5 Of the people who were supporting

6 continued use of this material and listing this

7 material, really all related to people who were

8 involved in production, so were farmers or

9 involved in soil maintenance and, you know,

10 productivity.

11 The -- to give you some idea of some

12 of the comments that were not supportive,

13 basically, the idea that humic acids present an

14 environment hazard in extraction. They are using

15 potential fossil fuels as a source and are not

16 compatible with organic productions.

17 They can play a role in transition,

18 but are incompatible with organic practices. And

19 a lot of this referred to the use of coal-related

20 sourcing as the material.

21 Those who are supportive felt like it

22 was an important piece of the toolbox to manage
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1 soil fertility. One former NOSB Member was

2 concerned about a suggestion in this review

3 document that we consider an annotation or other

4 constraint to try to use sources of humic acid to

5 manufacture the product better, have the least

6 harm on the environment.

7 I should also take a step back that

8 you can also manufacture this material from

9 plant-based organic sources, that it may be

10 derivable from, for example, compost or things

11 like that. And this is a material, of course,

12 that is often the "recalcitrant" portion of the

13 soil, so it's naturally occurring in some forms

14 as well.

15 And this former NOSB Member was just

16 concerned about, in general, the overuse of

17 annotations and that this should, you know, not

18 be lost from the toolbox.

19 Again, I mentioned people who are

20 opposed to it and there are some very strong

21 statements that it's not essential for organic

22 production, again, because of this coal source. 
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1 And I guess back in 2012 I'm trying to dig up the

2 history here that the NOSB denied a petition for

3 oxidized lignite saying that humic acids derived

4 from coal by oxidation with hydrogen peroxide

5 should not be listed and that this reasoning also

6 extends to water-based alkali processes to

7 produce it from lignite.

8 So I guess maybe there is some

9 interesting discussion following from that. I

10 thought this was going to be easy, but I'm

11 surprised that there is some polarity on it.

12 DR. THICKE: Thank you for that

13 comprehensive review there. Any comments or

14 questions? Steve?

15 MR. ELA: We're going to point at each

16 other here. You know, my only concern with it

17 and I agree, you know, the sourcing is, I think--

18 and I'm not, you know, in objection to the use by

19 growers. I mean, it seems to be fairly essential

20 to many growers, but I question whether it is one

21 of those things that becomes a crutch, that if

22 you are doing a good soil building program and
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1 having good soil ecology, that it's really a

2 redundant addition that you already have it.

3 And so I guess I would like to see

4 growers here using it. And you know, really the

5 question is do they actually need it in those

6 soils or can they by, you know, some other

7 program actually do something that negates its

8 use, rather than just using it routinely and

9 saying well, we need it? 

10 I mean, you know, as a fruit grower,

11 you know, I can say we don't add compost because

12 we do a lot of cover cropping and we mulch that

13 cover crop in. And so to me, the addition of the

14 biology of the compost is it's already there. 

15 And this, to me, strikes me as one of those

16 possible things.

17 So not to say I'm in favor of removing

18 it, but, you know, I think we should question its

19 over-use.

20 DR. THICKE: Emily?

21 MS. OAKLEY: Yes, I was basically

22 going to say the exact same thing. So, Sue, if
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1 you want to?

2 DR. THICKE: Sue?

3 MS. BAIRD: I think we have to

4 remember there are a lot of growing systems in

5 the United States and we can't be so site6 specific. And I understand what you are saying,

7 Steve, and I agree with it. But again, I go back

8 to my mid-America where we are talking about a

9 lot of errant conditions. 

10 And if they turned up that soil to do

11 cover cropping, they are losing every little bit

12 of moisture they have got. It's really not so

13 easy for them. And they do rely on humic acids. 

14 I have seen a real upsurge of people as you

15 intimated, Asa, that are doing innovative things

16 such as taking miscanthus and doing a

17 biodigestion to get biochar and humic acids from

18 those types of systems.

19 And they would tell you that without

20 that humic acid, they do not have the microbial

21 actions in the soils. So let's just be cognizant

22 that there are a lot of different growing
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1 conditions in the United States.

2 DR. THICKE: Harriet?

3 MS. BEHAR: I see this used mostly by

4 farmers who are either in transition or in the

5 first few years of transition until they really

6 get their functioning organic system on their

7 farm.

8 So I think it is useful to kind of

9 help them over that hump, because three years is

10 -- of transition is really not quite enough to

11 really bring everything back and really --

12 especially if you are challenged by soil type or

13 climate to really build a functioning organic

14 system.

15 DR. THICKE: Anybody else want to

16 comment on this?

17 MR. BRADMAN: I just --

18 DR. THICKE: Asa, yes?

19 MR. BRADMAN: Just maybe more

20 discussion. I'm interesting in hearing about,

21 you know, whether -- if we considered any -- not

22 -- constraints isn't the word I'm looking at,
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1 annotation, you know, whether it should be done

2 by annotation. If we were to put some

3 suggestion, for example, that we want to use a

4 natural source for less environmental harm and

5 note there was a comment yesterday about how do

6 you actually quantify environmental harm of

7 different course of humic acid?

8 But would that be something done by

9 annotation or just guidance? And there was a

10 concern about over-prescripting the approval

11 material.

12 DR. THICKE: Tom?

13 CHAIR CHAPMAN: If that's something we

14 would want to do, I think you could pass -- you

15 know, we would add it to our work agenda and pass

16 something related to it. And then the program

17 can make a determination whether guidance or

18 annotation was the best way to handle it.

19 DR. THICKE: So we could bring it up

20 in our Crops Committee discussions?

21 CHAIR CHAPMAN: Yeah.

22 DR. THICKE: To start off.
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1 CHAIR CHAPMAN: Yeah. And I do know

2 there was -- you know, there is a piece of

3 guidance out there already on the alkali used to

4 extract humic acid and they wanted to restrict it

5 via guidance in the programs that you couldn't do

6 that. You would need rule change.

7 DR. THICKE: Okay. Thank you. Maybe

8 we should move on to the next one. The next one

9 up is micronutrients, soluble boron products. 

10 Lisa?

11 DR. BRINES: Okay. Thank you. So we

12 are continuing on under 205.601(j). We are at

13 subparagraph (6) Micronutrients not to be used as

14 a defoliant, herbicide, or desiccant. Those made

15 from nitrates or chlorides are not allowed. Soil

16 deficiency must be documented by testing. The

17 listing is soluble boron products. Thanks.

18 DR. THICKE: Thank you. Harriet?

19 MS. BEHAR: It's another product that

20 begins with a B.

21 So in -- at the October 29, 2015 NOSB

22 meeting, the vote at -- the Board voted to change
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1 the micronutrient annotation by changing the last

2 sentence "Soil deficiency must be documented by

3 testing" to "Deficiency must be documented." So

4 that would allow producers to document, you know,

5 visual signs of deficiency, tissue testing. 

6 I mean, because it was -- or whatever. 

7 But there is more than one way than just testing

8 to document the deficiency. At this point, that

9 has still not been put in the Federal Register,

10 but just so people know that that was voted on at

11 the 2015 fall meeting of the NOSB.

12 So this product is essential to plant

13 health. It is typically applied in very small

14 quantities. And while producers can choose to

15 rely on the natural presence of micronutrients in

16 their soil, many find deficiencies of some

17 micronutrients including boron.

18 So -- and the lack of this can be very

19 much a limiting factor in water and micronutrient

20 uptake resulting in limited growth and vitality

21 of the crops.

22 We did get public comments. The vast
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1 majority were very supportive. Both producers

2 and certifiers felt that it is very commonly used

3 and they wanted to keep it. Many labeling this

4 product as essential. Some did talk, the

5 Northeast Organic Farming Association of Vermont

6 mentioned that they wanted us to look at the

7 accumulation perhaps of micronutrients, but they

8 don't want to really make growers wait until

9 deficiency is found in a crop before they can be

10 allowed to apply it, because many of these are

11 slow release and take a while to be taken up by

12 the plant, so that might be something the Crop

13 Committee can discuss how we can be more

14 practical in this.

15 Because if we wait until deficiency,

16 then it could be two or three years until they

17 could get that -- especially if it's a perennial

18 up to speed. So anyway, that was one comment.

19 They also -- OFA mentioned that

20 providing documentation of deficiency is a

21 difficult item for growers, so they like that

22 change in annotation when it could possibly be
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1 put in the Federal Register. 

2 There was a comment from the Center

3 for Food Safety about addressing the nano issue

4 on micronutrients, that there is like nano cobalt

5 and I don't remember the other nano, but that's

6 in the other area. But that we should be

7 addressing nanotechnology in these

8 micronutrients.

9 Let's see, relist, relist. CCOF, that

10 was very helpful. There were 905 growers that

11 used micronutrients as a class in their OSP, so

12 that really does show some widespread use in the

13 state that produces the largest amount of organic

14 produce, the United States.

15 And that's -- and then PCO mentioned

16 170.

17 Beyond pesticides mentioned, that soil

18 deficiency must be demonstrated by a verifiable

19 site-specific documentation that is accompanied

20 by a plan for building soil that provides

21 adequate nutrition through soil building, so they

22 were hoping that the micronutrient issue could be
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1 dealt with from a systems approach. That's it.

2 DR. THICKE: Okay. Thank you. Any

3 questions or comments? Yes, Steve?

4 MR. ELA: I would tend to agree with

5 some of the comments of -- I mean in perennial

6 crops the deficiency is then, you know, five

7 steps too late. And so it is a challenge to --

8 on some of these micronutrients like boron and

9 the following subset we are going to discuss that

10 no, you don't want things to fall too low because

11 the response time to build it back up is years.

12 So it does put growers in a bit of a

13 quandary of how to document a declining amount or

14 a low level that is not really a deficiency. So

15 I would be in favor of some kind of allowance to,

16 you know, based on industry standards or PCAs, I

17 think there is some public comments that -- on

18 the recommendation of a PCA or, you know,

19 industry extension, something, you know, credible

20 to be able to apply these.

21 DR. THICKE: And could documentation

22 be part of -- could part of the documentation be
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1 history where you've seen it in the past and that

2 you documented in the past history and so on?

3 MR. ELA: It could be, although you --

4 like with boron, you know, it's used at so low

5 levels. I mean, you are putting on a pound --

6 DR. THICKE: Right.

7 MR. ELA: -- an acre for years. I

8 mean, the Washington State recommendation is a

9 pound an acre a year for years. I mean, the

10 Washington State recommendation is a pound an

11 acre a year.

12 DR. THICKE: Um-hum.

13 MR. ELA: So very low levels, but just

14 as a routine thing, especially in soils that tend

15 to be -- you know, environments that tend to be

16 low boron.

17 DR. THICKE: And boron disappears

18 fast. It can bleach out, yes.

19 MR. ELA: Yeah. And it is a nutrient

20 that over-use can also be very problematic. So I

21 think growers -- there is not much incentive to

22 create a boron excess, because then you have some
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1 real severe food issues.

2 DR. THICKE: Um-hum, okay. Scott?

3 MR. RICE: Yeah, I would just echo

4 that, you know, with the intent of that

5 deficiency must be documented versus testing

6 allows that -- you know, still deals with the

7 site-specific or area/region-specific deficiency,

8 but that was intended to not leave the farmer

9 watching things go downhill before one was able

10 to correct it.

11 DR. THICKE: Any other comments on

12 boron? Harriet?

13 MS. BEHAR: So just to ask the

14 program, any thoughts on when that change to the

15 annotation, is that in any process down the pike? 

16 And is it, you know, at the end of the pipeline,

17 at the middle of the pipeline? You know, not

18 being --

19 DR. LEWIS: Right. We are still

20 working through the process of the review in this

21 case, based on recommendations. So it's really

22 hard to say in terms of, again, what you have
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1 heard during the course of the past few days, the

2 new Administration is coming on board. We need

3 to socialize this with that.

4 MS. BEHAR: It would seem to me to be

5 a fairly simple one. We are just taking out by

6 testing from that and we are really not

7 necessarily really weakening the annotation. We

8 are just actually broadening the way that the

9 requirement can be met.

10 DR. THICKE: Okay. Let's move on to

11 the next one. It's the rest of the

12 micronutrients: Sulfates, carbonates, oxides or

13 silicates of zinc, copper, iron, manganese,

14 molybdenum, selenium and cobalt.

15 DR. BRINES: Thank you. So this

16 listing we are continuing under Section

17 205.601(j)(6) under the micronutrients listing

18 and the listing is sulfates, carbonates, oxides

19 and silicates of zinc, copper, iron, manganese,

20 molybdenum, selenium and cobalt. Thanks.

21 DR. THICKE: That's Harriet also.

22 MS. BEHAR: So pretty much the same as
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1 the boron. But so the two things I see are

2 making sure that, again, we are not requiring

3 that things be totally deficient before we will

4 allow someone to use the product as well as I

5 think the issue of nanotechnology, especially

6 with some of these, might be something we might

7 want to talk about with the program.

8 DR. THICKE: Okay. Any comments on --

9 Tom?

10 CHAIR CHAPMAN: Can you clarify that

11 nanotechnology concern?

12 MS. BEHAR: I believe when they gave

13 public comments, I would have to look back, but I

14 know this was nano cobalt and there was an NOSB

15 recommendation to not allow nanotechnology in

16 organic production, but it never really -- they

17 are actually suggesting that it be added to the

18 excluded method section of the rule so it's very

19 clear.

20 But just to make it clear that --

21 well, I suppose we have to talk about whether we

22 want to prohibit nano micronutrients or not. But
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1 they felt that over time more and more of these

2 micronutrients will be available in a nano form. 

3 And are we then, because we don't specifically

4 prohibit them, allowing those?

5 CHAIR CHAPMAN: So is my

6 understanding, there is guidance out from the

7 program or policy out from the program that

8 states that nanotechnology is a synthetic method

9 and would need to be specifically listed.

10 Can someone from the program comment

11 on that?

12 DR. LEWIS: I'm going to try Dr.

13 Brines, in this case, since you worked on this

14 issue previously. Thank you.

15 DR. BRINES: Yes. Thank you. Yes, we

16 did publish Policy Memo 15-2 on nanotechnology,

17 which implemented the NOSB recommendation. So

18 yes, farm materials on the National List, none of

19 which are currently on the list, would be allowed

20 in nanotechnology derived form. Any new product

21 derived from nanotechnology would need to be

22 petitioned for use in organic production and
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1 handling would have to go through that petition

2 process.

3 The Policy Memo doesn't prohibit the

4 use or I'm sorry doesn't prohibit the petition of

5 those types of technologies and that is

6 consistent with the NOSB recommendation on

7 nanotechnology. Thank you.

8 CHAIR CHAPMAN: So to clarify, nano

9 cobalt not allowed under this listing today?

10 DR. BRINES: Correct, yes, um-hum.

11 MS. BEHAR: Thank you.

12 DR. LEWIS: A question for Harriet. 

13 So I'm assuming that the Excluded Methods Group

14 will be looking at this issue and nanotechnology

15 is part of your ongoing activity?

16 MS. BEHAR: It wasn't on our list, but

17 I suppose we could add it.

18 DR. LEWIS: Okay. 

19 MS. BEHAR: But --

20 DR. THICKE: For crops or for

21 materials?

22 MS. BEHAR: No, in the Excluded
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1 Methods in the Materials Subcommittee. But it's

2 not -- it doesn't really fit under genetic

3 engineering. Well, maybe it does. I don't know.

4 DR. THICKE: Okay. 

5 MS. BEHAR: I don't think so, because

6 it's kind of a migrated -- it's a micro -- you

7 know, they take the small particles and grind it

8 up into little, little, little, little pieces. 

9 That's my science.

10 DR. THICKE: Okay. Any other comments

11 on the micronutrients?

12 MR. BRADMAN: Yeah, definitely not

13 genetic.

14 MS. BEHAR: Yes.

15 DR. THICKE: Not genetic, yes. Thank

16 you, Asa. I have to identify everybody because

17 for the transcriptor/transcriber. So, Harriet?

18 MS. BEHAR: The commenter asked us to

19 add it to the section of the rule that would

20 specifically -- rather than in guidance and

21 allow, I suppose, four things to be petitioned,

22 they were asking us to put nanotechnology under
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1 205 -- 105 as a separate item. Excluded methods

2 are radiation, sewage, sludge, nanotechnology.

3 DR. THICKE: All right. Okay. Let's

4 move on to vitamins. Vitamins B1, C and E. Dr.

5 Brines?

6 DR. BRINES: Yes, thank you. We are

7 still continuing on under Section 205.601(j) as

8 plant or soil amendments and the listing is

9 Vitamins B1, C and E. Thank you.

10 DR. THICKE: Thank you. Emily?

11 MS. OAKLEY: Vitamins including

12 synthetically derived vitamins are generally

13 considered non-toxic essential nutrients for

14 terrestrial and aquatic organisms. Non-synthetic

15 sources of all vitamins and synthetic sources of

16 Vitamins B1, C and E may be used in certified

17 organic operations.

18 The 2015 Technical Report noted that

19 the available literature does not support the

20 premise that foliar and soil applications of

21 Vitamin B1 are responsible for root stimulation

22 in transplanted crops.
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1 And commenters both this time and in

2 its most recent review indicated that Vitamins

3 B1, C and E are rarely used individually, but are

4 included as ingredients in some of the products

5 reviewed for crop fertility.

6 The TR indicated that the root growth

7 claims associated with B1 are largely

8 unsubstantiated. And we asked a specific

9 question related to that in this current review. 

10 We didn't get a tremendous amount of feedback

11 regarding that and we got some public comment on

12 these vitamins, but not a great deal.

13 The majority of the comments was as

14 before that they are typically used as a blended

15 or in blended fertilizers. Only a couple of

16 people commented on the specific Vitamin B1

17 saying that it might be used in -- for root

18 stock, but, as the TR indicated, it is not

19 typically effective for that.

20 There was one commenter that noted

21 that the TR indicated that these vitamins can be

22 produced using genetic engineering, but that
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1 would not be allowed in organic production. So

2 if we were to try to remove B1 because it's not

3 typically used, it would mean trying to change

4 this listing, which might be a lot of work. So

5 we could discuss that in Subcommittee if it's

6 sort of worth our effort to change the National

7 Listing to remove B1.

8 But it definitely isn't widely used

9 and it's not effective for the use that it is

10 listed for. So it's kind of one of those things

11 where we kind of need to weigh out what is the

12 most effective use of our time, but we can

13 discuss it on the crops call.

14 Are there any questions about it? 

15 Okay. 

16 DR. THICKE: Okay. Thank you, Emily. 

17 Next up is lead salts. Dr. Brines?

18 DR. BRINES: Thank you. So we are

19 moving to a new section of the National List now,

20 that section is 205.602, the Non-Synthetic

21 Substances prohibited for use in organic crop

22 production. And this listing is lead salts. 
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1 Thanks.

2 DR. THICKE: Thank you. And this is

3 my material here.

4 Basically, we know lead is not good

5 for human health and it accumulates in soils. 

6 And so there really was no support for taking it

7 off the prohibited list. There were a number of

8 comments that mentioned yes, let's leave it on

9 the list.

10 Basically, that's it. Anybody have

11 any comments on that? Okay. Thank you. So we

12 will move on then to tobacco dust.

13 DR. BRINES: All right. So this is

14 the last substance on the crops part of the

15 agenda for Sunset 2019. So continuing under

16 205.602, this listing is tobacco dust, nicotine

17 sulfate. Thanks.

18 DR. THICKE: Harriet?

19 MS. BEHAR: Okay. So this -- to

20 tobacco dust or nicotine sulfate has been on the

21 National List since its first printing in 1995 as

22 a prohibited non-synthetic. 
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1 It can be used as a pesticide or as a

2 fertility input, but due to the negative human

3 health caused by this material, it has been

4 relisted as a prohibited at every Sunset with no

5 objections from the public or the NOSB.

6 It is present on the Hazardous

7 Substance List and regulated by OSHA and EPA as

8 well as other agencies. So it is listed.

9 There is some concern that it is being

10 -- could be used as an ag product that can be

11 incorporated into the soil as a tea -- no, I'm

12 sorry. Dust, tea and smoke are prohibited

13 according to OMRI and MOSA. But -- and it's no

14 longer available commercially. It used to be

15 more available, but people could still make it

16 themselves and use it.

17 But there -- I think there was one

18 comment about trying to be a little bit more

19 clear that it's not allowed in any use. And also

20 I personally know that because it's not listed on

21 the livestock section, there has been discussion

22 about it being used for some topical pest control
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1 on livestock. So that is not really a crops

2 issue, but I always found that interesting, since

3 our list is broken up into sections, that because

4 it's not prohibited under livestock, it could be

5 used there. That's it.

6 DR. THICKE: Thank you, Harriet. Any

7 comments or questions for Harriet? Okay. Well,

8 that concludes the Sunsets. And now the next

9 item up is the discussion document on

10 strengthening the organic proposal. 

11 Strengthening the Organic Seed Guidance. And,

12 Harriet, you are the lead on that.

13 MS. BEHAR: Yeah, I don't know why I

14 took on all this work. Okay. 

15 So it was a fairly long document. It

16 was very wide-ranging, because we were really

17 trying to cover a lot of comments and kind and

18 kind of fill-in places where we felt that the NOP

19 Policy Manual Memorandum could be improved on

20 this issue of seeking out organic seeds in

21 commercial availability.

22 And there really are a lot of issues
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1 there. So I hope everyone read it and I know

2 there were some comments.

3 There was -- one of them, the comment

4 that I saw most often was that we are trying to

5 get producers to total compliance and many

6 certifiers, especially as well as people in the

7 trade, mentioned how difficult that is,

8 especially for vegetable producers, at this time,

9 because we want people to use regionally adapted

10 seeds.

11 There are market constraints that

12 people might want a certain heirloom or a certain

13 hybrid or whatever and this is what either their

14 processor is requiring of them or their market,

15 their retail, their restaurant or whatever. And

16 to push producers to total compliance when it's

17 an impossibility is really impractical and

18 unfair.

19 Let's see, oh, also there was this

20 concern again, which we are going to deal with in

21 another discussion document, on the GMO side,

22 making sure that the non-organic seeds that are
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1 being used also are free of genetic modification. 

2 That's another challenge.

3 And they felt, some of the commenters

4 felt that that's somewhat of a difficult issue to

5 deal with, because it tends to be that organic

6 seed producers will do that GMO testing. But to

7 get, you know, that type of assurance from non8 organic seeds, especially things like vegetables

9 or whatever, it's a little bit more difficult.

10 DR. THICKE: Okay. Any discussion? 

11 Do you recommend that, Harriet? Do you recommend

12 sending it back based upon the comments?

13 MS. BEHAR: Yes. The Crops

14 Subcommittee to discuss that, especially since it

15 is such an in depth and wide-ranging document

16 that we felt that we would like to get more

17 comments. And so I think there was somebody who

18 was supposed to make a motion. I don't know if

19 it is me.

20 DR. THICKE: Go ahead.

21 MS. BEHAR: Oh, I will make a motion

22 to send it back to Subcommittee.
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1 DR. THICKE: Second. Anybody?

2 CHAIR CHAPMAN: I have a motion and a

3 second.

4 DR. THICKE: I would second the --

5 CHAIR CHAPMAN: Francis seconded it. 

6 All right. Hold on. I'm going to get my list. 

7 All right. So the motion is to refer the

8 proposal on Strengthening the Organic Seed back

9 to the Crops Subcommittee. Is there any further

10 discussion on this measure?

11 Hearing none, we will move to a vote. 

12 The voting will start with Dan and a yes vote is

13 to send this back to Subcommittee.

14 DR. SEITZ: Yes.

15 MR. RICE: Yes.

16 MS. BAIRD: Yes.

17 MS. BEHAR: Yes.

18 MS. OAKLEY: Yes.

19 DR. THICKE: Yes.

20 MS. ROMERO-BRIONES: Yes.

21 MS. De LIMA: Yes.

22 MR. BRADMAN: Yes.
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1 MS. MOSSO: Yes.

2 MR. ELA: Yes.

3 MR. MORTENSEN: Yes.

4 MR. BUIE: Yes.

5 MS. SWAFFAR: Yes.

6 CHAIR CHAPMAN: The Chair votes yes. 

7 The motion passes 15 yes, 0 no. The proposal is

8 referred back to the Crop Subcommittee.

9 DR. THICKE: Thank you. Moving on,

10 next up is the --

11 MR. MORTENSEN: I just had a quick

12 question --

13 DR. THICKE: Oh, yes, Dave?

14 MR. MORTENSEN: -- about the general

15 subject of this --

16 DR. THICKE: Yes.

17 MR. MORTENSEN: -- proposal. And it

18 doesn't bear at all on the vote. But and maybe

19 this is to Harriet. There is -- during the

20 course of this meeting, several folks have, both

21 in public comment and then in just discussions in

22 the hall, have raised a concern about challenges
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1 that organic and non-GM seed breeders are facing

2 with contamination from nearby fields.

3 That is largely driven by the

4 prevailing agriculture, maize breeding and a

5 maize landscape, etcetera, alfalfa breeding in a

6 landscape where bees are flying several miles

7 around. 

8 And I'm just wondering how do we

9 address that? You know, in the section that

10 reads "Crops at risk GMO contamination might need

11 to be acknowledged," blah, blah, blah. It seems

12 that acknowledging that contamination might be

13 happening is not a very satisfying endpoint. 

14 So what -- how do we get into that in

15 a more rigorous way?

16 MS. BEHAR: We are actually working on

17 another discussion document with Dan and I that

18 will look at what are our options. Is it

19 testing? Is it a risk-based decision-type tree? 

20 It's a very complicated issue because, to me, it

21 comes down to who in the end is going to be

22 punished? 
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1 DR. THICKE: Um-hum.

2 MS. BEHAR: Somebody is going to get

3 punished. And is it going to be the seed breeder

4 who has to throw away three-quarters of the seed

5 that they have produced? Is it going to be the

6 farmer who has got, the organic farmer, a higher

7 price because that type of production loss will

8 have to be covered at some point in the market.

9 You know, there is just a lot of

10 issues. Is it going to be the consumer who is

11 going to have less availability of organic crops? 

12 And we are not sure other places of the threshold

13 of an allowance of some genetic modification

14 contamination is considered somewhat of a

15 solution. We are not sure if that's the solution

16 or not, but we will be looking at that in a

17 separate document.

18 DR. THICKE: Um-hum. Also, about a

19 year ago or maybe a little longer, we put

20 together a guidance document listing all the

21 things that organic producers and handlers can do

22 to protect ourselves and then acknowledging that
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1 we can only do so much. But being public about

2 what we are doing and suggesting that our

3 neighbors need to do more. Okay.

4 CHAIR CHAPMAN: All right. I just

5 have --

6 DR. THICKE: Tom?

7 CHAIR CHAPMAN: -- just to clarify,

8 Harriet, so that is a work agenda item for the

9 Material Subcommittee?

10 DR. THICKE: Yes, yes.

11 MS. BEHAR: So there has also been a

12 lot of discussion about the patent holders also

13 being liable or putting some sort of, I don't

14 know if you would say, blame or responsibility on

15 that because the technology -- I mean, it's not

16 so much the farmers that are the neighbors that

17 have the fall, but that they have purchased a

18 technology that is -- has not dealt with the

19 promiscuity of what they are selling.

20 That it does go out in the air and

21 well, you know, so I think there is not a lot of

22 will among the organic farmer community to feel
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1 like they have to go after their neighbors.

2 DR. THICKE: Right. 

3 MS. BEHAR: For an effective product

4 that their neighbors have bought, basically.

5 DR. THICKE: My neighbor, yes. Right,

6 exactly. Of course, we don't have much leverage

7 over those people. Any other comments? Probably

8 we should move on here to the next proposal is

9 the Marine Algae Listings. Emily?

10 MS. OAKLEY: So as Scott noted

11 yesterday, this is the identical proposal that

12 was brought forth in handling. Thank you to Dr.

13 Richardson for all of her hard work on this

14 issue. The only difference in the CS proposal

15 was the motion.

16 And there was some concern from the

17 public that there wasn't sufficient explanation

18 as to why the brown class was identified and so I

19 just want to note, as I noted with the handling,

20 that there has been an ongoing discussion with

21 this and perhaps we could have elaborated a

22 little bit more about why we were identifying the
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1 brown class. But as is noted in the background

2 of this document, the TR gave the indication that

3 the majority of the products used under this

4 listing do come from the brown class of seaweed.

5 Although as everyone knows from our

6 conversation during public comment, OMRI has

7 identified a handful of products that also

8 include seaweed from the red class.

9 Our intent with this was to identify

10 what is being used, to just clarify that for the

11 public comment and question on that. And now

12 that we know that there are some products with

13 some red algae in it, I think we will be working

14 with OMRI to identify what those might be and to

15 see if we might be able to come back with a

16 document that has a little bit more background in

17 support for why we are naming what we are naming.

18 But we also don't want to be so broad

19 as to include things that aren't being used and

20 aren't necessary. And as Scott discussed, there

21 is definitely a sustainability component of this

22 document, so we want to try and work on that. 
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1 Although, it is extremely challenging to

2 identify, you know, how we can measure

3 sustainability and how we can then evaluate it.

4 The problem with this listing is that

5 it is a crop input. So the irony is that some of

6 these materials might be harvested under the Wild

7 Craft Standard and be subject to environmental

8 standards when they are used for human

9 consumption. But that exact same product might

10 be harvested for a crop input and not be subject

11 to an environmental standard.

12 So we have a conundrum within the

13 situation and I don't want to let this issue drop

14 and will continue to work on it and try to see if

15 we can find some ways to address the

16 sustainability piece.

17 In terms of public comment for this,

18 there -- it was very mixed. There were marine

19 scientists. Oh, did you want to interrupt? I'm

20 sorry. When you are done. Okay. 

21 There were marine scientists who

22 expressed like very obvious widespread support
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1 for this proposal as it is written now. And also

2 the second motion on the handling proposal that

3 we will, I'm sure, be exploring in future

4 meetings.

5 There were those who didn't feel they

6 had time to adequately look into this and so

7 asked us to take it back to the Subcommittee to

8 give them a little more time to explore this

9 issue. And then there were those who felt we

10 needed to address the fact that red algae is also

11 being used in some instances.

12 So I think -- yes, Tom, do you want to

13 go ahead and ask? You can go ahead and ask me

14 your question before I continue.

15 CHAIR CHAPMAN: Yes, I just wanted to

16 point out. So on the wild craft statement that

17 you made, so an organic product is certified

18 under wild craft would have those protections.

19 MS. OAKLEY: Correct.

20 CHAIR CHAPMAN: All the items that

21 were part of the handling proposal that are

22 already listed on 605 or 606, would have the same
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1 issues that this --

2 MS. OAKLEY: Yes.

3 CHAIR CHAPMAN: -- extract does. I

4 just wanted to make sure people are clear that

5 that wild craft protection or requirements does

6 not translate over to the 605, 606 items.

7 MS. OAKLEY: Right. Only if they are

8 certifying them organic, yes. But it is this

9 strange little like --

10 CHAIR CHAPMAN: Definitely.

11 MS. OAKLEY: -- not loophole, but

12 situation that we have.

13 CHAIR CHAPMAN: Yes.

14 MS. OAKLEY: And there are definitely

15 marine scientists who are very concerned. And

16 there are landowners along the coast of Maine who

17 have been dealing with rockweed issues and there

18 is some current legislative rulings that have

19 actually indicated that harvesting rockweed in

20 the Intertidal Zone is not permitted, that that

21 does belong to the landowner.

22 But that is a very recent ruling that
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1 was made available to us also in the public

2 comment.

3 Are there any other questions that

4 people have about this proposal or these

5 materials? Harriet?

6 MS. BEHAR: I would make a motion to

7 send it back to Subcommittee.

8 MS. OAKLEY: I'll second that.

9 CHAIR CHAPMAN: I have a motion and a

10 second. Any further discussion on this item? 

11 Yes, it was a motion by Harriet, seconded by

12 Emily. The motion is to refer the crops proposal

13 on marine algae back to the Crops Subcommittee. 

14 This is a majority vote. Voting will start with

15 Scott and a yes vote sends this back to

16 Subcommittee.

17 MR. RICE: Yes.

18 MS. BAIRD: Yes.

19 MS. BEHAR: Yes.

20 MS. OAKLEY: Yes.

21 DR. THICKE: Yes.

22 MS. ROMERO-BRIONES: Yes.
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1 MS. De LIMA: Yes.

2 MR. BRADMAN: Yes.

3 MS. MOSSO: Yes.

4 MR. ELA: Yes.

5 MR. MORTENSEN: Yes.

6 MR. BUIE: Yes.

7 MS. SWAFFAR: Yes.

8 DR. SEITZ: Yes.

9 CHAIR CHAPMAN: The Chair votes yes. 

10 15 yes, 0 no. The motion passes and this

11 proposal is referred back to the Crops

12 Subcommittee. I think it's a good time to break.

13 MS. OAKLEY: Before we break, can I

14 just --

15 CHAIR CHAPMAN: Yes.

16 MS. OAKLEY: -- I just want to say

17 that for those who are concerned about this

18 issue, sending it back is not going to table it. 

19 We will continue to work on it.

20 CHAIR CHAPMAN: Thank you. Francis,

21 do you agree good time to break?

22 DR. THICKE: Good.
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1 CHAIR CHAPMAN: Yep, okay. So we are

2 going to take a recess now until -- a 15 minute

3 break until 10:00. And we will get started back

4 then with continuing on the Crops Subcommittee

5 agenda. We are in recess.

6 (Whereupon, the above-entitled matter

7 went off the record at 9:44 a.m. and resumed at

8 10:07 a.m.)

9 CHAIR CHAPMAN: Okay. We will come

10 back into order and back to you, Francis.

11 DR. THICKE: Thank you, Tom. So the

12 last item on our Crops agenda is the discussion

13 document on Aeroponics/Hydroponics/Aquaponics. 

14 And there were four leads on that document and so

15 each of the leads are going to take a little

16 chance to summarize what we have heard and where

17 we think we want to go.

18 And then we want to try to get input

19 from everybody on the whole Board to get your

20 feedback and to see where you think we should go

21 in the future.

22 So Harriet is going to lead off with
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1 just a summary of the document.

2 MS. BEHAR: Okay. So at the last

3 meeting, we also had a discussion -- actually,

4 two discussion documents and we also had a

5 resolution at the end of the meeting stating that

6 the Board was looking at the hydroponic,

7 aeroponic and aquaponic issue with the Board

8 leaning towards figuring out a way to make more

9 clear where the line is between soilless and

10 soiled production. And then what we would do.

11 So this discussion -- I mean, also the

12 program clarified for us that the previous

13 discussion document even if we would have voted

14 for it, which would have been a ban on

15 hydroponics, aeroponics and aquaponics, would not

16 have given them the tools that they needed to

17 actually do any kind of regulatory action.

18 So this document was a response to

19 that. It includes both the containers and the

20 ponics in it, because we felt that the items were

21 related. I know it's -- there is reasons to

22 break them up and there is reasons to keep them
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1 together. And we decided to come out in one

2 document to ask questions.

3 And so the -- you can see we did refer

4 back to public comments and some of the history

5 in this document, but also there are proposals

6 for definitions for each of the ponics,

7 aeroponic, hydroponic and aquaponic, as well as

8 proposed regulatory prohibitions on those things. 

9 So there would be a definition put into the

10 definition section and then a prohibition put

11 into a 5.105 for each of those items.

12 Now again, this is a discussion

13 document, but it's pretty close to what a

14 proposal would look like that we could vote on. 

15 And it was meant to be three different -- well,

16 it would be six different votes whenever we do

17 vote and things will probably be modified some

18 based on public comment.

19 So we would vote on each definition. 

20 We would vote on each prohibition, if that's what

21 ended up happening. We would vote one way or

22 another. Then the -- so everyone has read that,
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1 I am sure.

2 Then we do go into possibilities,

3 questions about the container growing, because

4 the Committee really felt like we needed to know

5 more about what was being done and what is

6 feasible, because we don't want to set up a type

7 of production, a requirement for type of

8 production that is not practical or not doable.

9 So we are looking at still separating

10 out the various ponics and eventually voting on

11 them separately with clear definitions and a

12 place to put that prohibition or not in the rule

13 and we are also looking at having a production

14 standard that will be for container production. 

15 So it wouldn't be nebulous about what is allowed

16 and what is not allowed.

17 We are trying to give both the growers

18 and the certifiers something very clear that they

19 can follow and is doable and will set a line

20 between this is okay and this is not okay. So an

21 actual production standard. And that is really

22 one of the main issues that we have with the
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1 hydroponics being put -- allowed by the program

2 is that it was being -- it was allowed without an

3 actual standard.

4 And so we have lots of different types

5 of hydroponic operations, all of them really seen

6 as equal whereas those of us on the NOSB don't

7 see them all as equal as we can see by separating

8 out the containers and container production.

9 So we are hoping that we will be able

10 to do that and I'm not sure, it may be that it is

11 a proposal on some items and a further discussion

12 document on others. We will see how far we get,

13 but our Committee is very committed to have --

14 getting this done.

15 We are also planning on making sure

16 that all Members of the NOSB are kept informed,

17 even those not on the Crop Subcommittee, as we go

18 through various drafts. And of course, everyone

19 is always welcome to listen in and give some

20 input on our calls as we go through it.

21 So we don't want there to be any

22 surprises of anyone. And of course, once we have
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1 something finished, it will be up for the public

2 to make comment as well.

3 So with that, I think I'm passing it

4 on to Francis.

5 DR. THICKE: Thank you, Harriet. I'm

6 just going to spend a few minutes summarizing

7 some of the comments. We heard comments for days

8 here and also we don't want to go too much in

9 detail.

10 I wanted to look at the perspective

11 that we are really divided and emphasize that you

12 have all seen that wide range of opinion here

13 amongst the organic community.

14 For example, with OFPA and the organic

15 rule, some will claim that it prohibits

16 hydroponics. Some will say that the language

17 allows hydroponics. Some of the comments we

18 heard said that we should allow everything that

19 is hydroponic as long as it's not sterile. We

20 should allow 100 percent liquid feed.

21 Some are arguing that we should only

22 allow plants to be growing in the soil, in
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1 contact with the subsoil. Tremendous difference

2 in opinion here. So that's what we have to

3 navigate here and try to find some common ground

4 at some point.

5 And as was pointed out several times

6 that I think we need to keep this in mind, too,

7 that the European Union requires plants to be

8 grown in the ground. No container growing,

9 except in three countries which was reported that

10 only 30 hectares in the whole European Union is

11 allowed -- allows container growing. And there

12 are 5,000 hectares otherwise that do not allow

13 that.

14 And farmers are both sides, as I said. 

15 Some farmers say we need to feed the soil and let

16 the soil feed the plant. Some will argue it

17 doesn't matter if you feed it through water, the

18 soil has water on it and the water is an

19 interface between the plant and the soil anyhow. 

20 So we have every argument you can have.

21 And the certifiers are also -- and the

22 organic organizations are also split. Some
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1 certifiers are certifying and some will not

2 certify and are against it.

3 CCOF apparently certifies now. They

4 reported the 130 hydroponic and container growing

5 operations. And they recommended that the label

6 be allowed -- to add the label hydroponically7 grown along with organic. So that's one thing

8 that people have suggested.

9 Others support container growing. We

10 heard yesterday MOSA supports some container

11 growing. Some certifiers are adamantly against

12 it. The Montana Organic Association is against

13 it. NOFA-NY also in their comments they oppose--

14 also they oppose an organic hydroponic label.

15 In some of the farmer comments, on

16 both sides, they see economic damage possible. 

17 Those who are now growing hydroponically see that

18 if it's disallowed that they will either have to

19 change, it might cost them a lot or they may have

20 to quit selling organic.

21 And on the other hand, soil-based

22 farmers say that their market is being damaged by
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1 hydroponic growing, which is not equivalent to

2 their growing. And so we have a huge divergence

3 here.

4 We didn't get a lot of suggestions on

5 what we should -- how we should structure our

6 future proposals. We didn't get as much

7 information as I would like to have seen on

8 container growing and what it constitutes and so

9 on. So we will have to keep working on that.

10 We got an interesting comment from the

11 Netherlands, from Marian Blom, I guess, who heads

12 up the Netherlands organic organization and she

13 is one of the leaders in Europe actually and they

14 are very strong on soil growing. But they say

15 they are proposing new European, EU, legislation

16 that would require 50 percent of a plants

17 fertility needs to be added in the soil before

18 the crop is planted.

19 So 50 percent has to be in the soil

20 before the crop is planted. And then only 25

21 percent of the total plant's needs can be added

22 as a liquid feed. So that's what they are
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1 pushing. And they are concerned -- they are

2 watching us very closely, because they see that

3 they have -- they are holding the ground strong

4 on this idea of growing in the ground only.

5 And if we come completely different

6 from them, not only is it a trade issue, but it's

7 -- they are getting a lot of pressure from

8 hydroponic growers to change. And if we are

9 completely different from them, they are going to

10 get a lot more pressure. So they are looking

11 closely at what we are doing.

12 They said currently that in the

13 Netherlands 65 percent of the nitrogen added in

14 the year must come from complex organic materials

15 like compost and manure.

16 And then we come to the word

17 recalcitrant. And I take full responsibility for

18 that. Soil scientists use that term regularly

19 and I didn't think it would be that -- there

20 would be that much recalcitrance to it, but the

21 reason that we use that term is that the 2010

22 recommendations had a definition of hydroponics
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1 that it said it was grown in an inert matrix,

2 bathed in nutrient rich solution.

3 And so as we heard yesterday from a

4 certifier, that person claimed that that was

5 really what kind of was the impetus for,

6 hydroponic or container growing taking off

7 hydroponics, because inert was rockwool

8 assumption. Some inert material chemically not

9 reactive. And people now are using coconut coir

10 and other organic materials which are not

11 technically inert.

12 And so they don't feel they fall under

13 that definition of hydroponics, because they are

14 not using an inert material. So that's why we

15 use that word recalcitrant, inert or recalcitrant 

16 to include those materials that are used as a

17 rooting medium, but do not contribute substantial

18 nutrition to the system.

19 Now, whether or not we want to go

20 ahead with that in the future, I don't know, but

21 that was the reason for it. And we actually got

22 a comment -- we got some comments from farmers
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1 saying that they thought that needed to be in

2 there, but also from the Netherlands because the

3 same person, they said that the European Union

4 also defines hydroponics as an inert medium.

5 And they have the same thing going on

6 is that people are going from an inert medium,

7 fully inert to this resistant biological material

8 and calling that as not being outlawed.

9 So that's -- I kind of wanted to end

10 there. And Jesse was going to be next, tag-team

11 to Jesse here.

12 MR. BUIE: As we move forward in this,

13 I think the most important thing that we need to

14 look at is that we uphold the integrity of the

15 organic seal. And we do that by complying with

16 the regulations that we already got out there.

17 I think people -- many people are

18 operating under wrong assumptions. And that is

19 that all of these aeroponic and hydroponic

20 operations, all of them want to be certified

21 organic. Then the other assumption is that if

22 they are not organic, that they may
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1 disenfranchise inner city, minorities, veterans,

2 and I'm a minority and a veteran, and those kind

3 of arguments are just not true.

4 So what we need to do -- what I

5 realized is that people who go into farming, they

6 go into farming because they love farming. They

7 love producing a product that is nutritious, safe

8 and a product that they can, you know, get a good

9 price for.

10 So having said all of that, I think as

11 a Board, it's our mission to determine, document,

12 whatever we want to call it, that these entities

13 meet organic standards and not their own

14 standards. You know, for the last couple of

15 days, I have heard many claims about microbial

16 activity and nutrients. None of which I think

17 have been documented.

18 In the system that we deal in right

19 now, all of those activities should be verified,

20 quantified and documented. And so the kind of

21 thing that I'm talking about, for these plants

22 that are -- whatever root system they are in, we
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1 need to be able to quantify, verify total

2 phosphate, pot ash, nitrate, nitrogen, humic -- 

3 humeric, pH, you know, all of these things.

4 And I can show you right now from

5 operations that I held that as a Board we need to

6 set the standard. Well, we don't have to set the

7 standards, they are already there. We just need

8 to determine if these entities comply with the

9 standards that are already there.

10 And like I said, we need to be able to

11 quantify microbial activity in these systems

12 where we know that microbes they reproduce, they

13 take in nutrients, they give off carbon dioxide

14 as a byproduct. Therefore, they got the carbon

15 nitrogen ratio. Do these systems have a ratio

16 that is 8:1 to 15:1, which is what is required?

17 So basically what I'm saying is if

18 systems are going to be certified organic, they

19 all need to meet the same -- you know, we need to

20 determine if they meet the same standard.

21 As a Board, how do we get there is the

22 big question. And I would hope that we can talk
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1 among ourselves to come up with a consensus that

2 we all can believe in, a consensus in which the

3 entities that we are dealing with, we can prove

4 to them that either they are compliant or not

5 compliant with organic standards.

6 I have some suggestions how that may

7 be done. Maybe setup some beta sites to

8 determine that. But in the final analysis that

9 we have a plan that in the end, if we determine

10 that these entities are not compliant, then we

11 can vote -- we just vote it down or if they are

12 compliant, we vote it forward.

13 And I think that's -- you know, that

14 is the way -- that is the approach we ought to

15 take going forward.

16 DR. THICKE: Go ahead, Emily.

17 MS. OAKLEY: So the last thing that I

18 wanted to say is that we, as the 15 Members of

19 the NOSB all represent various different

20 stakeholders and we all come to this conversation

21 with different viewpoints and we are not all

22 going to believe the same thing or think the same
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1 thing and that is totally fine, that is

2 understood.

3 And I think that we all represent

4 various ends of the spectrum from soil to

5 hydroponics and I think that in our conversations

6 I'm hoping we can maintain a friendly atmosphere. 

7 We all work together and are going to be working

8 together for the next many years. And I don't

9 want this to be something that causes stress and

10 anxiety and personal feelings for people, because

11 it's not a personal interaction between us. It's

12 something that is a broader conversation.

13 And I also just want the stakeholder

14 community to be aware of that, too. And we are

15 all working together on issues beyond this. So

16 maintaining an atmosphere that is collegial and

17 that we understand that we can probably come to

18 some degree of consensus and I think that the

19 most important thing to realize is that there are

20 not 15 people on this Board that are going to

21 vote for only in the soil production.

22 There are not 15 people on this Board
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1 that are going to vote for aeroponics. And given

2 that reality, we have to be pragmatic about how

3 we can come to some kind of middle ground, which

4 is going to mean everybody giving a little bit of

5 something.

6 And I think if we can do that, that

7 the 15 of us can ideally find some form of a

8 document that we can all support and agree on. 

9 And I also think that that will increase the

10 likelihood that this will make it through the

11 rulemaking process and also not drag this

12 discussion out to the point that we never come up

13 with any kind of solution, because we are all

14 staking our claims and not kind of finding some

15 place where we can agree.

16 I know that is not going to be easy,

17 but I think that that's our goal. And as Harriet

18 said, everybody is on the hydroponics document,

19 at this point, so all of our future iterations of

20 this proposal will be sent to everyone, so that

21 everyone can have feedback. We don't, you know,

22 get other Members who are not on the CS not
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1 contributing throughout the process of what we

2 come up with.

3 So yeah, I think we are going to have

4 a good conversation and I appreciate hearing

5 everyone's perspectives.

6 So the four of us who worked on the

7 draft discussion document that is in front of you

8 now, I wanted to open it up to others to comment

9 first before we might, you know, put forward our

10 points of view.

11 We could do it in a roundtable fashion

12 or we could just let it be a free flow of whoever

13 wants to speak kind of starting that dialogue. 

14 So whatever people are most comfortable with. 

15 The most important thing is we want people to

16 feel comfortable in their conversations and not,

17 you know, feel that they can't be honest about

18 their perspectives.

19 DR. THICKE: Why don't we just see if

20 people want to speak and we will take your names

21 and we will go in order as you raise your hands.

22 MS. OAKLEY: I know it's hard to be
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1 the first person.

2 DR. THICKE: Okay. Dan?

3 DR. SEITZ: So I would like to say a

4 few things. First, as Francis mentioned, there

5 was a lot of talk about the economic impact. And

6 I think, first of all, the -- our regs don't

7 really address economic impact as a factor, but I

8 think it's important to remember that anyone will

9 be impacted by this decision, whichever way it

10 goes.

11 If we allow for a hydroponic in

12 container, I think it's inevitable that soil13 based farmers will be impacted and vice versa. 

14 There was a lot of talk about the

15 adverse impact potentially on consumers if they

16 don't have access to certain products year-round

17 or whatever. But there is also in -- let me --

18 there is also an impact on consumers if more

19 agriculture is transitioned to hydroponic, which

20 may mean that fewer conventional farms are

21 transitioned to organic farms.

22 So I feel that we can't make a
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1 decision based on the economic impact. We really

2 do have to go to, I think, the core and as Emily

3 was saying, we won't -- none of us probably fully

4 agree on that. But what the core of the law says

5 and the regulations and what is really going to

6 benefit this movement in the long run.

7 I just want to say as a consumer

8 Member on the Board, that consumers are

9 schizophrenic. They want cheap food. They want

10 sustainable food. They want healthy food. So I

11 don't think it's possible to generalize.

12 I think there is a big philosophic

13 question here which is the -- you might say two

14 competing paradigms, philosophic paradigms. One,

15 I call the mechanistic paradigm that the human

16 intellect has the capacity to improve nature in

17 definitely through scientific means that we can

18 replicate natural systems through various

19 mechanistic, mechanical or scientific means.

20 And I would call the other viewpoint

21 the align with nature. And these are two very

22 different approaches. The align with nature, you
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1 have to learn from nature, work with nature,

2 figure out what it is that allows you to bring

3 out the best.

4 And I think a lot of the conflict

5 potentially here is that these are such different

6 world views that it's hard to bridge that. And

7 then the final point I want to make is that in

8 this field as well as in the field I'm most

9 involved with natural medicine, there is

10 constantly these dueling science reports out

11 there. And the former editor and chief of the

12 New England Journal of Medicine said "Of science

13 around clinical research that it is simply no

14 longer possible to believe much of the clinical

15 research that is published."

16 And I think that that's a really

17 interesting point. We have reached a place in

18 the development of our societal support for

19 science belief that there is that we can always

20 arrive at the truth that we are inviting a fair

21 amount of a vested interest into the scientific

22 conversation.
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1 So I think it's just incumbent upon us

2 to be very careful in terms of giving credence to

3 any one study or set of studies, but we

4 constantly have to look at what are some of the

5 interests that may be involved. And that's not

6 to say you couldn't get good industry science. I

7 wouldn't want to make such a generalization.

8 But the use of science again in a

9 decision like this is going to require a lot of

10 careful digging on our part as Board Members to

11 get beyond what may be compromised findings.

12 DR. THICKE: Thank you, Dan. Steve?

13 MR. ELA: As a new Board Member, I

14 recognize the complexity of this topic and it's--

15 I can say it's fascinating and scary at the same

16 time to come on the Board at this point, because

17 there are obviously many, many arguments on all

18 sides of this.

19 And you know, I have read many of the

20 documents and I have appreciated the public

21 testimony, because, you know, it is a learning

22 curve. And so even though some of my questions
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1 probably have been pointed, I also am very open

2 to hearing, you know, what people are saying and

3 what the situation is.

4 And I appreciate Dan's comments. I

5 think that it is a philosophical divide. And we

6 all do come at it from different philosophies. 

7 And that being said, I think most -- I mean, I

8 tend to believe the best in people, that, you

9 know, we know some people do occasionally try and

10 game the organic system, but by and large, I

11 think organic growers are really trying to do

12 their best and within, you know, the rules we

13 set. So I believe in that.

14 I take literally, I guess, the must

15 maintain or improve the natural resources of the

16 operation, including soil and water quality. And

17 that word soil is in the law and I take that

18 seriously. I have listened to the, you know,

19 arguments of biological activity and I hear those

20 and I don't discount those at all.

21 And I -- it's -- you know, I woke up

22 this morning thinking about that. How do we, you
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1 know, find what is right and what is real in

2 this?

3 You know, I guess I -- my thinking, at

4 this point, is that, you know, I think we need to

5 move beyond just raw biological activity. You

6 know, is -- because biology happens anywhere. 

7 It's whether it's -- and it could be good

8 biology. It could be bad biology. It's probably

9 somewhere in between. And that's where I have

10 several of my questions that come back to, you

11 know, in these systems do we have multiple

12 trophic levels?

13 Is it not just bacteria or fungi, but

14 do we have nematodes? Do we have arthropods? Do

15 we have mammals? And other, you know, things

16 that are part of this ecosystem. And that's part

17 of my criteria. And I'm -- not to say that

18 everything has to be included, but I think we

19 need to pay attention not just to a single subset

20 of biology.

21 I also tend to look at -- we talked,

22 you know, the over-use of the word
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1 sustainability, but I'm going to truncate it to

2 sustaining. And that is in a system if we -- and

3 we are talking about plant systems, you know, or

4 I'm going to talk about plant systems, if you

5 were to remove adding any other inputs but water,

6 because we recognize a plant needs water to

7 survive, how long will that system sustain

8 itself? Given that, you know, maybe the plants

9 will have lower productivity or whatever, but

10 will that system continue to operate on its own

11 as its own ecosystem for how long?

12 And I don't have a specific time of

13 what -- you know, where that breaks. You know,

14 is it three days? Is it a year? Is it 10 years? 

15 But I tend to think of an organic system as being

16 -- that's something we are trying to grow and

17 develop as something that will sustain itself

18 with less human input, not more human input.

19 And finally just I think we are

20 dealing with incredibly complex ecosystems and

21 Dan just said, you know, it's the philosophical

22 thing of human hubris. It would -- our system is
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1 so complicated that we will never understand or

2 do we think we can design them.

3 As an organic grower, I was a

4 conventional grower originally, I became an

5 organic grower. I have grown organically for 15

6 years now. The older I get, the less I know. 

7 And the more I look at our system in our farm and

8 I can, you know, look at through my eyes, that

9 the system becomes more and more complex the more

10 we understand.

11 And you know, I have learned that

12 maybe the best thing to do as a grower is to let

13 the system do most of the work and keep my hands

14 off of it. And only enter into that system when

15 we really have something that needs to be -- that

16 is catastrophic like for us that would be

17 probably moth and worms.

18 So in this incredibly complex system,

19 I believe that, and I think Harriet mentioned it

20 yesterday when we were talking about the

21 wildlands conversion and mentioned wetlands, and

22 where -- and it really struck me because as-- you
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1 know, developers destroy wetlands and they have

2 to add wetlands in.

3 You know, 10, 15 years later those

4 wetlands only have 10 or 15 percent of the -- or

5 whatever, I'm not going to quote a specific

6 number. But a fraction of the biodiversity that

7 those original wetlands had.

8 And I believe, I guess, in that human

9 hubris that soil systems, organic systems,

10 organic agriculture are incredibly complex. And

11 that we are going to have a very difficult time

12 recreating them. And that we may be able to

13 recreate something, but it's not going to have

14 the same complexity and the same resilience that

15 our natural systems do.

16 I recognize sandy soils. I recognize

17 all the extremes and that's where the debate

18 happens. You know, is a sandy soil a hydroponic

19 operation even though it's a soil? I get that. 

20 And I get these complexities, but I just think we

21 need to be -- I tend to fall on the side of human

22 hubris, that I don't believe that we can engineer
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1 reliably some of these systems.

2 That being said, I hear what people

3 are doing and I have talked to fellow Board

4 Members that visited operations and I get that

5 some of these operations in containers are, you

6 know, complex and are diverse. And I take that

7 into account and I'm listening. So don't take my

8 comments by being closed-minded, but I just feel

9 as a grower and somebody representing organics

10 that I feel like I need to represent the

11 sustaining ability of a system, the resilience

12 and the complexity.

13 DR. THICKE: Thank you, Steve. Lisa?

14 MS. DE LIMA: So I liked how Dan

15 defined the two different world views. And what

16 struck me was the problem I'm having with this

17 whole issue is that I feel like I have both world

18 views. It's not -- I'm not easily at one end of

19 the spectrum or the other. I mean, I definitely

20 agree with a lot of what Steve said. And like we

21 don't know everything and the human hubris and

22 all of that.
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1 And then I look at organics, I mean,

2 personally, as a way to, you know, restore the

3 environment. I think that's why we are here. 

4 But then I think about how small the fraction

5 organics is of the whole food sector and, yeah, I

6 do want to grow organics because the end goal is

7 to have more organic production, so that there is

8 less pollution, contamination, all of that

9 happening. And that's where I get stuck, where

10 it's not -- I see both ends of those, the

11 mechanistic, as you said, or the in-line with

12 nature. And that's where I really struggle.

13 And then also to Dan's point about

14 consumers being a little, you know, all over the

15 place. Currently it's not a question that I get

16 a lot from our consumers, which is interesting. 

17 I mean, we have a lot of them and we have a

18 fairly educated consumer base. And there is

19 definitely a subset of customers that really

20 understand organics and believe in organics from

21 a soil-based system.

22 But the market has grown so much and
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1 there is so many people that, you know, at times

2 I wish they were buying organics simply be -- I

3 mean, for the reason that I got into it, which is

4 the environment. But the truth is, a really

5 large chunk of them are buying -- there was a

6 public comment that, you know, listed what are

7 the reasons people buy organic? 

8 And more and more, it's for health. 

9 You know, what are you feeding your family? They

10 want to know the food is free of X, Y and Z. So

11 we are also at that weird space where we, and

12 this whole community, understand why we got into

13 organics. And for many of us, it's from an

14 environmental standpoint.

15 You know, so I struggle. I know we

16 have talked about labels. And I kind of go back

17 and forth on whether that would be a good thing

18 or just not necessarily a bad thing, but just a

19 confusing thing to the customer, as we have like

20 more and more and more labels come into the

21 marketplace, what that would really do.

22 So I still haven't really got to a
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1 place in my mind where I think the label would be

2 helpful or just confusing. So that doesn't --

3 I'm just putting out there that I'm confused.

4 MS. OAKLEY: I just also want to say

5 that's fine. In any of your -- like don't --

6 nobody has to have a definitive -- like this is

7 just a discussion. And that is so helpful just

8 to hear your thoughts. They don't have to be --

9 none of us, I think, are fully formed.

10 DR. THICKE: Ashley, I think you had

11 your hand up. And then Dave was it?

12 MS. SWAFFAR: Okay. So first, I just

13 want to say Emily and Francis, thank you for your

14 leadership on this. This is not an easy task. 

15 This is the hardest thing that we will face on

16 this Board. I really -- oh, and Harriet and

17 Jesse. I'm sorry, yeah. I don't want to forget

18 you guys.

19 And I really appreciate what Emily

20 said about cooperation and I think that's the way

21 forward with this. I might know a thing or two

22 about a proposed rule that is currently in -- you
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1 know, going through the system where there was a

2 lot of decisiveness. And it had some struggles.

3 So I think that's really our best way

4 forward is to come together to hash things out

5 and see where we can find middle ground and move

6 forward with that.

7 So some of the things that I would

8 like to see moving forward is -- I know this

9 might not be the best thing, but I really would

10 like to see one more discussion document with

11 some of the changes that were suggested by

12 commenters, maybe doing a little bit more in

13 depth on definitions.

14 And then, you know, earliest would

15 vote spring of '18. Just because I think, you

16 know, this showed the definitions that you

17 proposed and you tweaked -- some commenter said,

18 you know, maybe not this, but we should do this. 

19 I think one more round of that would be critical

20 because I feel like we need to get this right.

21 The language needs to be right. We

22 don't need to have language coming out that is
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1 not really what is happening out there, because

2 then it doesn't prohibit or allow the right

3 thing. So I would really like to see one more

4 discussion document.

5 And then critical for me is I want to

6 see containers at the same time, because I feel

7 like that line is so blurred in the community, on

8 the Board, what is hydroponic, what is container? 

9 I really would like to see those moving forward

10 together, voting together, preferably containers

11 voting first over, then hydroponics just because

12 I think that's critical to explicitly separate

13 those documents.

14 And then you know, we have heard so

15 much stuff about well, if you say a percent of

16 nutrients coming from it, then we might be okay. 

17 But I just want to say if any restrictions are

18 put on like only 20 percent nutrients or

19 something like that, I want to see that applied

20 to soil farmers, too.

21 We can't just say it's got to be this

22 one sector of the industry. If you put
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1 stipulations on them, I want to see it across the

2 board. That's not probably a popular thing with

3 some soil folks, because there is areas of this

4 country where people are growing in soil that

5 probably shouldn't be growing in soil. You know,

6 so I just want a fair playing field if you go

7 down that rabbit hole. 

8 And then one other -- another thing

9 for me is I want to see these operations. I

10 haven't seen these operations. I would like to

11 ask the program if it's possible for us to see

12 these operations, to see what is going on in that

13 system? I think that would be very, very helpful

14 for me.

15 I am all over -- I get on a plane

16 every Monday, so you know, maybe I could just go

17 on my own, but I think it would be very important

18 for us as a Board to look at some of these

19 operations, because I think there are some --

20 probably some pretty cool ones out there that

21 would meet a lot of our definition of organic.

22 And you know, seeing those up close
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1 and personal, it's just my thought, I really

2 would like to see that before we move forward on

3 voting.

4 And then my like core of where I come

5 down to on this issue is access to organic

6 produce. So I'm not fortunate enough to live in

7 some really great areas of the country like

8 Viroqua or Portland or somewhere like that. You

9 know, it has just been within the past like

10 couple of years that I have had access,

11 consistent access to organic produce.

12 I actually was in a big box retailer

13 the other day in my small town of like 5,000

14 people and I hear on the loudspeaker come check

15 out our new expanded organic produce section. 

16 And I'm just like yes, that's so awesome, you

17 know. In Arkansas, I mean, we are not an organic

18 hotbed, you know, so it's really important to me

19 to see that on the marketplace.

20 And you know, I think Phil LaRocca

21 nailed it on the head for me of where I'm at with

22 this issue. If I've got tomatoes, and I've got
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1 soil-based hydroponic, yes, that soil one is

2 going to be better. But if I've got conventional

3 tomatoes and hydroponic organic, I'll choose the

4 hydroponic organic. 

5 And so that's where I'm at on

6 availability of this is there's a lot of places

7 in the country that, hey, we are super excited to

8 even get anything organic. And if anybody is

9 wondering where I'm going with all my questions I

10 asked this week, is what percentage of the market

11 is going to be taken away if we prohibit

12 hydroponics or whatever form we do. Data's not

13 really out there, but I hear there is maybe some

14 -- Lynn might be working on getting some good

15 data.

16 You know, we heard some of that 23

17 percent of tomatoes, greenhouse. We're not sure

18 what that data means. It could be in-ground or

19 not. But you know, I want to see those numbers

20 because if we take away 44 percent of all

21 peppers, you are talking about the Midwest, the

22 South, forget it. You are not getting tomatoes
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1 or peppers or cucumbers anymore.

2 And it's really important to me to buy

3 organic because it's -- well, it's non-GMO

4 pesticide-free, things like that. And I think a

5 lot of consumers feel that way. 

6 And I have a small farm. I grow in

7 the soil, but it's really small, and I don't feed

8 that many people in my community, and there is

9 not that much access. So that's where I'm at. I

10 don't know where to draw the line. I feel like

11 there is probably some systems that I would say

12 don't meet organic, but I feel like there is

13 probably some that I would be okay with, but

14 that's just where I'm at right now.

15 I'm undecided on where that line is.

16 MEMBER THICKE: Thank you, Ashley. 

17 And I think A-Dae is next.

18 MEMBER ROMERO-BRIONES: So --

19 MEMBER THICKE: And then Tom and then

20 Sue.

21 MEMBER ROMERO-BRIONES: Okay. So I

22 want to start by saying I'm sorry if I offend any
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1 of my fellow Board Members or anybody in the

2 audience. (Foreign language spoken.) Which is,

3 in my language, means I am Cochiti, and that

4 informs almost everything I do.

5 And when we talk about Cochiti, there

6 are Pueblo people who are some of the most --

7 some of the oldest agriculturalists in this

8 country. They go all the way back to the Anasazi

9 and Chaco Canyon. So that informs. And in the

10 Cochiti way, food is the culmination of all our

11 societal institutions, from politics, from legal

12 to religious, and these things culminate in our

13 food systems.

14 And so when we are looking at this

15 issue, I think, for me, I have to look at the

16 economic impacts. I have to look at the legal

17 language, because encoded in these systems are

18 the biases or the ways that society protects

19 certain classes of people.

20 So when we look at economic impacts,

21 we can say we are just going to look at a legal

22 perspective of things, but in this legal system,
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1 we are protecting certain classes of people, and

2 we have to kind of take those considerations into

3 view when we view anything when it comes to legal

4 analysis.

5 And that's the whole reason that I

6 became a food and agricultural attorney is

7 because there are biases in the way we word, they 

8 lead -- the way we word our legal provisions in

9 this country. 

10 And unfortunately, there is a whole

11 class and group of people in this country who

12 don't have access to land. This goes back to our

13 conversation yesterday where we have an entire --

14 entire nations of people who were disenfranchised

15 from their original or ancestral land bases.

16 When you look at Hawaii, for example,

17 the cost of land is astronomical. And the ones

18 who cannot afford it are the indigenous peoples

19 of that land. They can't even afford to buy

20 homes, because the land is so costly.

21 And so when I start from that point,

22 this issue is incredibly personal, and from legal
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1 training, I try to divorce myself from that

2 personal view. But again, in the Cochiti world

3 view, we are in a relationship with our

4 environment, which includes the soil, which

5 includes the plants we grow, and our success as a

6 people is extremely -- is tied to intimately to

7 those elements that we interact with on a daily

8 basis.

9 But on the contrary, when you go to a

10 place like Hawaii where they believe they are

11 evolving in the same kind of system but with

12 water, I'm sometimes afraid those systems like

13 you find in Hawaii are going to be thrown out

14 with the bath -- the baby -- throw the baby out

15 with the bath water, that same system.

16 So I think there are systems that are

17 highly -- are old, innovative, and can meet these

18 same philosophical principles that Cochiti have

19 in Hawaii. So I mean, you can go to the middle

20 of a lava field, and you will find an indigenous

21 native Hawaiian farmer who probably has what

22 could be defined as a hydroponic system, but has
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1 been in existence for a long time.

2 So I think those kinds of systems, I

3 know they are on the periphery of most of our

4 discussions, but the periphery or those

5 boundaries are just as important to this

6 conversation.

7 And I also think that this is such an

8 important issue that we have to consider the way

9 we do our process within the Board. So our

10 typical process is subcommittee. We have

11 conversations on the phone. But I think this

12 issue warrants a different view of how we process

13 this. Perhaps it is having a facilitated

14 conversation or more than one conversation when

15 we are all together in the same room.

16 I don't know if the processes that we

17 have right now lend itself to a thorough

18 discussion that will lead to a discussion

19 document that would reflect the varying

20 perspectives on our Board. So I say all of this

21 to say I am confused, but I know where my

22 starting point is, and I definitely appreciate
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1 all the comments from the public. It lends to

2 the confusion, but it offers some insight to how

3 other people view this issue, and I definitely

4 take those to heart. Thank you.

5 MEMBER THICKE: Thank you. So next is

6 Tom and then Sue and then Scott and Dave.

7 CHAIR CHAPMAN: So I'm just going to

8 say a note to self, don't follow A-Dae in

9 comments, because I feel like mine are going to

10 be slightly superficial compared to that

11 passionate statement. So I want to echo what

12 Ashley said and then thank Francis, Emily,

13 Harriet and Jesse for taking this on. Weighty

14 issues like this are always difficult, and you

15 guys showed great leadership in taking it, so I

16 appreciate that.

17 I'm going to make I guess two points

18 and then have a suggestion for maybe where we can

19 go from here.

20 But I do share in the confusion that

21 people have around resolving this issue. And I

22 do share a lot of the thoughts that have already
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1 been shared by Dan, by Steve, by Lisa, and by

2 Ashley.

3 So one point that does constantly

4 weigh on my mind is I do fear a competing label. 

5 And I don't think a bioponic label outside of the

6 organic family benefits organic. I have seen the

7 damage done by the non-GMO project and consumer

8 confusion on that.

9 And I have -- I think that is in part

10 driving pricing issues for farmers. I have seen

11 them for organic almonds in California. I think

12 it is also part of the issue with organic grains,

13 in addition to complex other issues like imports.

14 But you also have to weigh that

15 against, any compromise on these solutions can't

16 compromise consumer trust on a label. I mean,

17 that is paramount. And so, is there a way to

18 maintain consumer trust as well as prevent

19 competing and confusing labels?

20 I also -- I think that, I mean, this

21 is going to kind of build a little bit on what

22 Emily said about maintaining friendliness and
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1 collegiality in this discussion. I think we also

2 need to get beyond reductionist arguments. And I

3 see this on both sides.

4 You know, one side is saying organics

5 is about the soil. And they cite OFPA Section

6 6513 and that is true. It is about the soil.

7 And the other side talks about

8 organics being about the inputs. And no one has

9 cited this, but Section 605.04 about National

10 Standards in Organic Production, the very

11 beginning of OFPA, outlines what an organic

12 agricultural product is, and it doesn't mention

13 soil, but it mentions inputs. So it's about

14 inputs. It's about soil. It's about inputs. 

15 It's about a lot of things.

16 The system is greater than just one

17 item, and we need to look at all of these. But

18 the reductionist arguments are not helping us

19 move this forward.

20 So how do we move this forward? I

21 don't have a great solution for that. I've got a

22 starting point, I think, which is part of the
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1 confusion I have is around confusing terms. You

2 know, I think we have good starting points with

3 terms, both from the 2010 document and this

4 proposal. 

5 But I noticed folks talking past each

6 other in terms of container production,

7 hydroponic production, bioponic productions that,

8 you know, there is an operation that might fit

9 all three of those definitions for one person. 

10 There is an operation that might fit one of those

11 definitions for a person. 

12 There is an operation that might fit

13 none of those definitions. So I think we really

14 need to start with a common set of terms, so we

15 can ensure that we are all talking about the same

16 production systems, and then we can start looking

17 at the systems and determining from there what is

18 the important criteria to evaluate these against.

19 The objective of this would be not to

20 define systems for inclusion or exclusion at this

21 point, but really just to define discrete,

22 separate, accurate descriptions of various
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1 production systems and use that as a foundation

2 then to move the conversation forward around what

3 meets the criteria and what doesn't.

4 So that would be my roadmap to

5 starting to get towards a proposal. I don't have

6 a timeline. I do like a lot of the discussion

7 that has been around explaining this to the wider

8 Board as best we can to get a full set of input.

9 And that's all I've got for now. But

10 again, I thank everyone for their leadership and

11 time and thought on this subject.

12 MEMBER THICKE: Thank you, Tom. Next

13 we have Sue.

14 MEMBER BAIRD: I too am humbled by the

15 knowledge on this Board and by the willingness to

16 come back for further discussion. And I thank

17 Francis and Emily and Jesse, and what's your

18 name, Harriet, for their willingness to do this.

19 I am -- when I first was asked by the

20 Missouri Department of Agriculture to develop an

21 organic program, I said I don't even know what

22 this is. That was back in '98-'99. I don't know
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1 what organic means. I don't -- how can I develop

2 a program? And they said well, just read the

3 proposed rule. You can -- I said oh, this is

4 just a HASSUP. I can do this, because I came

5 from a poultry processing facility, and we were

6 the first ones that had to implement HASSUP. And

7 I said I can do this.

8 But then I started into the organic

9 world, and I said, whoa, this is the right thing

10 to do. This is what my grandmother taught me

11 back to the Cherokee Indian and reverence of our

12 earth and reverence in our environment.

13 So there is that side of me, and then

14 there is the other side of me which is my

15 grandfather's side, which were German farmers

16 traced back to 1600. We have always been

17 farmers, and I'm proud of that. And we have

18 always been small family farmers.

19 My father passed at 52 because he was

20 so committed to working that small family farm,

21 so he worked full-time to support that farm, so

22 that he could do his love, which was farming.
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1 So the second criteria for me is that

2 we don't leave small family farms out. I see

3 increasingly, at least in Missouri and in

4 Arkansas, land being gobbled up by people from

5 California or somewhere that has a lot of money

6 that comes in, for us a lot of money for our land

7 values, and they are gobbling up the land.

8 And family children who would love to

9 stay on that farm can't afford the land anymore,

10 because their parents, they put every dime into

11 it, so that is their inheritance. So they can't

12 afford to just turn the land -- the farms to

13 their children. They have to be able to sell

14 them to be able to continue through their elderly

15 life.

16 And I'm telling those stories because

17 I want you to understand where I'm coming from. 

18 I totally -- I said when I introduced myself, I

19 have no skin in the game. I don't grow

20 commercially. I'm not hired by any one

21 certifier. I am independent. And I think that

22 gives me a unique perspective.
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1 I too am confused. You know, some of

2 the Boards say well, where to you stand on this? 

3 And one day I was out there, whoa, I'm all about

4 the soil. And the next day, oh, man, I'm all

5 about the -- at least the aquaponics and the

6 container growing and those things. And it's now

7 even more. It's not a daily flop. Now, I'm an

8 hourly flop back and forth.

9 I'm confused. And I applaud this

10 subcommittee for saying we need to come back and

11 to give some clear definitions and more thought

12 into this. Just my thoughts. I love this

13 industry. Thank you.

14 MEMBER THICKE: Thank you, Sue. Next,

15 Scott is in line.

16 MEMBER RICE: Thanks. There is a lot

17 of us on this Board. We have a pretty diverse

18 stakeholder group, and mine is no different

19 thinking about my certifier colleagues, some very

20 interested in these innovative systems, finding

21 systems that in their view meet the regulations.

22 Others that we have heard from are
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1 feeling quite the opposite that, as many of the

2 producers have expressed, are very committed to

3 that soil concept.

4 And personally, my thoughts have

5 evolved on this over the years where I came from

6 gardening and learning how to farm and

7 apprenticing on farms, really learning to

8 appreciate, growing to appreciate that soil

9 aspect. And then as I have progressed in this

10 field and seen so many different kinds of

11 operations, I have seen a lot of innovation that

12 really meets the spirit and the systems approach

13 that organic is all about.

14 And so share a lot of the comments, of

15 course, that many of you have already shared. I

16 think through all of this, I am more of a kind of

17 visual person, so I keep getting this sort of

18 spectrum floating above me of, is it based on

19 substrate? Is it the input? Is it the

20 percentage of this? Is it the percentage of

21 that? And what does that -- how does that all

22 combine to meet the spirit and intent and letter
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1 of the regulation that we all deal with?

2 And from a certifier perspective, I

3 immediately get heartburn trying to think of how

4 we would actually evaluate that on a consistent

5 basis in a fair way. And I really feel like

6 those strong definitions are going to be needed

7 to find that common language, as many of you have

8 already expressed.

9 And I think we need to kind of, on

10 that same front, have some caution in how we

11 define those because we don't want to exclude the

12 operations that A-Dae mentioned. Some that we

13 heard from some other folks that are

14 incorporating aquaponics and gaining fertility in

15 a closed loop system, that is, in my mind,

16 precisely what organic is all about.

17 In the certifier world, we get a lot

18 of questions, and often as much as we hate to say

19 it, the answer is well, that depends. And I

20 would like to minimize that answer in relation to

21 hydroponics and use growing operations as much as

22 we can, because kind of going back to that common
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1 language, we need to be able to speak that same

2 language and clearly express to our certified

3 operations and each other what it is that we are

4 comfortable with and what is allowed and what is

5 not.

6 So I appreciate the view of moving

7 forward and establishing that common language.

8 MEMBER THICKE: Thank you, Scott. 

9 Dave, I think you are next.

10 MEMBER MORTENSEN: I too thank the

11 foursome, fearsome foursome for taking the lead

12 on this. I thank the receptivity of the Board to

13 the new members. For those in the audience, you

14 know, for a number of us, this is the first time

15 we have met, and it has been a really wonderful

16 experience for me.

17 Dan's comments, Dan kind of opened the

18 personal reporting by making the comment that

19 there is a credibility problem in science today. 

20 And I think about this a lot, because I'm the

21 "scientist" on the Board. But I just am coming

22 out of a deep dive on GMO, just a spiraling out
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1 of control GMO problem, both from a science point

2 of view, doing a lot of the science myself and

3 the folks that work with me, but also a lot of

4 policy work in D.C.

5 And one of the things that I think is

6 very important, in response to Dan's comment

7 about science and its credibility, is that you

8 will hear like my dean and administrators at

9 universities, we only do science-based stuff

10 here, you know?

11 And the problem with that pounding on

12 the table about we only do science-based stuff

13 here is that while scientists can be quite

14 objective about their methods, scientists are

15 incredibly subjective about the questions they

16 ask.

17 So you can have an entire -- whole

18 departments and, in fact, we do at many of our

19 finest universities across the country asking

20 this question and that about how do we do this

21 and that, molecular engineering or this or that,

22 GMO this or that?
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1 And far fewer asking, well, why are we

2 doing this in the first place? Is it for input

3 reduction or sales of things, or what's the

4 motivating force behind this? What are the

5 ecosystem service level impacts of these things? 

6 Very few people ask those questions when you

7 might have 100 folks hired at high salaries

8 asking, how do we put the gene in? And one or

9 two asking, what are the ecosystem service

10 impacts of this or that technology unleashed on

11 the landscape?

12 And this is not an exaggeration. So

13 I think it is going to be very important on -- as

14 we proceed as a group that we are asking the

15 right questions. And I think that, having spent

16 the time that was spent, many hours on the phone

17 together, you know, I'm confident we are all into

18 asking the right questions. And if we are not

19 asking the right questions, that we call each

20 other out on that.

21 And those questions, in my view,

22 coming to this as sort of agroecologist and
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1 ecotoxicologist kind of person, an ecosystem

2 services person is -- are things like what's the

3 ecological footprint of the practices that we are

4 assessing? And do they conform with the organic

5 standards that we have?

6 I think that the point that Steve made

7 at the outset about resilience is a very

8 important question. How resilient are the

9 systems? So those are the sorts of -- you know,

10 what are the ecoservice implications of these

11 things?

12 I grew up in a city. Before I went

13 back to school, I was teaching in Spanish Harlem

14 with children. I totally get the problem of food

15 deserts and the disconnection, or at least I get

16 it pretty well, of understanding. Like when you

17 ask folks, where does your food come from, and

18 some kids think bags of food grows on trees. We

19 have an education issue here also.

20 As for how we get to the answers, I

21 think there are a couple of process things that I

22 think we heard some really important things here,
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1 and I'll -- and without going on too long, I

2 totally agree with A-Dae's comment.

3 My way of thinking about what A-Dae

4 was saying is in Peter Block's language, he is

5 kind of a teaching, pedagogic guy. We must, as

6 communities of people, create space for

7 conversation. And this is definitely a case

8 where we need to create space for conversation,

9 and that means together face-to-face, not on the

10 telephone for an hour here and an hour there with

11 a lot of work in between.

12 I also agree with Ashley's point that

13 it is very important that we get out and see

14 these things. We see farmsteads growing in the

15 soil. We see what does an aquaponics system

16 look like

17 At one of the early calls for the new

18 members, I remember Asa brought this up, we need

19 to get out and see these things. And so

20 personally, I have actually been scheduling days

21 where I go out and visit places. I have now been

22 to three. I would love it if we could do that
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1 together and talk about it, like debrief, what

2 did we see? What did we think?

3 And then it's clear that we are going

4 to need people. Like sometimes I can like get

5 off track. It's going to be important that we

6 keep people in the loop and engaged as we go

7 forward to be sure that we have got the best

8 solutions worked out here. That's all.

9 MEMBER THICKE: Thank you, Dan. 

10 Joelle?

11 MEMBER MOSSO: Okay. Quite an act to

12 follow as well.

13 First, just thank you to everybody on

14 the collaborative conversation we have been

15 having regarding this. Something that I know I'm

16 struggling with, is I'm extremely confused about,

17 I guess, the age old question of when does

18 something stop becoming -- or stop being what it

19 is and start being something else?

20 And I think that's a big question for

21 me in regards to the current discussion document

22 and how it looks at container growing. And on
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1 that spectrum of what is maybe more traditionally

2 water-based hydroponics to the gradient as to

3 when we end up in beds in the ground.

4 So I think it's a continuous spectrum. 

5 It's not one that is discrete. So I think we

6 need to do better on the Crops Committee to get

7 definitions that allow us to use a vernacular

8 that everyone understands, because I do think we

9 talk in circles.

10 I say hydroponic. Maybe that means

11 one thing to you, and it means something else

12 completely to somebody else. And so I think if

13 we still have that uncertainty, we have a lot of

14 work to do. We can't speak and understand what

15 we are talking about.

16 Yes, I think one thing we all have

17 figured out at least, is that we don't understand

18 a lot. And that leads me kind of into this

19 situation where I think how can I prohibit

20 something I don't even understand? As well as

21 how can I allow something that I don't

22 understand?
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1 And I just think about it. Maybe it's

2 the microbiologist in me, but the evolutionary

3 development of different things. It's, you know,

4 when we decided not to be hunter/gatherers and we

5 started putting crops in the ground, what else

6 did we change? What ecosystem did we alter when

7 we started doing that? And now we are at another

8 stage in the evolution where we look at taking

9 something that has traditionally been grown in

10 the ground and perhaps not growing it in soil or

11 not growing it in any kind of solid substrate.

12 So it's just these are all things that

13 I think about from more of a scientific

14 perspective.

15 And then something that, more on a

16 personally or ideology, if you look at the

17 impetus of the organic system and the organic

18 movement, was ecological and sustainable and how

19 can we have healthier food for everybody?

20 And then that gets me more into what

21 A-Dae was kind of mentioning as well as many

22 other Board members. Accessibility to healthier
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1 organic food is something that I really struggle

2 with. If we are to limit or create a system

3 where we selectively say this is okay and that

4 means someone else doesn't get organic, I have a

5 problem with that.

6 I want organic to be the form of

7 agriculture, not a subset of agriculture. So

8 these are all kind of things that weigh heavy on

9 myself when thinking about these decisions. And

10 I think it's just -- particularly, if we can get

11 to that language where we really understand the

12 difference between hydroponic versus container or

13 container versus soil, and we go from there, I

14 think we will have a better shot at getting this

15 right, at least clarity.

16 In regards to alternate labeling, the

17 marketer in me, I think of a couple things. So

18 one, we -- let's say we decided to get rid of

19 hydroponic, however you want to describe it, we

20 will give rise to an alternate competing label,

21 because we are a capitalistic society, and that

22 will become a detriment against the organic
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1 label.

2 And that weighs heavy on me, and I

3 don't know that that would do anyone justice. I

4 think part of the reason we have conversations

5 today about what does organic mean to our

6 consumers is that our consumers still don't

7 understand what our label is. And if we were to

8 introduce another similar to what non-GMO did

9 when organics were still there, what was already

10 non-GMO, I think we just see the dilution of our

11 integrity and our market. And I do worry about

12 that.

13 So I think I'll leave it at that and

14 then just emphasize how appreciative I am of the

15 collaborative nature of this Board and on this

16 topic. It is complex and will continue to evolve

17 as everything continues to evolve. I just think

18 about evolution as that continuum in so many

19 things.

20 And there was a day where we weren't

21 planting crops in the ground, and we were novel

22 and revolutionary in figuring out how to
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1 cultivate land. And I just would fear that in 50

2 years, I will look back at this, or history will

3 look back at this and say well, you just

4 completely didn't understand.

5 We were ignorant, and we thought we

6 understood, and that's where we are at today. 

7 I'll leave it at that.

8 MEMBER THICKE: Thank you. Asa, are

9 you interested in making some comments?

10 MEMBER BRADMAN: Yes. And I wish I

11 could just kind of, as a premise, incorporate all

12 the comments that have already been said into

13 what I would say. And I think I have heard a lot

14 of things that resonate with me. In fact, almost

15 everything does.

16 So just a quick couple of comments

17 though. One, I definitely, to reemphasize what

18 was said earlier, I think it's really important

19 that we see different systems. I'm most familiar

20 with soil-based growing systems over decades, and

21 I really -- I kind of have put myself on a

22 mission to go out and on my own penny to see
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1 different kinds of systems ranging from aquaponic

2 to hydroponic to container and really try to

3 better understand those.

4 I have seen hydroponic systems that

5 I'm not sure what to call them, whether they are

6 hydroponic or not, and it seems to me they seem

7 aligned to me with organic principles. So I

8 think that's really an important thing. And to

9 the extent that we could do that as a group, I

10 think there is value there, though I realize

11 there is potentially a lot of cost and scheduling

12 issues.

13 I tend to be a person who is

14 compromise-oriented. Ideally, it would be great

15 if we could have consensus. Sometimes compromise

16 can result in an outcome that it doesn't satisfy

17 everyone, and I think that is something that is

18 going to happen here.

19 Another piece here too is that I'm

20 kind of humbled really to be on this Board and to

21 be in a position to make decisions about how

22 other people make a living in the whole system. 
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1 And to the extent that we could have more input

2 and discussion from stakeholders, I think that's

3 valuable.

4 I participate in a panel in

5 California, a scientific panel, and we have

6 incorporated, I think, a lot of -- partly because

7 there is less time involved in terms of the

8 number of people, but there is a lot of public

9 input and discussion back and forth between the

10 Board and the stakeholders, and there is less

11 constraints on -- comments really aren't viewed

12 as testimony. They are viewed as interaction.

13 And I think we have a lot of in the

14 hall conversations here, but maybe we need a

15 forum where there can be a larger discussion or

16 conference or some sort of more interaction with

17 the stakeholders, because we really represent a

18 lot of people and a lot of different views.

19 And then I just want to echo I think

20 A-Dae's comments about processes, kind of what

21 I'm hinting at there. So I don't really have

22 much more to add, but just that this is really a
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1 challenging topic.

2 I will say I tend not to want to

3 prohibit things. I rather would describe, like

4 to describe what we are for and what we want to

5 go forward with.

6 MEMBER THICKE: Thank you. Any other

7 comments? Yes, Emily?

8 MEMBER OAKLEY: Well, I just wanted to

9 see if the four of us who were working on this

10 document who haven't yet spoken wanted to speak? 

11 So Harriet, did you want to go?

12 MEMBER BEHAR: Okay. I've got a few

13 comments. So in my work as, basically, a

14 consultant to organic farmers, I run an info 

15 line, and people call me from all over the

16 country, mostly in the upper Midwest and I get a

17 lot of questions from transitioning farmers.

18 And I can always tell when they call

19 up and they say, what is the organic herbicide? 

20 I want to transition to organic. I just want to

21 know, you know, I'm used to using Roundup. What

22 do I do next?
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1 And then we have a very fruitful

2 conversation, I hope, about systems versus

3 inputs. And that organic is not an input

4 substitution. It is a whole system. And I

5 believe, too, as we were talking about the

6 surveys that if you asked consumers a question

7 about do they feel that organic is more than just

8 the inputs that don't cause them health problems?

9 It's about the environment that we are

10 all sharing. It's about the long-term health of

11 our entire planet. It's about healthy food for

12 seven generations and beyond. It's about a type

13 of agriculture that actually offers hope for

14 fixing the problems that we already have and

15 actually taking land that has been despoiled and

16 bringing it back to health.

17 Now, are we going to get that

18 biodiversity back completely in every system? 

19 No. I mean, we are doing agriculture. But we --

20 and so then also, I have 20 years as an organic

21 inspector, and I would always ask the new people

22 that I would visit, why did you go organic? And
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1 many times it was because there was somebody in

2 their family that had a health problem. I'm

3 sure, Sue, you run into that. You know, the wife

4 had breast cancer. The uncle died of leukemia. 

5 You know, whatever.

6 But then if I go back two or three

7 years later, I'll say what do you see a

8 difference on your farm? And they would usually

9 say, well, my livestock is a hell of a lot

10 healthier than it was before. And then the next

11 thing they would say is I see the wildlife coming

12 back. I have owls. I have badgers. I have

13 snakes. I have frogs. I have all these things

14 that they didn't really notice were missing when

15 they were conventional farmers.

16 But then they started coming back,

17 because they had been removing the toxins from

18 the environment, but not only that, they were

19 having a crop rotation which included sod crops. 

20 So the birds could nest, right? They were having

21 pasture. They were having hay ground or

22 whatever.
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1 So there was more to it. So yes, they

2 came to it first for health, for non-use of

3 toxins, but they became cemented as organic

4 producers because they could see that their

5 ecosystem was becoming healthier.

6 And there's -- and when you talk to an

7 organic farmer, a long-time organic farmer and,

8 of course, this is happening now, would they go

9 back to conventional production if they could not

10 get the price? And they were like are you crazy? 

11 Go back to this despoiled environment that I was

12 leaving for my children or I was living myself? 

13 No. I enjoy knowing that the geese can land on

14 my land, that I'm going to have all this

15 wildlife.

16 So I think we are not educating the

17 consumers about the benefits of organic in that

18 wider way. It's an easier sell to just say that

19 organic is about the inputs, but it's much more

20 than that.

21 Okay. About the economic impact,

22 actually, if the program changes something in the
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1 regulation, they are going to have to, isn't it

2 correct, Paul, shake your head yes, we are going

3 to have to justify whatever we do from economic

4 impact.

5 So that actually, I have made note of

6 that, that that should probably be somewhat in

7 our proposal, to give the program some direction,

8 if we are making a proposal to change something,

9 to help them with that. And especially have it

10 on the public record that we did look at that. 

11 It's not like we didn't care. Of course, we did.

12 But as, I'm not sure who said it, it

13 will -- either way, it is going to affect people. 

14 If there is more hydroponic in the market, it's

15 going to affect the soil people. If there is

16 less hydroponic in the market, it's going to

17 affect possibly at least for the short-term less

18 availability perhaps. I'm not 100 percent sure

19 on that. But it definitely -- it would obviously

20 affect the people who have the hydroponic label

21 now who would lose -- organic that would lose it.

22 Let's see if I have talked about that. 
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1 I think we have to find a place that protects our

2 brand for the future. It is wonderful to be

3 innovative and look at innovations, but I have

4 come to these meetings for years and years and

5 years, and I have heard Monsanto come and say

6 hey, GMOs can offer a lot to organic. Look at

7 the innovation. Don't stick your head in the

8 sand.

9 So I think we need to say, yes, some

10 things are innovative, but some things don't

11 deserve to carry the organic label. And we do

12 need to go back to the spirit of the law, not

13 just the letter.

14 I have a question for the program

15 about that. If we do get together and visit, you

16 know, maybe perhaps spend a day or two visiting

17 some operations and then talk about them, so I

18 would imagine it would be at least a two-day

19 event, so we have that time for discussion, would

20 that have to be a public meeting, if we are all

21 there?

22 And I'm not quite done, but if you
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1 want to answer that you can, and then I'll finish

2 up.

3 DR. LEWIS: So this could be in terms

4 of like a site visit where there won't be any

5 deliberations. It's more in terms of education. 

6 So we can talk about that with our Department in

7 terms of what the proper procedures are. And it

8 could be where a future NOSB meeting, where we

9 plan to meet at a day ahead of time to visit a

10 site, so we can look at that. Lots of options

11 here.

12 MEMBER THICKE: Can you explain about

13 the deliberation limitation?

14 DR. LEWIS: Well, in this case, the

15 Board won't be conducting business in terms of

16 seeing a site, making some -- and having

17 deliberations or discussions in terms of, based

18 on what we are learning here, here is the

19 direction we want to take. This is more of an

20 educational opportunity as opposed to an

21 opportunity for conducting business.

22 MEMBER THICKE: Okay. I guess I see
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1 like some others have said, the value of us

2 seeing it and then talking about it, but would

3 that not be allowed?

4 DR. LEWIS: Well, I think it's more in

5 terms of you going to the site, seeing the site,

6 and then based on what you observed, coming back

7 at a public meeting to have that help inform in

8 terms of your deliberations and making

9 recommendations. Does that help in terms of

10 finding clarity? Okay. Thank you.

11 MEMBER BEHAR: Okay. So like I have

12 taught the organic regulation for many years. 

13 Taught Sue. And so really know the OFPA and the

14 regulation quite well. And I can see how there

15 is many gray areas and how people can say that,

16 well, we can support hydroponic here or there.

17 To be open, I grow in containers. 

18 However, I grow in a compost-based mix, and I do

19 not add any liquid nutrients. Would it kill me

20 if I had to stop growing my lettuce in my

21 gutters? Probably not. But I don't think that

22 that's not an organic system. But I think part
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1 of it is because I'm relying on 100 percent soil

2 for the full life of the plant with no outside

3 inputs whatsoever.

4 I also have a couple of fig trees in

5 my greenhouse that are in containers, because

6 outside -- I move them outside, and I bring them

7 inside, but I also grow in the container, I have

8 like a Dutch white clover, and I put compost on

9 there, and then I put my seed and then I lightly

10 till it in. I'm trying to mimic, right, a soil -

11 - it is a soil-based system. It is actually soil

12 in that pot with my fig tree.

13 And I know of others in the northern

14 climate that do things like that. Sometimes we

15 can't grow these tropical plants, right, unless

16 they are in containers.

17 That said, I did mention something to

18 a speaker yesterday, and so far, I have found no

19 one who agrees with it. I'm not saying that this

20 is even what I agree with, but I figure if no one

21 agrees with it, I'm probably headed down the

22 right track.
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1 And that is a label that would say

2 hydroponic made with or grown with organic

3 agricultural -- organic-approved inputs or

4 something like that. If they are not organic

5 inputs, they are organically-approved inputs,

6 right? I hear all these people saying, no, I

7 don't like that.

8 And then it would be a certified

9 organic product. So there would be oversight on

10 it, and we already have a labeling -- we already

11 label things in the handling area that way, and

12 that might be a way. So it would be the same

13 thing, large "hydroponic", small "made with" type

14 thing. That might be one way to approach it.

15 I'm not even 100 percent sure that I

16 like that, but it's a way to, to me, tell the

17 truth, and that's where I started by saying I

18 know the regulation, so let's be truthful about

19 the regulation.

20 I think currently now, things that are

21 hydroponic that carry the organic label are not

22 being truthful about really meeting all aspects
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1 of the Organic Rule. But a label like that is

2 truthful, because that's all they are doing is

3 having organically-approved inputs. But they are

4 not meeting the biodiversity. They are not

5 meeting the crop rotation. And I truthfully

6 think that they are not as resilient as organic

7 systems are.

8 MEMBER THICKE: Thank you. Emily, do

9 you want to say something?

10 MEMBER OAKLEY: I'm sorry, yes, go

11 ahead.

12 MEMBER DE LIMA: Just in response to

13 what Harriet just said about the label, I guess

14 thinking about what Joelle said, I'm not sure how

15 that statement can be made, because I don't know

16 if that's true for in-the-soil organic farmers as

17 well. Like there is a huge spectrum of in-the18 soil organic farming.

19 And if you start to get that specific

20 with a label and say but we are only going to

21 apply that to hydroponics, then you -- sorry,

22 Siri is -- it seems super nuanced, and then you
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1 would have to apply that across the board to all

2 types of farms, because I think there is -- right

3 now we have a big variance in small, large, even

4 just within soil organic.

5 So, yes, I don't -- I'm not on board

6 with that.

7 MEMBER SWAFFAR: I just want to say

8 one thing to the Department. What we are asking

9 for -- right here Paul. So what a lot of us are

10 asking for when we are saying we want to saying

11 we want to go see operations is not the day

12 before the fall meeting, because we need that to

13 help us and guide us in this drafting of another

14 discussion document or a proposal, whatever the

15 Crop Committee does.

16 We need that information beforehand so

17 we can say, okay, this is what this definition

18 means. So I just wanted to clarify that for the

19 Department.

20 MEMBER THICKE: Thank you. Emily?

21 MEMBER OAKLEY: So in the fall, I

22 spoke first on this subject, and I spoke off the
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1 cuff. And it was suggested to me that I might

2 want to read from something in the future. And

3 so I know nobody has done that this time, but I

4 did actually write something down that I do want

5 to read, but I also want to say before I do that

6 that I -- in proposing that we have this

7 collegial environment, I also don't want it to

8 delay us in coming up with a decision.

9 I want us to realize that stakeholders

10 on all ends of the spectrum want us to be

11 deliberate and not hurried, but they also don't

12 want us to delay a decision to the point that we

13 either never get anywhere or it takes us so long

14 that we end up creating more conflict within the

15 stakeholder community.

16 So I just -- I understand Ashley's

17 perspective about wanting to wait, but in my

18 ideal world, we might be able to find some common

19 ground by the fall and put this forward as a

20 proposal and maybe with various separate motions

21 and vote on the ones around which maybe we have

22 the most amount of consensus or agreement. And
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1 then if there are ones that we need to elaborate

2 further, we could bring those back to

3 subcommittee.

4 I just want to put that out there. I

5 also want to say that as a farmer, I make my

6 full-time living growing vegetables and selling

7 them to consumers. I don't have any off-farm

8 sources of income. And I feel the burden in this

9 position of representing those family-scale

10 farmers who are like me who represent a really

11 large percentage of the organic community.

12 I heard anecdotally that 75 percent of

13 organic producers fall behind the $250,000 limit

14 for the organic check-off, which means that a

15 huge percentage of the growers are more like me

16 than I think we sometimes hear in these

17 conversations, because they are on the farm

18 farming, and they may not have the funds or the

19 time to come here and speak to us.

20 So I feel the extra weight of

21 representing that voice to everyone here. And as

22 there are other people on this Board who make
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1 their full-time living farming, but we are

2 definitely a smaller percentage. And I take to

3 heart what Asa said that we are making decisions

4 that affect people's livelihood.

5 So on both sides of the spectrum,

6 absolutely, but to Joelle's point about not

7 wanting to disallow something and then find that

8 the hydroponic or bioponic community creates its

9 own label. I also don't want to see small-scale

10 farmers feel that the label no longer represents

11 them and that they feel so disenfranchised that

12 they move elsewhere, because that also will be

13 very detrimental to the movement.

14 So many of them, as I said in the

15 fall, are talking face-to-face with their

16 customers. And I want to see more direct farmers

17 get certified. I want to see more beginning

18 farmers get certified. I don't want to see less

19 of that. And I want to see this movement grow as

20 many small-scale farmers as we can.

21 I think the answer to organic farming

22 and farming in general is not, you know, more
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1 huge farms. I think it is more people just

2 growing food within their local community and

3 making farming a viable economic career for that

4 to happen.

5 And organics does provide, obviously,

6 an outlet for that. And I just also want to echo

7 the point made that many people who come to

8 farming like me do this because it's both a

9 business and a cause. And it is that cause part

10 that I think is creating a lot of the conflict

11 around this issue, because we don't all agree on

12 what the basic philosophy is.

13 And as organics has grown, you know,

14 it started out with like kind of a hippy back to

15 the land movement. That really was a big part of

16 the genesis of the organic movement. And now it

17 encompasses a wide spectrum of stakeholders. And

18 I am a small scale organic farmer, but I'm an

19 avid organic consumer.

20 And as I told Miles when I was being

21 interviewed for this role on the Board, I'm under

22 no illusion that the organic food that I get in
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1 the grocery store was grown on a 5-acre parcel,

2 and I don't have that expectation, but I also

3 want to see the standards applied equally to all

4 of us. And I agree with Ashley's point that any

5 standard that we create, should we come to some

6 sort of consensus on a container production

7 system, should be applied equally.

8 If there are in-ground farms anywhere

9 in this country that are supplying a majority of

10 their nutrients through liquid means, that causes

11 me as much concern as it would on a hydroponic

12 basis as well. And I'm not sure that that is in

13 keeping with the spirit of OFPA.

14 So I am going to just read, so that I

15 don't speak or whatever too much off the cuff and

16 misspeak in any way.

17 I just want to say that in my view,

18 the expectation in organic farming is that the

19 soil will provide most or even all of the crops

20 nutrient needs. OFPA and the regulations

21 establish parameters for best practices to foster

22 soil organic matter and to provide nutrients
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1 through practices, such as manure and compost

2 applications, cover crops, and incorporating crop

3 residue.

4 Outside sources of macro- and

5 micronutrients are supplied on an as-needed

6 basis, based on the results of soil tests. To my

7 knowledge, in no organic system plan would it be

8 accepted to supply a daily liquid fertilizer to

9 crops grown in the ground. I can't imagine a

10 certifier accepting that, because no -- because

11 the soil should and will provide most of the

12 crops fertility needs.

13 Supplemental nutrients are used to

14 optimize productivity, but not because the crops

15 are dependent on them for growth, which is a

16 really key point for me.

17 In contrast, hydroponic and some

18 container crops are solely or largely dependent

19 on outside liquid fertilizers not just for

20 optimal growth, but for their basic survival.

21 I can't see allowing an organic system

22 plan that relies largely or exclusively on
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1 outside inputs for crop production. This

2 includes the substrate materials used in

3 containers. Those inputs are harvested or mined

4 off-farm and in the case of peat from

5 environmentally sensitive areas with ecological

6 consequences.

7 Rather than inputs supplementing a

8 farm as in-field grown organic crops, fertilizer

9 and substrate inputs are the foundation of the

10 system in hydroponic crops.

11 The dependence on and high consumption

12 of fertilizers and substrate materials for the

13 systems do not, in my view, meet the standards of

14 maintaining or improving the environment.

15 I don't want to see us allow an

16 organic system plan that creates a double

17 standard between hydroponic or container growers

18 and in-field growers. I think a lot of the

19 conversation around "competition" is mainly a

20 concern of small scale farmers feeling that the

21 requirements for their production systems are

22 much higher.
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1 And then the competition is the

2 concern that those same standards aren't being

3 met by hydroponic operations. Whether we all

4 agree on that or not, my -- what I'm trying to do

5 here is just represent that perspective of where

6 they are coming from.

7 But all that being said, even though

8 my preference would be to see us focus on in

9 ground production, I'm being pragmatic that's not

10 going to happen. And I, you know, was looking

11 around the room throughout the past two days

12 thinking okay, that's obviously not going to

13 happen.

14 But what can we do? Like what can we

15 come to that we can agree on? Can the in ground

16 soil folks concede to containers? Can the 100

17 percent liquid feeding no soil folks agree to a

18 percentage of soil in containers and limit them

19 on liquid feeding?

20 And I see that is probably our best

21 and only possible way forward in terms of trying

22 to find something where we are all giving a
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1 little, we are all getting a little. Nobody is

2 going to be 100 percent happy, but I think our

3 work over the next several months is to try to

4 find that middle ground. Thanks.

5 DR. THICKE: Thank you, Emily. 

6 Ashley?

7 MS. SWAFFAR: So, Emily, I just want

8 to respond on moving forward this fall. I want

9 to say again and really stress that that line is

10 so blurred between hydroponics and containers and

11 I can't see myself really being able to vote on a

12 hydroponic proposal without a container proposal.

13 And, you know, we didn't see a

14 container discussion document this spring, so I 

15 just think we owe it to the stakeholders to come

16 out this fall with a container discussion

17 document. And another hydroponic discussion

18 document. And then, you know, vote in the

19 spring, because that line is so blurred.

20 I mean, to me, it means one thing and

21 to you, it probably means a totally different

22 thing. And, you know, I just want to caution us,
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1 let's not rush it, because we need to get these

2 definitions right.

3 And, you know, I think it could really

4 be a challenge if we don't bring them forward at

5 the same time together. Especially since we are

6 going to have some great compromises. You know,

7 we need to -- you know, for me to give up some

8 stuff, I need to feel like, honestly, containers

9 are safe. 

10 You know, I think that kind of this

11 give and take that if we move forward with that,

12 I need to feel like part -- you know, some of,

13 you know, mine -- what I believe in can still be

14 protected if we are giving out some things.

15 MS. OAKLEY: You know, I definitely

16 don't want it to be rushed, too. I guess I'm

17 just asking us to keep an open mind of optimism

18 that maybe we will just all work so hard this

19 summer that in that time we will be able to come

20 up with something that, you know, is agreed upon

21 and who knows what -- I mean, of course, the

22 stakeholder comments are going to be all over the
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1 Board, no matter what we do, but I just want us

2 to keep an open perspective that maybe we could

3 come up with something that we can agree on.

4 DR. THICKE: And keep in mind we did

5 have a discussion document on containers last

6 fall, which covered a lot of ground and we can --

7 we have already started working on that in our

8 Crops Committee.

9 Sue, you had your hand up?

10 MS. BAIRD: I want to bring to the

11 table that the system of aquaponics which they

12 feel, at least, the aquaponic producers don't

13 feel that they should be categorized as straight

14 hydroponics. They use very little inputs, very

15 little inputs, probably in most cases less than

16 in ground, in soil input people.

17 They would like to have a special

18 consideration as well, just bringing that to the

19 table.

20 DR. THICKE: Okay. Ashley, you wanted

21 to say something?

22 MS. SWAFFAR: Sorry, one more time. 
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1 You know, I think even though we have had these

2 discussion documents, where I -- why I feel like

3 we need that one more time is, you know, this

4 audience out here, the growers, the producers,

5 they are the ones that we rely on that feedback

6 that it's right.

7 And so if we bring a proposal forward

8 then we just pull it back, I mean, that's just

9 kind of -- I don't like that. But I do want to

10 say to the stakeholders and Francis touched on

11 this a little bit in his opening, you know, I was

12 a little disappointed in that the meat of what we

13 got, you know, answering those questions, you

14 know, we got an oh, I just don't like it or it

15 should be allowed.

16 That's great, but, you know, these

17 guys are working really hard on a discussion

18 document that is to get stakeholder input and

19 they pose those questions for a reason. And I

20 was looking for more answers to those questions.

21 DR. THICKE: Okay. I would like to

22 make a couple of points, too, if I can. And no
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1 reflection on you, Ashley. Sorry.

2 And one of them is about biological

3 activity. We hear a lot about that and I just

4 want to clarify that, you know, biologically if

5 we put in a labile substrate like hydrolyzed

6 soybean oil into water, we are going to get a

7 huge amount of biological activity. So that by

8 itself doesn't really define anything.

9 And secondly, biological diversity. 

10 I have been looking down -- trying to find out

11 how much diversity is in these bioponic systems. 

12 And there were some references given, but I

13 couldn't really find any data. Mostly I found

14 people quoting each other in a circle about there

15 is a lot of biological diversity. But I would be

16 interested in that information.

17 But I did see a paper that compared

18 the diversity, ecological diversity at soils

19 under organic and dimensional agriculture. And

20 they found that the organic soils had two and a

21 half times more biological diversity than the

22 conventional.
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1 And so I'm thinking that probably soil

2 versus in water. We are going to see a different

3 complexity in the system. 

4 And the other point I want to make is,

5 and I'm stepping out of the box here a little bit

6 as a soil scientist, and it reminds me when I was

7 -- I had been an organic farmer in the '70s and I

8 came back to graduate school in the '80s. And I

9 made the mistake of telling my professors I had

10 been an organic farmer.

11 And one of them asked me how far back

12 in the horse and buggy days are you going to go

13 here? 

14 But anyway, that was outside the box

15 then. Now, it is, you know, we have professors

16 doing research in organic and it's very credible.

17 But there are -- let's look ahead,

18 maybe look back. I have studied some ancient

19 cultures a little bit and if you look at, for

20 example, Chinese medicine, they talk about Chi

21 energy. And they talk about it coming from food. 

22 And this is really life force energy.
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1 In Japan it was Ki energy, like Reiki. 

2 In Ayurveda, it's prana, that life force that is

3 in food and they prescribe how to cook it, how to

4 grow it and how to prepare the soil in order to

5 get maximum prana or chi energy in the soil.

6 And in the -- back to the Chinese

7 system, they, for example, lay out that the earth

8 connects with the roots, the water, the stem and

9 leaves, the air, the flowers, the fire is in the

10 fruit and seed. And the fruit is made up of chi

11 from soil, sunlight and water.

12 So there is all these cultural things

13 and A-Dae mentioned too that there are cultural

14 things in Native American systems. There is

15 plant spirit medicine.

16 And like Lao Tzu is purported to have

17 said "The footstep of the farmer is the best

18 fertilizer." And when you think about that,

19 either he is full of manure and he spreads it on

20 the -- when he goes around or else there is that

21 relationship between the farmer and the soil and

22 the plant that is really key.
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1 And I think that Rudolf Steiner also

2 talked about that. He talked about -- became

3 biodynamics about how the plant is in the soil

4 and the clay function and the limestone and all

5 these soil functions and the cosmic energy and so

6 on, but that make that energy in the plant.

7 And even in western society, we had

8 this idea of vitality or vital energy and the

9 Greeks had that. Hippocrates, as Dan said, said

10 food is -- make food they medicine. But that

11 was, of course, when the reduction in science

12 came in, that was thrown out.

13 However, it is starting to reappear. 

14 Even back in the '70s, the book on the "Secret

15 Life of Plants" about how plants could actually

16 perceive what is going on around them and that

17 was totally discounted by the farmers, but now it

18 is coming back and new research shows that

19 actually plants can perceive light. They can

20 perceive smell, touch. They can know what color

21 your shirt is.

22 And so we are seeing that science is
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1 showing us more complexity than we thought. It's

2 not just about 16 to 18 essential elements and

3 how we get them in that plant. But there could

4 be more subtle things that we don't want to close

5 the door to. And so 10 years down the road we

6 don't want to -- as we get more information about

7 these things, we don't want to think oh, we

8 really kind of maybe made a wrong step.

9 Somebody told me two days ago that

10 there is now a radionics type of machine that

11 will measure vitality in food, that they are

12 taking to the grocery stores and so on.

13 So anyway, I just want to kind of open

14 it up a little bit to our thinking that it's not

15 just about how you get the elements into the

16 plant. It's more complex than that. Tom?

17 CHAIR CHAPMAN: I agree with most

18 things you said. And the only other point I

19 would like to point out is that, you know, in --

20 I saw less of this time, but definitely in the

21 fall we received a lot of comments about the long

22 history the hydroponic operations have in
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1 agriculture, including hanging gardens of

2 Babylon, operations in shallow lake beds by

3 Native Americans in Mexico. And like even in

4 aquaponic -- not aquaponic -- aquaculture --

5 aquaponic operations in China that incorporate

6 rice and fish.

7 So it does have a long, long history

8 as well dating back hundreds and thousands of

9 years.

10 DR. THICKE: Okay. Jesse? I'm not

11 sure who is next.

12 MR. BUIE: You know, I'm, kind of to

13 summarize all of this, encouraged by the attitude

14 that this Board has in approaching this issue. 

15 And I think that what we need to do first of all

16 is listen to what each other have said here as we

17 go forward.

18 And I want us -- we have done a lot of

19 talking, but it's time to try to figure out the

20 solution to this. And Ashley has said some

21 things that I hope that we will listen to in

22 order to make this thing move quicker, but I
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1 think like I said, I'm encouraged that we now

2 understand what the challenge is and we

3 understand what the impact is going to be when we

4 make a decision on the people and the industry.

5 So I think we are ready to move in the

6 right direction on this.

7 DR. THICKE: Steve? Harriet next.

8 MR. ELA: I would agree and I think

9 though we are going to run into the buzz saw

10 continuously. And, you know, Ashley asked for

11 clear definitions. And yes, we all want those. 

12 However, you know, we also provided what we

13 thought were clear definitions this meeting. And

14 you know, recalcitrant gets blown up and I don't

15 know that we are -- I think that is the -- I

16 don't think there is.

17 I think the definitions are trying to

18 set something in black and white in a continuum. 

19 And so, you know, while I think we to need

20 definitions, I think it is still going to be the

21 definition is never going to be black and white. 

22 It is going to be a continuum and we are going to
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1 have to agree that this is the definition.

2 So I am not sure it's going to provide

3 clarity. I think it may provide process. But I

4 guess I'm a pessimist on that side of things.

5 DR. THICKE: So we have a few minutes. 

6 I promised Tom we would get done by noon. 

7 Harriet, you had your hand up. And anybody else? 

8 And then Dan.

9 MS. BEHAR: Well, I think we need to

10 also remember that we are not in a vacuum here. 

11 That there are other countries around the world

12 that are dealing with this as well. We can look

13 at what they have defined it as, because they are

14 our trading partners. 

15 But I wanted to also say, too, that

16 when I was looking at all the public comments,

17 especially on the native ecosystems and I was

18 just kind of searching all the comments for the

19 word ecosystem, how often it came up in the

20 hydroponic comments as well.

21 So there is a lot of synergy. And as

22 we are talking, too, about the reliance on
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1 inputs, we are talking about marine algae and

2 sustainable harvest and really trying to find

3 systems that are self-reliant and are not -- you

4 know, so it's a much bigger picture and it's not

5 just hydroponic is separate, you know, or this

6 issue of containers. We need to look at it how

7 almost everything that we are looking at feeds

8 into this discussion as well.

9 DR. THICKE: Dan?

10 DR. SEITZ: This is a little off

11 topic, but I just want to say that I am deeply

12 heartened by what you might call the organic

13 holistic nature of this decision making process. 

14 And I feel that we, in the spirit of field trips,

15 might like to invite the Congress to come visit

16 us and watch a process like this at work.

17 Miles mentioned that he is under

18 pressure to -- with any new regulation, you have

19 to get rid of two old regulations and so much of

20 regulation making is a win/lose and sometimes a

21 lose/lose process. And sometimes we all benefit

22 actually by gridlock, because at least some bad
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1 things don't happen.

2 But I just want to say this I think is

3 a wonderful example of a truly positive approach

4 to what is typically in a political situation a

5 much more combative type of situation.

6 DR. THICKE: Remember, Dan, last fall

7 we Sunsetted 11 materials, so that means we can

8 make five and a half new regulations. Next?

9 MR. BRADMAN: I almost feel like we

10 should end there. But I just want to say

11 Harriet's comments just before I think really

12 resonate with me and that we need to look at

13 whole systems.

14 I know some of the issues that

15 resonate with me are around water use and

16 resource use. I have also -- you know, I have

17 met for example the owners and some of the top

18 growers in the Salinas Valley where we do a lot

19 of work, many of whom have both conventional and

20 organically certified products and these are big

21 producers.

22 These are, you know, it's a family
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1 farm, but it's a very big family operation with

2 thousands and thousands of acres. And you know

3 one thing they say, to put it bluntly, there is

4 not enough manure, to use a different term,

5 around to grow organic, at least the crops they

6 grow, vegetables, row crops, things like that.

7 And there is a case where they are

8 very dependent on outside inputs and, in fact,

9 the outside inputs aren't available to expand

10 growth, that there is a basic limitation there.

11 So this larger issue of ecosystem and

12 impacts and ecological services, I mean, in a

13 closed greenhouse, you are not going to find the

14 biodiversity that you are going to find in an

15 organic field.

16 At the same time, in an organic field,

17 that's a tremendous alteration from a natural

18 land use. And that dovetails with the native

19 use. Also for example, I see in the Salinas

20 Valley, you know, there has been a big effort to

21 reduce "trespass" of mammals or other animals

22 onto fields, because of concerns around food
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1 safety.

2 There has been a reduction in

3 vegetation along drainage ditches and things like

4 that. So there has been a real alteration that

5 is a food safety issue across agriculture, but it

6 is distressing to a lot of people we're certain

7 the ecosystem services.

8 Then my last thought I kind of hinted

9 at this earlier, this need for a broader

10 discussion and the concern about not getting deep

11 enough answers during this process. And really

12 three minutes, you know, even if it's sequential,

13 a few people on the same issue, is not enough to

14 go into real depth.

15 There is the written comments and I

16 can tell you I have read every comment related to

17 hydroponics and aeroponics. There is hundreds. 

18 I have read the Task Force report. I have it

19 right here. But I think it would be useful to

20 have -- you know, if there was a conference, I

21 mean, I would appreciate if the people from

22 Driscoll came up and gave a half hour
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1 presentation with a very clear description of

2 their procedures.

3 If the people from Wholesome Farms

4 have a very clear description, if people who are

5 dealing with constraints on soil-based systems

6 that we can kind of combine in a way of review of

7 the larger ecological and environmental issues

8 around with both systems, that might help us in

9 our thinking of defining what we might want to go

10 forward with.

11 And I understand there is time

12 constraints with that and expense, but I know

13 that would be helpful to me. I know there is a

14 lot of people here with a lot more history than I

15 do on this issue and I don't know if that would

16 feel redundant, but I sense that that would be

17 valuable based on our discussions and discussions

18 in the hall.

19 DR. THICKE: Thank you. We will have

20 Tom and then Joelle and then maybe then we have

21 to close it up. Tom, it's your decision.

22 CHAIR CHAPMAN: Yeah. I mean, I don't
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1 want to end this if people have more to say. We

2 can keep talking about it, but I guess my

3 statement here was a question to you and the

4 leaders on this proposal.

5 So far, you know, I think this

6 conversation has been great. It has laid out a

7 foundation and the multiple perspectives of the

8 different stakeholders. But my question I'm

9 going to pose to you guys is are you prepared? 

10 Do you have a -- what is -- where do we go from

11 here? What's the next step? And are you guys --

12 did we -- did this discussion provide that?

13 MS. OAKLEY: Yeah, I think this is

14 extremely helpful, because it allowed everybody

15 to kind of air their questions, kind of state

16 some of the positions they may have, the

17 confusion that they have, but it's very helpful

18 for us to know that we are dealing with a

19 diversity of use.

20 And I also think it is extremely

21 helpful for stakeholders to realize the extent of

22 the diversity on the Board because that is going
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1 to help, I hope, everyone stomachs whatever

2 compromise we come up with and realize if we all

3 stake lines in the sand, we are not going to go

4 anywhere.

5 So I think our progress forward is to

6 make amendments on the hydroponic proposal

7 section of the discussion document and delve

8 right into the container aspect. And I would

9 welcome any more detail that people want to

10 provide us on the open docket regarding

11 containers, regarding substrate materials,

12 regarding liquid inputs, because at the end of

13 the day, even though we don't want to be

14 reductionists, that's where a lot of the

15 philosophical conflict comes from.

16 So I think we need more information on

17 that and we will continue to work on that. Do

18 the other co-leads want to add something to that?

19 DR. THICKE: Joelle and then, Dave,

20 you had your hand up, too? Did you?

21 MR. MORTENSEN: No.

22 DR. THICKE: Oh, okay.
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1 MS. MOSSO: I'll be very brief. As we

2 owe kind of the community better definitions of

3 hydroponics and containers and all those things,

4 I would ask the public to be clearer in their

5 definitions. I think microbial activity is a

6 really poor definition. I think what we are

7 really trying to get at is microbial ecology.

8 Activity is just active. I think if

9 we could get clarity from the public when you use

10 those in talking about these systems, how we can

11 then use that to incorporate and define our

12 systems. So we owe you something, but I think we

13 need clarity from the community as well. It's

14 very vague to just say microbial activity.

15 DR. THICKE: Steve, did you have a

16 comment?

17 MR. ELA: Yes. And I would echo that. 

18 And I think -- I mean, I asked a couple of

19 questions yesterday. I think we know it's a

20 continuum and we know we are going to have to

21 draw a line somewhere in the gray area probably. 

22 And so, to me, the stakeholders need to give us
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1 some sense of what is acceptable and what is not. 

2 How far can we go? And what crosses the line?

3 And we know every stakeholder is going

4 to be a little bit different, but otherwise it is

5 going to come back to amateurs, you know, where

6 we are trying to figure something out where

7 people have experience. And I think, you know,

8 with actual details, this would work. It would

9 make me edgy, but this would work. It would be

10 very helpful.

11 MR. MORTENSEN: And I -- maybe just

12 quickly on the point that Steve is on right now

13 and I'll follow on on Joelle's point.

14 You know, it may seem like this is

15 nitpicking, but, you know, microbial ecology

16 versus activity that Joelle is raising, but the

17 literature on biodiversity is very clear. You

18 know, if there are breakdowns in biodiversity,

19 and functional groups of organisms, whole chains

20 of other organisms disappear from the system. 

21 They just aren't there.

22 So it may seem like a picky thing, but
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1 it's actually fundamentally important to

2 understanding, you know, is biodiversity high or

3 low in a system that is, you know, managed in

4 this way or that. And that's the sort of detail

5 I think we need to, you know, proceed forward and

6 make smart decisions about this on the kind of

7 ecology of the system side of things.

8 DR. THICKE: Harriet, can you make it

9 short?

10 MS. BEHAR: Yes, very short. So the

11 way I'm approaching this is looking at giving the

12 program, the tools -- I mean, it's -- when we

13 look at, you know, a definition that could

14 actually be put in regulatory language, a

15 standard for container growing that could

16 actually be put into the regulation. So of

17 course, I welcome all of you who are also kind of

18 a certification geek like me to also look at it

19 from that point of view, because we have to make

20 sure that it is practical and understandable and

21 verifiable.

22 DR. THICKE: This may be a good place
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1 to pause here. Tom?

2 CHAIR CHAPMAN: Yes. Do you want any

3 closing comments or do you -- okay. Emily, do

4 you want to?

5 MS. OAKLEY: Yes, I will just say I

6 want to thank everybody for a very positive and

7 friendly and forward moving conversation and I

8 have a lot of confidence that we will come to a

9 place that we can all meet in the middle as much

10 as possible and I hope that we can all agree on

11 something together as a Board. So thanks,

12 everybody, for your work on it and we appreciate

13 ongoing input.

14 CHAIR CHAPMAN: Thank you. And with

15 that, that concludes the Crops Section of the

16 agenda. Thank you everyone for that great amount

17 of dialogue that we look forward to taking it

18 forward from here or the Board taking it forward

19 from here.

20 And now I have to pull my agenda back

21 up. Up next, just so the public is aware, our

22 plan right now is to continue through the agenda
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1 and wrap up stuff prior to breaking for lunch, so

2 we may go longer than the, I think, scheduled

3 12:15 break. But then we won't be adjourning for

4 lunch. We will be adjourning permanently.

5 So up next is the Policy and

6 Development Subcommittee update with Dan. Sorry,

7 I didn't realize Dan was just coming back. Dan,

8 I put you on the spot. Do you want me to switch

9 to -- so we will give Dan a second to get

10 settled, if I can. And, Harriet, do you mind if

11 I move to you on materials?

12 MS. BEHAR: So the Materials

13 Subcommittee did not bring anything forward for

14 this meeting, but we are working on two items.

15 One is last fall we approved a

16 decision mechanism for reviewing and categorizing

17 excluded methods, because there is so much change

18 in that area and continuous addition of new

19 methods. And so we have a list of to be

20 determined that we are going to try to tackle. I

21 don't know if we will get them all determined or

22 not. There still may be some that are to be and
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1 some that are proposed to be put on the excluded

2 or not excluded methods list.

3 But there will be a -- there was a

4 group of people that CEAA worked with that met a

5 few times. We will continue with those people

6 and add some more. Dave has expressed a lot of

7 interest and I'm just thrilled to have his

8 expertise on this subject. And so we will be

9 continuing with that.

10 The second thing is Dan with my help

11 and also with Dave will be working on seed

12 purity, which is purity from the contamination of

13 GMOs. So we will be coming forward with a

14 discussion document on that.

15 And research priorities, which is

16 actually amongst all of the committees. We are

17 always looking at that.

18 CHAIR CHAPMAN: Thank you. Any

19 questions or discussion on the Materials

20 Subcommittee update? Thank you, Harriet. And we

21 will move back to the Policy and Development

22 Subcommittee update. Dan?
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1 DR. SEITZ: So I don't know if you

2 know this, but this is the most exciting

3 Subcommittee. So we are responsible for looking

4 at our Policies and Procedures Manual,

5 determining whether any revisions need to be made

6 to that.

7 A comprehensive revision of that was

8 made when the Subcommittee was chaired by Tom. 

9 Thank you, Tom. That was -- and others involved

10 with that, that was a major project. And based

11 on the revisions that the Committee made at that

12 time, an updated edition of the Policies and

13 Procedures Manual was adopted last year.

14 So at this point, there are not a lot

15 of questions or issues before the Committee. The

16 Committee has been looked -- has been asked to

17 look at how we might review ancillary substances

18 and to see if we can put some wording into the

19 Policies and Procedure Manual that would address

20 that procedure. So we will be looking at that

21 over the next few months.

22 And then a question did come up about
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1 our conflict of interest policy, the policy that

2 pertains to NOSB Members. There was a question

3 about whether a statement in that policy that

4 said you -- Board Members can't accept

5 compensation related to their Board duties would

6 apply to Members who actually do some work during

7 the regular business day when they are otherwise

8 gainfully employed by their regular employers.

9 And in talking with the NOP staff,

10 they made it clear that if you happen to do work

11 during the regular work day when you are paid by

12 your regular employer, that would not constitute

13 a conflict of interest. And we may put a little

14 wording to that effect in the Policies and

15 Procedures Manual, but that is not a super

16 pressing matter.

17 So that's all I have to report.

18 CHAIR CHAPMAN: Thank you, Dan. Any

19 questions for Dan on the Policy and Development

20 Subcommittee update? No slides, Dan? Not one,

21 not two, not 83 slides.

22 DR. SEITZ: No.
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1 CHAIR CHAPMAN: Sorry. Emily?

2 MS. OAKLEY: So if you guys propose

3 some wording changes, will that come out first

4 for stakeholder comment? What's that process

5 like?

6 DR. SEITZ: Tom, that's my

7 understanding that when we make changes, they go

8 out for stakeholder comment. Is that always

9 true?

10 CHAIR CHAPMAN: So changes to the PPM

11 would need to be voted on by the Board, so the

12 Policy Subcommittee would make a proposal and it

13 would get published with the other proposals. 

14 The way that style of proposal is handled is

15 under the Subcommittee, so it doesn't always have

16 the same level of greater background research, I

17 would say like the normal proposals we see have. 

18 But it's open for the public comment and then we

19 would vote on it at the Board meeting.

20 Any other questions? All right. 

21 Thank you, Dan.

22 Up next on the agenda is Deferred
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1 Proposals and Final Votes. And we do have

2 something to bring up in this section.

3 During my introductory comments, we

4 mentioned the Final Rule that we are waiting for

5 implementation upon the Organic Livestock and

6 Poultry Practices Rule OLPP, for short.

7 And in my comments, we are -- you

8 know, I was spontaneously interrupted by Ashley

9 and Harriet to also speak their mind on support

10 for this item. And so I think it is proper for

11 the Board, at this time, to consider a resolution

12 supporting the implementation without delay of

13 the Organic Livestock and Poultry Practices as an

14 Advisory Board to the USDA.

15 We do sit here representing the

16 diverse interests of the community from consumer

17 groups to retailers to industry to farmers,

18 ranchers, handlers, everyone like that. I think

19 it is important for incoming Administration and

20 the new Secretary once appointed to know where we

21 stand on this issue.

22 And so I'm proposing that what is
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1 being projected right now is a resolution that

2 the Board considers to pass at this meeting. And

3 I'll read it very briefly.

4 "The National Organic Standards Board

5 recognizes that consumers trust in the organic

6 label and industry growth depends on the strength

7 and consistent application of organic

8 regulations.

9 The National Organic Standards Board

10 has an integral role advising the USDA in the

11 promulgation of these volunteer standards and

12 strives to seek consensus amongst organic

13 stakeholders in its recommendations to the USDA

14 and the Secretary.

15 The recently finalized Organic

16 Livestock and Poultry Practices Rule was based on

17 a unanimous NOSB recommendation to the USDA in

18 2011.

19 The NOSB recommendation was a product

20 of a decade of public NOSB meetings, lengthy

21 discussions, public comment periods and

22 consultation from organic producers, processors,
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1 consumers and the veterinary and scientific

2 community.

3 According to a survey by the Organic

4 Egg Farmers of America from 2014, the majority of

5 egg producers representing the majority of

6 organic egg production already adhere to the

7 practices and standards set forth in the rule.

8 A recent consumer report survey found

9 that 83 percent of consumers who frequently

10 purchase organic products believe that organic

11 eggs should come from hens that have access to

12 the outdoors.

13 Additionally, the USDA APHIS has found

14 no significant differences in mortality rates

15 between organic and conventional laying hen

16 operations.

17 Support of this rule has been

18 expressed through public comment by major and

19 growing organic brands. The rule is supported by

20 organic producers, consumers and industry, as

21 well as, the NOSB.

22 The NOSB stands ready to answer any
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1 additional questions the Secretary may have on

2 the Organic Livestock and Poultry Practices

3 Rule."

4 Michelle, can you advance?

5 "Therefore, be it resolved by

6 unanimous vote, the National Organic Standards

7 Board, as the USDA's Federal Advisory Board on

8 organic issues and representing organic farmers,

9 ranchers, processors, retailers and consumers

10 urges the Secretary to allow the Organic

11 Livestock and Poultry Practices Rule to become

12 effective on May 19, 2017 without further delay."

13 I now open it up for discussion.

14 MS. SWAFFAR: So I said my main point

15 of this the other day, but I just want to stress

16 how important this rule is to become implemented. 

17 And I think that our Board having this

18 resolution, you know, shows the Secretary that we

19 are unanimous in this also just like the Board

20 was when they passed the Animal Welfare

21 recommendations back in the middle of 2011.

22 Yeah, that was just -- you know, this
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1 is really important to me. I spent a ton of my

2 time prior to getting on this Board actually

3 standing at that podium commenting on this

4 proposed welfare recommendations coming out of

5 the Livestock Committee.

6 So I'm very passionate about this. 

7 And this is very important. And like I said the

8 other day, you know, I'm on egg farms every

9 single week doing inspections. And this is all I

10 hear about. Is this in the finding? 

11 So a little different topic for that

12 one, but, you know, farmers really feel like this

13 is important to them to see this implemented and

14 not delayed any further.

15 CHAIR CHAPMAN: Okay. Harriet?

16 MS. BEHAR: I think we need to

17 recognize, too, that organic is unique in that we

18 tend to want strict regulations and we also want

19 to protect our brand. And that right now, there

20 are many producers that have to have more than

21 one certification in order to show that they meet

22 standards such as this. And that was one of the
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1 reasons why we wanted this was to provide that

2 full -- the full range of what consumers expect

3 that brand to mean to be in our regulation.

4 And as Ashley said, the producers want

5 this. And the consumers want this. And the

6 environmentalists want this. And the scientists

7 want this. The full range of stakeholders want

8 this. And those who don't want it, don't have to

9 carry the organic label. It's all voluntary.

10 MS. SWAFFAR: Don't talk me out of a

11 job, Harriet.

12 CHAIR CHAPMAN: Emily?

13 MS. OAKLEY: I just want to say that

14 what is wonderful about organics is that it

15 crosses the political divide and I'm an organic

16 farmer in Oklahoma. And we have organic farmers

17 who are republicans and democrats and

18 libertarians and otherwise.

19 And so too do our consumers reflect

20 that diversity. So I hope that Congress and the

21 Secretary will recognize that this is not a

22 political issue. This is simply a consumer and
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1 farmer issue.

2 CHAIR CHAPMAN: Any other discussion? 

3 MS. SWAFFAR: Mr. Chair, I would like

4 to move that -- this forward or make a motion for

5 that.

6 MS. BEHAR: I'll second.

7 MS. SWAFFAR: Unanimous resolution,

8 sorry.

9 CHAIR CHAPMAN: So I have a motion to

10 adopt this resolution as written and a second

11 from Harriet. A motion by Ashley. Any further

12 discussion on this? Otherwise, we will proceed

13 to a vote starting with Sue. A yes vote on this

14 is to approve the resolution.

15 MS. BAIRD: Yes.

16 MS. BEHAR: Enthusiastic yes.

17 MS. OAKLEY: Yes.

18 DR. THICKE: Yes.

19 MS. ROMERO-BRIONES: Yes.

20 MS. De LIMA: Yes.

21 MR. BRADMAN: Yes.

22 MS. MOSSO: Yes.
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1 MR. ELA: Yes.

2 MR. MORTENSEN: Yes.

3 MR. BUIE: Yes.

4 MS. SWAFFAR: And another enthusiastic

5 yes.

6 DR. SEITZ: Yes.

7 MR. RICE: Yes.

8 CHAIR CHAPMAN: The Chair votes yes. 

9 15 votes, the Board passes this resolution

10 unanimously. And we will be working with the

11 program to communicate this to the Secretary.

12 I'm sorry, I have to flip back to my

13 agenda, which next up on our agenda is review of

14 the Subcommittee Work Agendas. And if Michelle

15 could pop that open, we will quickly run through

16 these with each Subcommittee Chair reviewing

17 their section.

18 First up is Scott with CACS.

19 MR. RICE: Thanks, Tom. We have the

20 Eliminating the Incentive to Convert Native

21 Ecosystems into Organic Crop Production proposal

22 that we referred back to Subcommittee and look
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1 forward to having something in the fall.

2 We have the in-field annual

3 evaluations of inspector's update. Again, a

4 proposal that was referred back and look to more

5 information and work on that for the fall.

6 CHAIR CHAPMAN: Okay. Thank you. 

7 Francis?

8 DR. THICKE: I can't see far enough to

9 see over there. Fatty alcohols. We have just

10 gotten a revision of the petition from the

11 petitioner, so we will be working on that.

12 Anaerobic digest, we have just gone

13 back to the TR writers to get a little more

14 information on. And both of those are set for

15 fall, as most of these things are.

16 Polyaxon D zinc salt. That one is --

17 it's for control of fungal diseases in organic

18 crops and that one will -- we are also heading

19 for fall with.

20 Allyl isothiocyanate, that's for a

21 soil-applied nematocide and also for a soil22 applied fungicide. So these are all going to
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1 come for the fall.

2 Sodium citrate, an allowed synthetic. 

3 It is being petitioned as an allowed -- no, I'm

4 sorry, that's different. This was synthetic for

5 an anti-coagulant for processing bovine blood

6 after slaughter to maintain the blood as a liquid

7 for processing into organic fertilizer.

8 And natamycin is petitioned as a non9 synthetic to be used as a fungi -- in mushroom

10 production and to control fungal diseases on

11 fruit.

12 So these are all scheduled for fall.

13 Contamination issues in farm inputs,

14 that's kind of languishing, but it's -- it might

15 move forward by fall in maybe a discussion

16 document.

17 Anaerobic digest, well, we have

18 covered before. That's -- we have kind of taken

19 a broader reproach to anaerobic digest because

20 there are -- there have been more than one

21 petitions for anaerobic digest. So the TR we got

22 was broader in scope, so we can use that for
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1 future reference.

2 Biodegradable biobased mulch. We may

3 have a discussion document for fall. We are

4 still talking about that.

5 Inerts, this is on hold. NPEs and

6 inerts, annotation change, that one is kind of on

7 hold.

8 Newspaper annotation change. We got

9 a TR on that and it wasn't very conclusive, so we

10 are still discussing what to do with that and

11 whether we need a discussion document or not.

12 And hydroponics and container, our

13 hope is to have a proposal for fall.

14 Strengthening and clarifying the seed

15 requirements. Again, we took that back. We are

16 going to have that for fall.

17 Marine materials. We will look at

18 that and see if we decide we want to bring it

19 forward again as a proposal in the fall.

20 The Sunsets, I guess. Okay. The

21 Sunsets, we will, of course, have in the second

22 step of the Sunset review this fall for all of
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1 those.

2 Is that all that's on the list,

3 Michelle? Yes, I think that's coming. All

4 right. There are some more down below. That's

5 it. Okay.

6 CHAIR CHAPMAN: Thank you. Up next

7 handling, Lisa.

8 MS. De LIMA: All right. So for

9 petitions, for SDBS, we are still waiting for a

10 TR. So whether we bring a proposal forward in

11 the fall or not is uncertain at this point.

12 Sodium chlorite, we need to discuss as

13 a Subcommittee. We had some questions for the

14 petitioner that we put forward to them and they

15 did submit some answers via the public docket,

16 but we haven't had a chance to discuss yet as a

17 group.

18 We have -- the rest of the petitions

19 there, we do have leads on and are moving forward

20 with: Silver dihydrogen citrate, Japanese

21 pepper, Ethiopian pepper.

22 The tamarind seed gum, we sent
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1 additional questions back to the petitioner, so

2 that's likely to be a spring item, not this fall.

3 And then other projects: BPA, again

4 waiting for the TR as we sent that back. Most

5 likely a discussion document, again, in the fall,

6 but we will have to discuss together as a

7 Subcommittee.

8 Tocopherols, again, lots of good

9 public comment. So not sure where we are going

10 to go with that yet.

11 On hold is the nutrient, vitamin and

12 mineral annotation change.

13 And then marine materials, again, we

14 will be working alongside with crops in figuring

15 out what the next steps are, to be determined.

16 And the same goes for ancillary

17 substances, hopefully bringing up a proposal back

18 in the fall, but again, we need to discuss as a

19 Subcommittee.

20 And then the magnesium chloride,

21 probably a proposal in the fall.

22 And then we have got all the Sunsets,
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1 which I am not going to read through. And that's

2 it.

3 CHAIR CHAPMAN: Thank you. Up next is

4 livestock, Ashley?

5 MS. SWAFFAR: So we have had several

6 petitions, one for sulfur that we will plan to

7 bring forward in the fall. We just got our TR

8 back.

9 Glycolic acid, waiting on a TR.

10 Hypochlorous acid, waiting on a T --

11 a limited scope TR, so those may or may not come

12 out in the fall, depending on when we get that

13 back.

14 Thymol, just received that one. We

15 had some more questions for the petitioners, so

16 not sure if we will crank that out for fall, but

17 we don't have just a time of stuff happening, so

18 we might.

19 All the aquaculture stuff is currently

20 on hold.

21 And we are working on our Sunset 2019

22 materials.
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1 Other projects defining emergency

2 treatment for parasiticides. Do look for a

3 proposal in the fall of 2017 for that. And that

4 one is still there. 

5 The Organic Poultry Task Force, that

6 is set on hold until OLPP Rule is -- that says

7 published. So maybe that should say final. But

8 that is -- what that was, if anybody forgot about

9 that, is we had looked at different ways on

10 methionine alternatives, different stuff like

11 that. It was a proposal right after I got on the

12 Board.

13 So, Tom, are you itching to say

14 something?

15 CHAIR CHAPMAN: So the OLPP Rule is

16 published and final. It's just not effective.

17 MS. SWAFFAR: Well, not effective,

18 yes. And that is kind of it for livestock as far

19 as things that are approved.

20 We are -- I will mention that, you

21 know, at some point we will be adding quite a bit

22 of stuff to our work planner requesting that we
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1 add once OLPP is enforced, the data is final.

2 There are several things that the

3 Department called out that our Subcommittee will

4 need to do more work on, so we are ready and

5 willing to start on that and maybe a few other

6 poultry items.

7 CHAIR CHAPMAN: Thank you. Up next is

8 materials, Harriet?

9 MS. BEHAR: So I did talk about this

10 earlier, so we are going to keep looking at

11 research priorities. We look at the tracking of

12 petitions and TRs and are going to make sure that

13 things are moving along and work with all the

14 Committees on that.

15 We will probably have a discussion

16 document for seed purity from GMOs in the fall. 

17 And we will, I'm pretty sure, at least be able to

18 deal with maybe half. I'm not sure how many we

19 will end up with in the excluded methods

20 terminology to have a proposal there to see if we

21 would add a few more of those methods to our

22 excluded list.
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1 CHAIR CHAPMAN: Thank you. Policy,

2 Dan?

3 DR. SEITZ: As mentioned a few minutes

4 ago, our work is just to make ongoing revisions

5 to the policy manual as needed.

6 CHAIR CHAPMAN: All right. I think

7 that concludes the work agendas.

8 All right. So that takes us to --

9 since we dealt with presentation certificates

10 last meeting, other business and closing remarks. 

11 I have a couple comments that I'll say in a

12 second.

13 And for those folks interested in the

14 work agenda, what we just reviewed, it will be

15 posted on the meeting page after the meeting.

16 So in closing, I want to thank the

17 public for their written and oral comment. I

18 think we had a great interaction between the

19 Board and the public at the webinar and at this

20 meeting, even more so than we normally do. And I

21 think that level of interaction is invaluable.

22 And then again I'm impressed with all
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1 my fellow Board Members, especially the new

2 Members in their interaction and engagement with

3 the issues before the organic community.

4 I mentioned earlier about the time

5 spent unpaid away from colleagues, students, your

6 own farms and operations, your businesses and

7 most importantly your family. And I'm just

8 personally inspired by how some Members, you

9 know, through pressing family issues or physical

10 or medical issues that may occur, still, you

11 know, are so dedicated that they still show up

12 and come here.

13 And I really draw inspiration from

14 that. So thank you guys. But with that, I think

15 we are concluded. 

16 Yes, and at this point, I will pass

17 the meeting back to Paul Lewis to adjourn the

18 meeting.

19 DR. LEWIS: Thank you, Tom. I just

20 want to echo some of the remarks that Tom just

21 made. 

22 CHAIR CHAPMAN: Sorry, Paul, my
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1 apologies. I wanted to mention the next meeting

2 as well. So our next meeting will be in

3 Jacksonville, Florida in the fall in October, the

4 end of October. It's a three day meeting and as

5 you can tell from the work agenda, we have a lot

6 of issues. We will be scheduling two webinars,

7 one on October 24th and another one on October

8 27th. They will be handled in overflow fashion,

9 so we will fill up the 24th and if we still have

10 additional commenters, then we will add the 27th.

11 If we don't have enough commenters,

12 then we will just have the 24th.

13 At the in-person meeting as well, so

14 in total we will have just under 12 hours of

15 public comments, similar to this one at the in16 person meeting, though it will only -- public

17 comment will only be heard on that first day,

18 since we will have a lot of issues to vote on. 

19 We will need to save more time for that

20 deliberation and voting.

21 In total though, we will have enough

22 time. It's similar to this time. I had enough
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1 time scheduled for about 140 public commenters as

2 well as question time and discussion by the Board

3 with those public commenters.

4 So look for those notices to come out

5 as they do and we plan to have the open docket on

6 this as well, so published as shortly as

7 possible. I apologize for the interruption,

8 Paul, and I hand it back to you to adjourn the

9 meeting.

10 DR. LEWIS: Thank you, Tom. I just

11 want to echo in terms of what Tom shared. I want

12 to thank Board Members, especially new Board

13 Members for all your work getting ready for this

14 first meeting. I know it was a lot to come up to

15 speed and I applaud you in terms of really doing

16 a great job.

17 And also overall for the Board for

18 your thoughtful dialogue, insight and really

19 helping us in terms of as a program to do our

20 work in filling our mission.

21 Appreciate the stakeholders,

22 especially the very thoughtful comments and
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1 perspectives that you shared. I always find it

2 very insightful in terms of information that is

3 shared for the Board and for the program to help

4 the Board do their work.

5 And finally, I want to thank my USDA

6 colleagues for tirelessly all their work that

7 they have done for preparing for this meeting and

8 making this a success. Yes?

9 MS. BEHAR: Before you close, I have

10 a short poem that I would like to read. Is that

11 okay with everyone? Okay. This is something

12 that Dave Engel wrote and I just thought it would

13 be fitting, since his recent passing, to read it. 

14 I'm not going to sing it. It was a song that he

15 did sing, but it is, I think, his -- I think it

16 was 19 -- no, 2002 when he sang it to the NOSB.

17 "But if for just one time we would

18 farm this land organic, and see the hand of

19 Howard reaching for the horizon, it would be so

20 fine. There would not be all this panic and

21 sweat and mud and tears and blood. This truth,

22 we set our eyes on.
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1 For 50 years, the chemicals and sprays

2 have harmed the planet. For 50 years we have

3 taken Mother Nature for granted. Now, the time

4 has come to be more humble and wise, lest one day

5 we awaken to a rather rude surprise.

6 Leopold and Carson both wrote and

7 warned about stuff like this, that the web of

8 life and a silent spring simply cannot coexist. 

9 And still we are so dang wrapped up in our

10 technology and greed, we think we are cool, but

11 we are fools to play with God's seed.

12 This truth we set our eyes on. And so

13 many of us now around the world are trying hard

14 to find in tune with Mother Nature, we are trying

15 not to harm.

16 The life in the soil and in the water

17 and in the air, we are learning things, lots of

18 new things and what we are learning we share.

19 We can choose to buy our food from

20 those whose farms are near and if that food is

21 organic, then how wonderful, how great. But if

22 we wait for all those who eat to come to care,
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1 then it would be too late.

2 And so it is our time will come, our

3 time will come just so for each of us one-by-one. 

4 Our time will come to go. And when we meet Saint

5 Pete, he will ring the bell and he will say dear

6 friend, you farmed organic, you did very well.

7 Let us pray that more folks will take

8 and farm their land organic and see the hand of

9 Howard reaching for the horizon, then it will be

10 so fine. There will not be all this panic in

11 sweat and mud and tears and blood. This truth we

12 set our eyes on."

13 DR. LEWIS: Thank you, Harriet, for

14 sharing that. Appreciate it. Just a few more

15 closing remarks. In the theme of having an open

16 docket for working on publishing the Federal

17 Register Notice announcing our next meeting,

18 which will be occurring October 31st to November

19 2nd.

20 And in that Federal Register Notice it

21 provides the opportunity for the public to

22 provide comments for the Board for the
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1 deliberation of that meeting.

2 And finally, we will be working on

3 publishing a Federal Register Notice for the

4 upcoming seat for Francis, I want to thank

5 Francis again for your service, working on that

6 filling the seat for an environmentalist resource

7 conservationist.

8 So look for both the Federal Register

9 Notice for that and upcoming real soon the

10 Federal Register notice announcing our meeting

11 for the fall.

12 And with that, I would like to adjourn

13 the meeting and again thank, especially all the

14 Board Members for all your thoughtful insight and

15 perspectives.

16 This meeting is now adjourned.

17 (Applause.)

18 (Whereupon, the above-entitled matter

19 was concluded at 12:37 p.m.)

20 

21

22
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A

A-Dae 1:17 108:17

113:8 122:12 127:3

130:21 162:13

A-Dae's 127:2 135:20

a.m 1:9 4:2 72:7,8

ability 99:11

able 16:22 18:9 22:11

44:20 46:9 66:15 76:9

85:1,10 98:12 119:13

119:14 123:1 148:18

156:11 157:19 199:17

above-entitled 72:6

207:18

absolutely 150:6

acaricides 19:15

accelerated 4:13

accept 182:4

acceptable 176:1

accepted 153:8

accepting 153:10

access 31:17 90:16

106:5,10,11 108:9

110:12 186:11

Accessibility 130:22

accompanied 43:19

account 99:7

accumulates 55:5

accumulation 26:16,20

42:7

accurate 116:22

acid 3:6,8 8:8 10:17

14:2 19:12,16 20:1,21

21:22 32:12 34:4

37:20 39:7 40:4 197:9

197:10

acids 11:7 30:12,15

31:6,9 32:5,11 33:13

35:3 37:13,17

acknowledged 62:11

acknowledging 62:12

63:22

acre 45:7,9,11

acres 170:2

act 5:8 128:11

action 73:17

actions 37:21

active 175:8

activities 84:19

activity 50:15 84:16

85:11 94:19 95:5

160:3,7 175:5,8,14

176:16

actual 75:21 76:3 176:8

actually-- 18:18

acute 5:22 20:22

adamantly 79:11

adapted 58:9

add 29:13 36:11 39:15

50:17 51:19 79:6 98:2

135:22 143:19 174:18

180:6 199:1,21

202:10

added 48:17 80:17,21

81:13

adding 96:5 198:21

addition 28:17 36:2,13

114:13 179:18

additional 31:15 187:1

196:1 202:10

Additionally 186:13

address 14:21 22:8

62:9 67:15 68:10 90:7

181:19

addressing 43:3,7

adequate 43:21

adequately 68:6

adhere 186:6

adjourn 3:22 201:17

203:8 207:12

adjourned 207:16

adjourning 179:3,4

Administration 47:2

184:19

Administrator 2:17

administrators 124:8

adopt 190:10

adopted 181:13

advance 187:4

adverse 90:15

advising 185:10

Advisory 2:11 184:14

187:7

aeroponic 73:7 74:7

83:19

aeroponics 73:15 88:1

171:17

Aeroponics/Hydropo...

3:14

Aeroponics/Hydropo...

72:13

affect 140:13,15,17,20

150:4

afford 110:18,19 119:9

119:12

afraid 111:12

ag 56:10

age 13:6 128:17

agencies 56:8

agenda 39:15 55:15

64:8 72:5,12 178:16

178:20,22 183:22

191:13,13 200:14

202:5

agendas 3:19 191:14

200:7

ago 23:11 63:19 164:9

200:4

agree 35:17 37:7 44:4

71:21 88:8,15 91:4

99:20 127:2,12

144:20 151:11 152:4

155:4,15,17 158:3

164:17 166:8 167:1

178:10

agreed 157:20

agreement 148:22

agrees 144:19,21

agricultural 110:6

115:12 145:3

agriculturalists 109:7

agriculture 1:1 62:4

90:19 98:10 117:20

131:7,7 137:13,19

160:19 165:1 171:5

agroecologist 125:22

ahead 59:20 68:13,13

82:20 86:16 142:9

146:11 161:17

aimed 29:8

air 64:20 162:9 173:15

205:17

alcohols 192:9

alfalfa 62:5

algae 3:14 65:9 66:13

68:10 70:13 168:1

algicide 4:22

align 91:21,22

aligned 134:7

alkali 30:16 32:15 35:6

40:3

alkaline 32:8

allow 41:4 48:4,15

51:21 77:18,20,22

78:12 90:11 104:2

129:7,21 154:15

187:10

allowance 44:15 63:13

allowed 4:20 14:15 28:1

40:15 42:10 49:19

50:9 54:1 56:19 75:15

75:16 76:1,2 78:11

79:6 123:4 143:3

159:15 173:14 193:2

193:3

allowing 49:4 153:21

allows 46:6 77:17 78:11

92:2

Allyl 192:20

almonds 114:11

alongside 196:14

alter 130:6

alteration 170:17 171:4

alternate 131:16,20

alternative 20:21 29:1

alternatives 6:13 8:7,11

8:21 28:3 29:4,16

198:10

amateurs 176:5

amendments 30:15

52:8 174:6

America 186:4

American 162:14

Americans 165:3

ammonia 11:6

ammonium 10:19 11:4

11:6 32:10

amount 43:13 44:13

53:10 92:21 148:22

160:7 178:16

AMS 2:17

anaerobic 192:12

193:17,19,21

analysis 86:8 110:4

Anasazi 109:8

ancestral 110:15

ancient 161:18

ancillary 181:17 196:16

anecdotally 7:2 149:12

Animal 187:20

animals 24:8 170:21

annotation 13:10 16:13

19:3 20:11 21:12,19

22:3 24:6,10 27:21

28:18 32:13 34:3 39:1

39:2,9,18 41:1 42:22

46:15 47:7 194:6,8

196:12

annotations 34:17

announcing 206:17

207:10

annual 192:2

answer 18:9 25:2

122:19,20 142:1

150:21 186:22

answering 159:13

answers 126:20 159:20

171:11 195:15

ant 22:10

anti-coagulant 193:5

antibiotics 27:9

ants 20:2

anxiety 87:10

anybody 6:20 22:20

38:15 55:10 60:1

107:8 109:1 167:7

198:8

anymore 108:1 119:9

anyway 42:18 161:14

164:13

APHIS 186:13

apologies 202:1
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apologize 203:7

apparently 79:3

applaud 120:9 203:15

Applause 207:17

applicable 10:7

application 185:7

applications 26:4 52:20

153:2

applied 5:6 28:5 41:13

104:19 152:3,7

192:22

apply 28:9 42:10 44:20

146:21 147:1 182:6

appointed 184:20

appreciate 89:4 94:4

102:19 112:22 113:16

121:8,8 123:6 171:21

178:12 203:21 206:14

appreciated 93:20

appreciative 132:14

apprenticing 121:7

approach 27:6 44:1

86:14 121:12 145:14

169:3

approaches 91:22

approaching 165:14

177:11

approval 39:10

approve 190:14

approved 14:13 27:2

179:15 198:19

APRIL 1:7

aquaculture 165:4

197:19

aquaponic 73:7 74:7

134:1 158:12 165:4,4

165:5

aquaponics 3:15 73:15

120:5 122:14 127:15

158:11

aquatic 52:14

aqueous 11:6

area 43:6 145:11

175:21 179:18

area/region-specific

46:7

areas 23:6,21 25:6

105:3 106:7 143:15

154:5

argue 78:16

arguing 77:21

argument 78:20

arguments 84:3 93:17

94:19 115:2,18

Arkansas 106:17 119:4

arrive 92:20

ARSENAULT 2:11

arthropods 95:14

as-- 97:22

as-needed 153:5

Asa 1:13 21:8 22:2,5

31:1 37:15 38:18

51:16 127:18 133:8

150:3

ash 85:2

Ashley 1:19 8:2 102:10

108:16 113:12 114:2

156:6 158:20 160:1

165:20 166:10 184:8

189:4 190:11 197:4

Ashley's 127:12 148:16

152:4

asked 13:10 17:17,18

24:5 51:18 53:8 68:7

107:10 117:19 137:6

161:11 166:10 175:18

181:16

asking 51:22 124:19

125:1,8,9,14,18,19

147:8,10 157:17

aspect 121:9 174:8

aspects 145:22

assessing 126:4

assigned 5:18

associated 53:7

Association 42:5 79:12

assume 24:15

assuming 50:13

assumption 82:8 83:21

assumptions 83:18

assurance 59:7

astronomical 110:17

atmosphere 87:6,16

atoms 10:18

attention 95:19

attitude 165:13

attorney 110:6

audience 109:2 123:13

159:4

authorizing 25:10

availability 8:10,17

23:14 31:19 57:21

63:11 107:6 140:18

available 8:14 32:5 49:2

52:19 56:14,15 70:1

170:9

avid 151:19

avoids 24:4

awaken 205:5

aware 87:14 178:21

awesome 106:16

Ayurveda 162:2

B

b 10:5 14:5 40:20

B1 3:11 52:4,9,16,21

53:3,7,16 54:2,7

baby 111:14,14

Babylon 165:2

back 4:4,5 13:17 34:7

35:1 37:7 38:11 44:11

48:13 59:12,22 60:8

60:13 61:8 66:15 68:7

70:7,13,15 71:11,18

72:3,10,10 74:4 95:10

101:16 109:8 110:12

117:16,22 118:11,16

120:8,10 122:22

126:13 133:2,3 135:9

137:16,18 138:6,12

138:16 139:9,11

141:12 143:6 149:2

151:14 159:8 161:8

161:11,18 162:6

163:14,18 165:8

176:5 178:20 179:7

180:21 187:21 191:12

191:22 192:4,13

194:15 196:1,4,17

197:8,13 201:17

203:8

background 66:1,16

183:16

bacteria 95:13

bacterial 29:19

bad 95:8 101:18 168:22

badgers 138:12

bags 126:18

BAIRD 1:12 9:18,22

10:12,14 12:15 13:19

13:22 22:14 37:3

60:16 70:18 117:14

158:10 190:15

bait 20:12 21:1,7

Ballroom 1:8

ban 73:14

barriers 10:6 23:13

base 7:16 100:18

based 6:20 11:22 12:2

25:19 44:16 46:21

59:12 74:18 90:13

91:1 121:18 142:17

143:6 153:6 172:17

181:10 185:16

bases 110:15

basic 151:12 153:20

170:10

basically 33:13 36:21

55:4,10 65:4 85:17

136:13

basis 111:8 122:5

152:12 153:6

bath 111:14,15

bathed 82:2

bear 61:18

becoming 128:18 139:5

beds 129:3 165:2

bees 62:6

beginning 115:11

150:17

begins 40:20

BEHAR 1:13 14:12 15:9

15:14,16,19,22 19:21

21:10,16 28:22 38:3

40:19 46:13 47:4,22

48:12 50:11,16,19,22

51:5,14,18 55:19

57:13 59:13,21 60:17

62:16 63:2 64:11 65:3

70:6,19 73:2 136:12

143:11 167:9 177:10

179:12 188:16 190:6

190:16 199:9 204:9

belief 92:19

believe 4:11 9:16 19:19

48:12 86:2,22 92:14

94:8,13 97:19 98:8,22

100:20 111:10 137:5

157:13 186:10

bell 206:5

belong 69:21

benefit 91:6 168:21

benefits 114:6 139:17

benign 6:4

best 39:18 92:3 94:8,12

97:12 103:3,9 117:8

128:7 152:21 155:20

162:17

beta 86:7

better 34:5 107:2 129:6

131:14 134:3 175:2

beyond 43:17 87:15

93:11 95:5 115:2

137:12

biases 109:18 110:7

big 85:22 91:12 106:12

128:20 147:3 151:15

169:20 170:1,20

bigger 168:4

biggest 27:13

biobased 3:6 14:3,6,13

14:18 15:1,2,8,11,13

16:1,21 18:1 194:2

biochar 37:17

biocontrol 25:22

biocontrols 29:14

biodegradable 3:6 14:2

14:6,12,22 15:2,5

16:21 18:6,17 194:2

biodegrade 18:22

biodigestion 37:17

biodiversity 98:6
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137:18 146:4 170:14

176:17,18 177:2

biodynamics 163:3

biological 83:7 94:19

95:5 160:2,7,9,15,21

biologically 160:4

biology 36:14 95:6,8,8

95:20

bioponic 114:5 116:7

150:8 160:11

bioproducts 29:7

birds 138:20

bit 8:4 18:11,12 20:8

21:15 37:11 44:12

56:18 59:9 65:22

66:16 88:4 103:12

114:21 159:11 161:5

161:19 164:14 176:4

198:21

bituminous 31:12

black 166:18,21

blah 62:11,11,11

blame 64:14

bleach 8:16 45:18

bleach-related 7:6

blended 53:14,15

blight 27:8 29:7,12,18

Block's 127:4

Blom 80:11

blood 193:5,6 204:21

206:11

blown 166:14

bluntly 170:3

blurred 104:7 156:10

156:19

board 1:3,8 2:11 19:11

20:20 40:22 47:2

72:19 73:6,7 84:11

85:5,21 87:20,22 91:8

93:10,13,16 99:3

102:16 104:8 105:2

105:18 109:1 112:9

112:20 117:8,15

120:17 123:12,21

130:22 132:15 134:20

135:10 142:15 147:1

147:5 149:22 151:21

158:1 165:14 173:22

178:11,18 182:4,5

183:11,19 184:11,14

185:2,4,9 187:7,7,17

187:19 188:2 191:9

198:12 200:19 201:1

203:2,12,12,17 204:3

204:4 206:22 207:14

Boards 120:2

bodies 9:8

bonded 10:18

book 163:14

boric 3:6 14:2 19:12,16

20:1,21 21:22

boron 3:8 40:9,17 41:17

44:8 45:4,16,17,22

46:12 48:1

bought 65:4

boundaries 112:5

bovine 193:5

Bowl 13:6

box 106:12 161:5,14

BPA 196:3

BRADMAN 1:13 7:1,22

20:17 21:14 24:14

30:21 31:2,4 38:17,19

51:12 60:22 71:2

133:10 169:9 190:21

brand 141:2 188:19

189:3

brands 186:19

break 71:12,13,21 72:3

73:22 179:3

breakdowns 176:18

breaking 179:1

breaks 96:13

breast 138:4

breeder 63:3

breeders 62:1

breeding 62:4,5

bridge 92:6

brief 175:1

briefly 185:3

Brines 2:13 4:16,18

9:19 10:1,4 14:4

19:13 23:1 26:9 30:12

30:13 40:11 47:15

49:13,15 50:10 52:5,6

54:17,18 55:13

bring 38:11 39:19 92:2

144:6 149:2 157:4

158:10 159:7 179:13

184:2 194:18 195:10

197:7

bringing 137:16 158:18

196:17

broad 66:18

broadening 47:8

broader 87:12 171:9

193:19,22

broken 57:3

brought 65:12 127:18

brown 31:11 65:18 66:1

66:4

Bs 19:22

buggy 161:12

BUIE 1:14 61:4 71:6

83:12 165:12 191:3

build 38:13 44:11

114:21

build-up 30:6,9

building 10:9 35:22

43:20,21

bundled 24:20

burden 149:8

burn 12:22

business 142:15,21

151:9 182:7 200:10

Business/Closing 3:20

businesses 201:6

buy 101:7 108:2 110:19

205:19

buying 101:2,5

buzz 166:9

byproduct 85:14

C

C 3:11 52:4,9,16 53:3

C-O-N-T-E-N-T-S 3:1

CACS 191:18

Calcium 5:13

California 20:19 114:11

119:5 135:5

call 54:13 84:12 91:15

91:20 125:19 134:5

136:15,18 168:12

called 199:3

calling 83:8

calls 76:20 127:17

cancer 138:4

Canyon 109:9

capacity 31:18 91:16

capitalistic 131:21

capture 24:8

carbon 10:17 85:13,14

carbonates 3:9 47:12

47:18

care 140:11 205:22

career 151:3

careful 93:2,10

carry 141:11 145:21

189:9

Carson 205:6

case 46:21 49:13 127:7

142:14 154:4 170:7

cases 158:15

catastrophic 97:16

categorized 158:13

categorizing 179:16

cation 31:18

cause 6:1,2 137:8 151:9

151:9

caused 56:3

causes 87:9 152:10

caustic 5:21

caution 122:10 156:22

CCOF 43:9 79:3

CEAA 180:4

cemented 139:3

Center 43:2

certain 25:6 58:12,12

90:16 109:19 110:1

171:6

certainly 24:2

certificates 200:9

certification 17:8

177:18 188:21

certified 52:16 68:17

83:20 85:18 123:2

145:8 150:17,18

169:20

certifier 28:13 82:4

119:21 120:19 122:2

122:17 153:10

certifiers 11:11 20:5

23:19 28:10,19 30:7

42:2 58:6 75:18 78:21

79:1,11

certifies 79:3

certify 79:2

certifying 69:8 79:1

Chaco 109:9

chains 176:19

Chair 1:12,19 4:3 25:8

25:12 39:13,21 40:1

48:10 49:5 50:8 60:2

60:5 61:6,6 64:4,7

68:15,20 69:3,10,13

70:9 71:9,9,15,20

72:1,9 113:7 164:17

172:22 178:2,14

180:18 182:18 183:1

183:10 188:15 189:12

190:2,3,9 191:8,8,16

192:6 195:6 197:3

198:15 199:7 200:1,6

201:22

chaired 181:8

Chairman 3:2

Chairperson 1:10

challenge 44:7 59:2

157:4 166:2

challenged 38:12

challenges 61:22

challenging 67:1 136:1

chance 72:16 195:16

change 16:13 17:13,15

19:3 21:12 40:6,22

42:22 46:14 54:3,6

79:19 81:8 130:6

140:8 179:17 194:6,8

196:12

changes 103:11 139:22

183:3,7,10

changing 17:21 19:4
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Neal R. Gross and Co., Inc.

211

20:11 41:1

Chapman 1:10,12 3:2

4:3 25:8,12 39:13,21

40:1 48:10 49:5 50:8

60:2,5 61:6 64:4,7

68:15,20 69:3,10,13

70:9 71:9,15,20 72:1

72:9 113:7 164:17

172:22 178:2,14

180:18 182:18 183:1

183:10 188:15 189:12

190:2,9 191:8 192:6

195:6 197:3 198:15

199:7 200:1,6 201:22

cheap 91:9

check 106:14

check-off 149:14

chemically 82:8

chemicals 7:17 205:1

Cherokee 118:11

chi 161:20 162:5,10

chief 92:11

childcare 7:15 21:7

children 119:8,13

126:14 139:12

China 165:5

Chinese 161:20 162:6

chloride 196:20

chlorides 40:15

chlorine 3:5 4:14 5:3,4

5:9,14 6:21 8:4,5,6,9

8:14,17,22 9:5,14

chlorite 195:12

choices 19:7

choose 41:14 107:3

205:19

chunk 101:5

circle 160:14

circles 129:9

cite 115:5

cited 115:9

citizen 23:22

citrate 193:2 195:20

city 84:1 126:12

claim 77:15

claimed 82:4

claims 53:7 84:15 88:14

clarified 73:12

clarify 48:10 50:8 64:7

66:10 147:18 160:4

clarifying 194:14

clarity 131:15 143:10

167:3 175:9,13

class 43:11 65:18 66:1

66:4,8 110:11

classes 109:19 110:1

clay 163:4

cleaning 5:1,6

clear 48:19,20 56:19

69:4 73:9 75:11,18

120:11 128:3 166:11

166:13 172:1,4

176:17 182:10

clearer 175:4

clearly 123:2

climate 38:13 144:14

clinical 92:13,14

close 74:13 105:22

164:4 172:21 204:9

closed 122:15 170:13

closed-minded 99:8

closely 81:2,11

closing 178:3 200:10

200:16 206:15

clover 144:8

co-leads 174:18

coal 31:11,13 34:22

35:4

coal-related 32:6 33:19

coast 69:16

cobalt 3:10 43:4 47:14

47:20 48:14 50:9

Cochiti 109:3,5,10

111:2,18

cockroach 24:17

coconut 82:9

coexist 205:8

cognizant 37:21

coir 82:9

collaborative 128:14

132:15

colleagues 120:19

201:5 204:6

collegial 87:16 148:7

collegiality 115:1

color 163:20

Colorado 1:9

combative 169:5

combine 4:16 26:7

121:22 172:6

come 4:5 17:16 19:2

66:4,15 72:9 74:1

81:5,14,16 86:1,20

87:17 88:3,12 89:2

93:16 94:6 95:10

101:20 103:4 106:4

106:14 117:16 120:10

126:17 141:4,5

149:19 151:7 152:5

155:15 156:15 157:19

158:3 168:15 174:2

176:5 178:8 181:22

183:3 186:11 193:1

197:11 201:12 203:4

203:14 205:4,22

206:2,3,4

comes 62:21 110:3

119:6 174:15

comfortable 89:14,16

123:4

coming 14:20 47:2

103:22 104:16 119:17

123:21 125:22 138:11

138:16 143:6 148:8

155:6 161:21 163:18

179:7 180:13 188:4

195:3

comment 7:1 12:1 17:5

18:13 20:17 23:18,22

27:20 38:16 39:5

42:18 43:2 49:10

53:11 56:18 58:3

61:21 66:6,11 67:17

70:2 74:18 77:2 80:10

82:22 89:8 101:6

123:18 124:6 127:2

171:16 175:16 183:4

183:8,18 185:21

186:18 196:9 200:17

202:17

commented 28:10

53:16

commenter 24:5 51:18

53:20 103:17

commenters 13:9,13

20:7 53:1 59:3 103:12

202:10,11 203:1,3

commenting 188:3

comments 6:5,12,21

8:1 9:14 11:9,10,13

12:8,11 13:13,21 16:2

16:17,18 19:11 20:5

20:10,16 21:9,21

24:12 25:1 26:6,8

27:17 28:2,6,16,21

30:11 31:7 32:17,19

32:21 33:2,12 35:13

41:22 44:3,5,17 46:11

48:8,13 51:10 53:13

55:8,11 57:7,17 58:2

59:12,17 65:7 74:4

77:7,7,17 79:13,15

82:22 94:4 99:8 113:1

113:9 121:14 123:17

133:9,12,16 135:11

135:20 136:7,13

157:22 164:21 167:16

167:18,20 169:11

171:15 178:3 184:3,7

200:11 202:15 203:22

206:22

commercial 57:21

commercially 32:5

56:14 119:20

committed 76:13

118:20 121:2

committee 21:21 39:20

42:13 75:4 76:13

129:6 147:15 158:8

181:11,15,16 188:5

committees 180:16

199:14

common 78:3 116:14

122:7,22 123:7

148:18

commonly 42:2

communicate 191:11

communities 127:6

community 64:22 77:13

87:14 101:12 104:7

108:8 148:15 149:11

150:8 151:2 175:2,13

184:16 186:2 201:3

compared 113:10

160:17

compatible 33:16

compensation 182:5

competing 91:14 114:4

114:19 131:20

competition 154:19

155:1

complain 7:7

complaints 7:5

complete 12:22

completely 81:5,9

129:12 133:4 137:18

complex 81:14 96:20

97:9,18 98:10 99:6

114:13 132:16 164:16

complexities 98:20

complexity 93:14 98:14

99:12 161:3 164:1

compliance 9:7 58:5,16

compliant 86:4,5,10,12

complicated 62:20 97:1

comply 85:8

complying 83:15

component 10:17

31:13 66:21

compost 34:10 36:11

36:14 81:15 144:8

153:1

compost-based 143:18

comprehensive 6:15

7:13 9:11 27:5 35:13

181:7

comprised 10:16 11:10

compromise 114:15,16

134:15 174:2

compromise-oriented

134:14

compromised 93:11
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

212

compromises 157:6

concede 155:16

concentrations 6:1

concept 121:3

concern 5:21 7:11

27:14,19 35:16 39:10

48:11 56:9 58:20

61:22 65:16 152:11

154:20 155:2 171:10

concerned 11:16 28:16

34:2,16 69:15 71:17

81:1

concerns 170:22

concluded 201:15

207:19

concludes 57:8 178:15

200:7

conclusive 194:9

conditions 37:9 38:1

conducting 142:15,21

conference 135:16

171:20

confidence 178:8

confident 125:17

confined 23:6

conflict 92:4 148:14

151:10 174:15 182:1

182:13

conform 126:4

confused 102:3 112:21

120:1,9 128:16

confusing 101:19 102:2

114:19 116:1

confusion 113:2,20

114:8 116:1 173:17

Congress 168:15

189:20

connects 162:8

consensus 86:1,2

87:18 134:15 148:22

152:6 185:12

consequences 154:6

conservationist 207:7

consider 34:3 112:8

184:11

consideration 158:18

considerations 110:2

considered 9:6 27:22

38:21 52:13 63:14

considers 185:2

consistent 50:6 106:11

122:4 185:7

constantly 92:10 93:4

114:3

constitute 182:12

constitutes 80:8

constraint 34:4

constraints 38:22

58:11 135:11 172:5

172:12

consultant 136:14

consultation 185:22

consumer 63:10 91:7

100:18 114:7,16,18

151:19 184:16 186:8

189:22

consumers 90:15,18

91:8 100:14,16 108:5

132:6,6 137:6 139:17

149:7 185:5 186:1,9

186:20 187:9 189:2,5

189:19

consumption 67:9

154:11

contact 5:5 19:17 78:1

contain 15:19

container 75:3,14 76:8

78:8,11 79:4,9,10

80:8 82:6 90:12 104:8

116:6 120:6 128:22

131:12,13 134:2

144:7 152:6 153:18

154:17 156:12,14,16

174:8 177:15 194:12

containers 73:19 76:8

99:5 104:6,10 143:17

144:5,16 154:3

155:16,18 156:10

157:8 158:5 168:6

174:11 175:3

contaminate 23:9

contamination 62:2,10

62:12 63:14 100:8

180:12 193:13

content 14:15

continue 27:4 67:14

68:14 71:19 96:10

119:14 132:16 174:17

178:22 180:5

continued 23:12 27:2

33:6

continues 132:17

continuing 23:2 40:12

47:16 52:7 55:15 72:4

180:9

continuous 129:4

179:18

continuously 166:10

continuum 132:18

166:18,22 175:20

contrary 111:9

contrast 153:17

contribute 82:17

contributing 89:1

control 19:15,16 20:2

20:19,20 21:6 22:10

23:5,15 24:19 25:17

26:11 27:8 29:8 56:22

124:1 192:17 193:10

conundrum 67:12

conventional 90:20

97:4 107:2 138:15

139:9 160:22 169:19

186:15

conversation 13:17

66:6 86:20 87:12 89:4

92:22 110:13 112:6

112:14,14 117:2

127:7,8 128:14 137:2

154:19 173:6 178:7

conversations 87:5

89:16 112:11 132:4

135:14 149:17

conversion 97:21

Convert 191:20

convince 17:13

cook 162:3

cool 105:20 205:10

cooperation 102:20

copper 3:7,9 26:12,13

26:13,19,21 27:1,1,7

27:12,15,16,18 28:2

28:17 29:6,12 30:9

47:13,19

copper-based 26:15

coppers 26:7,12 27:4

27:14 28:9

core 91:2,4 106:4

correct 15:13 25:10

46:10 50:10 68:19

140:2

Coryneum 29:18

cosmic 163:5

cost 79:19 110:17

134:11

costly 110:20

counterions 10:19

countries 78:9 167:11

country 105:4 106:7

107:7 109:8 110:9,11

124:19 136:16 152:9

couple 28:6 53:15

84:14 106:10 126:21

131:17 133:16 144:4

159:22 175:18 200:11

course 34:11 39:7 47:1

61:20 65:6 76:18,22

121:15 139:8 140:11

157:21 163:11 177:17

194:21

Court 1:9

cover 36:12,13 37:11

57:17 153:2

covered 63:8 158:6

193:18

crack 22:12,17

cracks 22:16

craft 67:7 68:16,18 69:5

crank 197:16

crazy 139:10

create 45:22 127:6,8

131:2 152:5

creates 150:8 154:16

creating 148:14 151:10

credence 93:2

credibility 123:19 124:7

credible 44:19 161:16

crevice 22:17

criteria 95:17 116:18

117:3 119:1

critical 9:6 25:20,21

103:19 104:5,12

crop 4:21 5:5 13:18

19:8 21:11 32:2 36:13

42:9,12 53:5 54:21

61:8 67:5,10 76:17

80:18,20 138:19

146:5 147:15 153:2

154:1 191:21

cropping 36:12 37:11

crops 3:3 4:6 10:10

19:17 20:3,4,6 25:11

27:6,19 28:1,5,12

39:20 41:21 44:6

50:20 52:22 54:13

55:14 57:1 59:13 60:9

62:10 63:11 70:12,13

71:11 72:4,12 129:6

130:5 132:21 138:19

152:19 153:2,9,12,14

153:18 154:8,10

158:8 170:5,6 178:15

192:18 196:14

crosses 176:2 189:15

crutch 35:21

CS 65:14 88:22

cucumbers 108:1

cuff 148:1 152:15

culminate 109:12

culmination 109:10

cultivate 133:1

cultural 162:12,13

cultures 161:19

current 28:4 53:9 69:18

128:21

currently 14:21 17:9

49:19 81:12 100:15

102:22 145:20 197:19

curve 93:22

customer 101:19

customers 8:13 100:19

150:16
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

213

Cytospora 29:17

D

D 192:16

D.C 124:4

daily 111:7 120:7 153:8

dairy 8:20

damage 18:3 79:16

114:7

damaged 79:22

Dan 1:18 60:12 62:17

90:2 93:12 96:21

99:14 114:1 123:17

128:9 163:9 167:8

168:9 169:6 179:6,7,7

179:9 180:10,22

182:18,19,20 183:21

200:2

Dan's 94:4 100:13

123:17 124:6

dang 205:9

data 12:3,3 107:15,18

160:13 199:1

Data's 107:12

dating 165:8

Dave 1:15 61:13 102:11

113:6 123:9 174:19

180:6,11 204:12

day 106:13 120:3,4

132:20 141:16 142:9

147:11 174:13 182:7

182:11 187:15 188:8

202:4,17 205:4

days 47:1 77:7 84:15

96:14 127:20 155:11

161:12 164:9

De 1:14 60:21 71:1

99:14 146:12 190:20

195:8

deal 53:12 58:20 59:5

84:18 122:1 199:18

dealing 69:17 86:3

96:20 167:12 172:5

173:18

deals 46:6

dealt 44:1 64:18 200:9

dean 124:8

dear 206:5

debate 98:17

debrief 128:1

decade 185:20

decades 133:20

decide 194:18

decided 74:1 130:4

131:18

decision 90:9 91:1 93:9

148:8,12 166:4

168:13 172:21 179:16

decision-type 62:19

decisions 131:9 134:21

150:3 177:6

decisiveness 103:2

declining 44:13

dedicated 201:11

deep 123:22 171:10

deeply 168:11

defer 25:1

Deferred 3:18 183:22

deficiencies 41:16

deficiency 40:16 41:2,3

41:5,8 42:9,15,20

43:18 44:6,14 46:5,7

deficient 48:3

define 116:20,21

122:11 160:8 175:11

defined 14:7 99:15

111:22 167:13

defines 83:4

defining 172:9 198:1

definitely 7:11 26:3

51:12 54:8 66:21

69:10,14 91:17 99:19

100:19 112:22 113:3

127:7 133:17 140:19

150:2 157:15 164:20

definition 74:9,10,19

81:22 82:13 105:21

147:17 166:21 167:1

175:6 177:13

definitions 74:6 75:11

103:13,16 116:9,11

116:13 120:11 122:6

129:7 157:2 166:11

166:13,17,20 175:2,5

definitive 102:6

defoliant 40:14

degree 87:18

delay 148:8,12 184:12

187:12

delayed 188:14

deliberate 148:11

deliberation 142:13

202:20 207:1

deliberations 142:5,17

143:8

delve 174:7

democrats 189:17

demonstrated 43:18

denied 35:2

Denver 1:9,9

Department 1:1 117:20

142:6 147:8,19 199:3

departments 124:18

dependence 154:11

dependent 153:15,18

170:8

depending 197:12

depends 122:19 185:6

deployment 25:22

deposits 30:16 32:15

depth 59:15 103:13

171:14

Deputy 2:17

derivable 34:10

derivatives 32:11,12

derived 14:8 32:6 35:3

49:20,21 52:12

describe 131:19 136:3

136:4

described 31:11

description 172:1,4

descriptions 116:22

deserts 126:15

deserve 141:11

desiccant 40:14

design 97:2

despoiled 137:15

139:11

destroy 98:1

detail 77:9 174:9 177:4

detailing 14:14

details 176:8

determination 39:17

determine 84:11 85:8

85:20 86:8,9

determined 179:20,21

196:15

determining 116:17

181:5

detriment 131:22

detrimental 150:13

develop 96:17 117:20

118:1

developers 98:1

development 3:17

92:18 130:3 179:6

180:21 182:19

dialogue 89:13 178:17

203:18

diatomaceous 21:4

died 138:4

difference 65:14 78:1

131:12 138:8

differences 186:14

different 37:22 39:7

74:15,16 76:4 81:5,9

86:19,21 91:22 92:5

94:6 99:15 112:12

120:18 121:10 130:3

133:19 134:1 135:18

156:21 161:2 170:4

173:8 176:4 188:11

193:4 198:9,10

difficult 28:12,15 42:21

58:7 59:4,9 98:11

113:14

dig 35:1

digest 192:12 193:17

193:19,21

digging 93:10

dihydrogen 195:20

dilution 132:10

dime 119:10

dimensional 160:19

dioxide 5:14 85:13

direct 5:5 19:17 150:16

direction 140:7 142:19

166:6

directions 5:11

Director 2:15

disallow 150:7

disallowed 79:18

disappear 176:20

disappears 45:17

disappointed 159:12

disconnection 126:15

discount 94:20

discounted 163:17

discrete 116:21 129:5

discuss 21:17,20 42:13

44:9 54:5,13 59:14

195:12,16 196:6,18

discussed 66:20

discussing 19:8 194:10

discussion 3:14 6:17

27:21 33:1 35:9 38:20

56:21 57:9 58:21

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47:21 50:12 51:17

55:18 57:6,7,12 59:11

61:19 64:8 70:5,11

72:22 77:5 88:17

97:19 102:16 113:13

117:18 136:11 146:13

166:7 167:7 177:8

179:10 180:20 184:9

188:15 189:11 190:11

199:8 206:13

Harriet's 169:11

harvest 5:4 28:14 168:2

harvested 27:18 28:1

28:11 67:6,10 154:3

harvesting 69:19

hash 103:4

HASSUP 118:4,6

hate 122:18

Hawaii 110:16 111:10

111:13,19

Hawaiian 111:21

hay 138:21

hazard 33:14

hazardous 6:12 56:6

head 25:3 106:21 140:2

141:7

headed 144:21

heading 192:18

heads 80:11

health 41:13 55:5 56:3

101:8 137:8,10,16

138:2 139:2

healthier 130:19,22

138:10 139:5

healthy 91:10 137:11

hear 7:5 94:19 99:2

102:8 106:14 107:13

124:8 145:6 149:16

160:3 188:10

heard 11:12 12:1 17:2

22:4 31:11 47:1 72:16

77:7,18 79:10 82:3

84:15 104:14 107:16

120:22 122:13 126:22

133:13 141:5 149:12

202:17

hearing 38:20 60:11

89:4 94:2

heart 113:4 150:3

heartburn 122:3

heartened 168:12

heavy 18:4 131:8 132:2

hectares 78:10,12

heirloom 58:12

held 85:5

hell 138:9

help 17:19 26:3 38:9

140:9 143:7,9 147:13

172:8 174:1 180:10

204:3

helpful 43:10 102:2,7

105:13 172:13 173:14

173:17,21 176:10

helping 115:18 203:19

hen 186:15

hens 186:11

herbicide 9:15 11:14

40:14 136:19

herbicides 3:5 6:19

10:6,7,15,16 12:8

26:17

hey 107:7 141:6

Hi 10:14

high 5:22 27:16 125:7

154:11 177:2

higher 63:6 154:22

highly 5:21 111:17

hinted 171:8

hinting 135:21

Hippocrates 163:9

hippy 151:14

hired 119:20 125:7

history 35:2 45:1,2 74:4

133:2 164:22 165:7

172:14

hit 25:7

hold 60:6 194:5,7

196:11 197:20 198:6

holders 64:12

holding 81:3

hole 105:7

holistic 168:13

homes 110:20

honest 89:17

honestly 157:8

hope 16:19 18:15 58:1

85:22 137:2,13

165:21 174:1 178:10

189:20 194:13

hopefully 24:3,9 196:17

hoping 43:22 76:9 87:6

horizon 204:19 206:9

horse 161:12
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hotbed 106:18

Hotel 1:9

hour 127:10,10 171:22

hourly 120:8

hours 125:16 202:14

house 7:4

houses 20:2,9 22:15,18

Howard 204:19 206:9

hubris 96:22 98:9,22

99:21

huge 80:2 146:17

149:15 151:1 160:7

human 30:4 55:5 56:2

67:8 91:15 96:18,18

96:22 98:8,21 99:21

humans 30:6

humates 32:7

humble 205:4

humbled 117:14 134:20

humeric 85:3

humic 3:8 30:11,15

31:6,9 32:5,11,11

33:13 34:4 35:3 37:13

37:17,20 39:7 40:4

85:2

hump 38:9

hundreds 165:8 171:17

hunter/gatherers 130:4

hurried 148:11

hybrid 58:13

hydrogen 10:17 35:4

hydrolysis 32:7

hydrolyzed 160:5

hydroponic 73:6 74:7

76:5 77:19 79:4,14

80:1 81:8 82:6 83:19

90:11,19 98:18 104:8

107:1,3,4 111:22

116:7 129:10 131:12

131:19 134:2,4,6

140:14,16,20 143:16

145:2,13,21 150:8

152:11 153:17 154:10

154:17 155:3 156:12

156:17 164:22 167:20

168:5 174:6

hydroponically 79:17

hydroponically- 79:6

hydroponics 73:15

76:1 77:16,17 81:22

82:7,13 83:4 87:5

88:18 104:11 107:12

122:21 129:2 146:21

156:10 158:14 171:17

175:3 194:12

hydroxide 11:6 26:13

32:10,10

hypochlorite 5:13,15

hypochlorous 8:7

197:10

I

idea 33:11,13 81:4

163:8

ideal 148:18

ideally 88:7 134:14

identical 65:11

identified 65:18 66:7

identify 51:16 66:9,14

67:2

identifying 65:22

ideology 130:16

ignorant 133:5

ii 5:3

illusion 151:22

imagine 141:18 153:9

immediately 122:3

impact 11:18 90:5,7,15

90:18 91:1 139:21

140:4 166:3

impacted 90:9,13

impacts 12:5 109:16,20

125:5,10 170:12

imperative 25:16

impetus 82:5 130:17

implement 118:6

implementation 184:5

184:12

implemented 49:17

187:16 188:13

implications 126:10

important 27:4 33:22

83:13 87:19 89:15

90:8 105:17 106:18

108:2 112:5,8 116:18

124:6 125:13 126:8

126:22 127:13 128:5

133:18 134:8 177:1

184:19 187:16 188:1

188:7,13

importantly 201:7

imports 114:13

impossibility 58:17

impractical 28:19 58:17

impressed 200:22

improve 21:18 91:16

94:15

improved 57:19

improves 31:20

improving 154:14

in- 202:15

in-field 154:8,18 192:2

in-ground 107:18 152:8

in-line 100:11

in-person 202:13

in-the- 146:17

in-the-soil 146:16

inaccessible 21:2

incentive 45:21 191:20

include 10:20 66:8,19

82:16

included 53:4 95:18

138:19

includes 26:14 73:19

111:4,5 154:2

including 5:1 6:8 19:15

21:6 32:9 41:17 52:11

94:16 165:1

inclusion 116:20

income 149:8

incoming 184:19

incompatible 33:18

inconclusive 18:6

incorporate 133:11

165:5 175:11

incorporated 56:11

135:6

incorporating 122:14

153:2

increase 88:9

increased 32:3

increases 31:18

increasingly 119:3

incredibly 96:20 97:18

98:10 110:22 124:15

incumbent 93:1

independent 119:21

Indian 118:11

indicated 6:5 53:2,6,18

53:21 69:19

indication 66:2

indigenous 110:18

111:20

individual 10:20

individually 53:3

industry 11:11 20:7

44:16,19 93:6 104:22

120:13 166:4 184:17

185:6 186:20

inert 82:1,7,8,11,14,15

83:4,6,7

inerts 194:5,6

inevitable 90:12

info 136:14

inform 143:7

information 4:17 7:16

7:21 80:7 147:16

160:16 164:6 174:16

192:5,14 204:2

informed 76:16

informs 109:4,9

Ingestion 6:2

ingredients 53:4

inheritance 119:11

inhumane 24:1

injury 6:1

inner 84:1

innovation 121:11

141:7

innovations 141:3

innovative 37:15

111:17 120:20 141:3

141:10

input 56:2 67:5,10

72:18 76:20 96:18,18

117:8 121:19 125:2

135:1,9 137:3 158:16

159:18 178:13

inputs 96:5 115:8,13,14

115:14 137:3,8

139:19 144:3 145:3,5

145:5 146:3 154:1,3,7

154:9 158:14,15

168:1 170:8,9 174:12

193:13

insect 24:19 25:16

insecticides 19:14

24:19

insects 24:2

inside 144:7

insight 113:2 203:18

207:14

insightful 204:2

inspections 22:15

188:9

inspector 12:16 137:21

inspector's 192:3

inspiration 201:13

inspired 201:8

instances 68:11

institutions 109:11

integral 185:10

integrated 27:8

integrity 83:14 132:11

intellect 91:16

intended 46:8

intent 46:4 66:9 121:22

interact 111:7

interaction 87:11

135:12,16 200:18,21

201:2

interest 92:21 180:7

182:1,13

interested 120:20 133:9

160:16 200:13

interesting 7:21 31:7

33:1 35:9 38:20 57:2

80:10 92:17 100:16

interests 93:5 184:16

interface 78:19

interrupt 67:19

interrupted 184:8
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interruption 203:7

Intertidal 69:20

interviewed 151:21

intimated 37:15

intimately 111:6

introduce 132:8

introduced 119:18

introductory 184:3

invaluable 200:21

invite 168:15

inviting 92:20

involved 33:8,9 92:9

93:5 135:7 181:9

iron 3:10 47:13,19

irony 67:5

irrigation 5:1,6 6:9

irritant 20:14

irritation 6:3

isothiocyanate 192:20

issue 14:21 16:7 20:13

30:4,5 43:3,22 48:5

49:14 50:14 57:2,20

59:4 62:20 65:14

67:13 68:9 71:18 73:7

81:6 99:17 106:5,22

109:15 110:22 112:8

112:12 113:3,21

114:12 126:19 151:11

165:14 168:6 170:11

171:5,13 172:15

184:21 189:22 190:1

issues 13:2 17:12 46:1

57:22 63:10 69:1,17

75:22 87:15 113:14

114:10,13 134:12

169:14 172:7 181:15

187:8 193:13 201:3,9

201:10 202:6,18

it's-- 93:14

itching 198:13

item 21:18 42:21 52:1

57:9 64:8 70:10 72:12

115:17 184:10 196:2

items 68:20 69:6 73:20

74:11 76:11 179:14

199:6

iterations 88:19

J

j 30:14

Jacksonville 202:3

Japan 162:1

Japanese 195:20

Jesse 1:14 83:10,11

102:17 113:13 117:17

165:10

JESSICA 2:18

job 189:11 203:16

Joelle 1:16 9:1 128:10

146:14 172:20 174:19

176:16

Joelle's 150:6 176:13

Journal 92:12

justice 132:3

justify 140:3

K

Kansas 12:18

keep 42:3 73:22 78:6

80:9 97:13 121:17

128:6 157:17 158:2,4

173:2 199:10

keeping 152:13

kept 76:16

key 153:16 162:22

Ki 162:1

kids 126:18

kill 143:19

kind 18:11 19:6 31:11

32:22 38:8 44:15 51:6

54:10,11 57:17,18

73:17 82:5 83:9 84:2

84:20 88:3,13,14

89:13 101:16 110:2

111:11 114:21 121:16

122:9,22 123:17

126:1 127:5 129:18

130:11,21 131:8

133:11,21 134:20

135:20 151:14 157:10

159:9 164:8,13

165:12 167:18 171:8

172:6 173:15,15

175:2 177:6,17

193:14,18 194:6

198:18

kinds 112:2 121:10

134:1

knew 14:20

know 8:3,13,15 9:4 11:3

13:15 16:16 18:3,4

22:5,7,10 24:16,16,19

28:22 29:6,8,10,15,15

29:19 30:2,3,8 33:9

34:17 35:16,17,18

36:4,6,10,11,18 38:21

39:1,15 40:1,2 41:4

41:10 44:6,16,18,19

45:4,15 46:4,6,16,17

48:14 51:3,7 55:4

56:20 57:13 58:1 59:7

59:18 62:9 63:9 64:14

64:21 66:12 67:2

73:21 75:4 82:20 84:8

84:14 85:3,12,19

86:13 88:16,21 89:9

89:17,22 93:19,21

94:2,9,9,12,18,21

95:1,3,4,6,11,15,22

96:3,8,13,13,21 97:6

97:8,11 98:1,3,18

99:6,21 100:2,14

101:1,6,9,10,15,15

102:21 103:1,8,14,16

103:18 104:14 105:5

105:16,22 106:9,17

106:18,20 107:16,19

108:10 112:3,16,21

115:4 116:2,8 117:21

117:22 120:1 123:14

124:10 125:17 126:9

128:15 130:3 132:3

136:21,21 138:3,5

141:16 143:13 144:13

145:18 146:15 148:3

150:22 151:13 155:10

156:13,18,22 157:3,6

157:7,10,12,13,15,20

159:1,3,11,13,14,16

160:4 161:15 163:20

164:19 165:12 166:10

166:12,14,15,19

168:4,5 169:14,16,22

170:2,20 171:12,20

172:12,13,15 173:5

173:18 175:19,20

176:3,5,7,14,15,18

177:2,3,5,13 179:21

181:1,2 184:8,20

187:18,22 188:8,12

198:21 201:9,11

203:14

knowing 139:13

knowledge 117:15

153:7

known 11:2

knows 66:5 157:21

L

label 79:5,6,14 102:1

114:4,5,16 131:20

132:1,7 140:20

141:11 145:1,11,21

146:1,13,20 150:9,10

185:6 189:9

labeling 42:3 131:16

145:10

labels 101:16,20 114:19

labile 160:5

lack 41:18

laid 173:6

lake 165:2

land 110:12,15,17,19

110:20 119:4,6,7,9,12

133:1 137:15 139:13

139:14 151:15 170:18

204:18 206:8

landowner 69:21

landowners 69:16

landscape 62:5,6

125:11

language 77:16 103:21

103:22 109:2,3,17

122:7 123:1,2,7 127:4

131:11 177:14

languishing 193:14

Lao 162:16

large 12:21 22:15 94:10

101:5 145:13 147:3

149:11

largely 53:7 62:3

153:18,22

larger 135:15 170:11

172:7

largest 43:13

LaRocca 106:20

late 44:7 206:1

laurate 10:21

lava 111:20

law 9:12 91:4 94:17

141:12

lay 11:3 162:7

laying 186:15

lead 3:11 5:18 9:16

14:10 30:19,22 54:17

54:22 55:4 57:12

72:22 110:8 112:18

123:11

leaders 80:13 173:4

leadership 102:14

113:15 117:10

leads 72:14,15 129:18

195:19

leaning 73:8

learn 21:14 92:1

learned 18:14 97:11

learning 93:21 121:6,7

142:18 205:17,18

leave 46:8 55:8 119:2

132:13 133:7

leaves 162:9

leaving 139:12

legal 109:11,16,21,22

110:3,8,22

legislation 80:15

legislative 69:18

lend 112:17

lends 113:1

lengthy 185:20

Leopold 205:6

lest 205:4

let's 37:21 43:9 47:10
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52:3 55:8 58:19

131:18 140:22 145:18

157:1 161:17

letter 121:22 141:13

lettuce 143:20

leukemia 138:4

level 5:10 13:5 25:7

44:14 125:5 183:16

200:21

levels 5:4 27:16 45:5,13

95:12

leverage 65:6

Lewis 2:15 46:19 49:12

50:12,18 142:3,14

143:4 201:17,19

203:10 206:13

liable 64:13

libertarians 189:18

life 119:15 144:2 161:22

162:2 163:15 205:8

205:16

light 163:19

lightly 144:9

lignite 31:10,10 35:3,7

liked 99:14

likelihood 88:10

LIMA 1:14 60:21 71:1

99:14 146:12 190:20

195:8

limestone 163:4

limit 5:8 131:2 149:13

155:18

limitation 142:13

170:10

limited 23:6 41:20

197:11

limiting 41:19

line 73:9 75:19 104:7

108:10,15 120:15

136:15 156:9,19

175:21 176:2

lines 174:3

liquid 77:20 80:22

143:19 152:10 153:8

153:19 155:17,19

174:12 193:6

Lisa 1:14 2:13 14:2 26:8

40:10 99:13 114:1

195:7

list 2:13 4:20 11:14

14:14 16:9 17:4 27:10

27:12 32:12 49:18,19

50:16 54:19 55:7,9,21

56:7 57:3 60:6 179:19

180:2 195:2 199:22

listed 12:19 15:3 20:3

35:5 49:9 54:10 56:8

56:20 68:22 101:6

listen 76:19 165:16,21

listened 94:18

listening 99:7

listing 14:6 19:16 23:3

23:12 25:9,9 26:12,18

30:15 33:6 40:17

47:16,17,18 50:9 52:8

54:4,7,22 55:16 63:20

66:4 67:4

Listings 3:14 65:9

literally 94:14

literature 32:1 52:19

176:17

little 8:4 13:16 18:11

21:15 37:11 51:8,8,8

51:8 56:18 59:9 63:19

65:22 66:16 68:8 69:9

72:15 88:4 100:14

103:12 114:21 156:1

156:1 158:14,15

159:11,12 161:5,19

164:14 168:10 176:4

182:13 188:11 192:13

live 106:6

livelihood 150:4

livestock 56:21 57:1,4

138:9 184:5,13

185:16 187:2,11

188:5 197:4 198:18

living 134:22 139:12

149:6 150:1

local 151:2

long 23:15 57:15 77:19

91:6 96:7,11 112:1

127:1 148:13 164:21

165:7,7

long-term 18:10 137:10

long-time 139:7

longer 12:5 56:14 63:19

92:14 150:10 179:2

look 4:10 6:13,14 8:8

8:17 9:12 29:11,17

42:6 48:13 62:18 68:6

74:14 77:10 83:14

93:4 95:21 97:7,8

100:1 105:18 109:15

109:16,20,21 110:16

115:17 127:16 130:8

130:16 133:2,3

140:10 141:3,6

142:10 161:17,18,19

167:12 168:6 169:12

177:13,18 178:17

181:17 191:22 192:4

194:17 198:2 199:11

203:4 207:8

looked 32:16 181:16

198:9

looking 13:7 15:6 21:11

21:18 30:4,6 38:22

50:14 63:16 73:6 75:9

75:13 81:10 109:14

116:16 155:10 159:20

160:10 167:16 168:7

177:11 180:17 181:3

181:20 199:10

looks 25:3 128:22

loop 122:15 128:6

loophole 69:11

lose 140:21,21

lose/lose 168:21

losing 37:11

loss 63:7

lost 34:18

lot 7:14 16:2,17 17:5

18:15 20:18 22:4,14

22:16 31:7 32:19

33:19 36:12 37:4,9,22

54:4 57:17,22 63:9

64:12,21 79:19 80:4

81:7,10 90:5,14 92:4

93:9 99:20 100:16,17

103:2 105:21 107:6

108:5 113:22 115:15

117:6 119:5,6 120:16

121:11,14 122:17

123:20 124:2,3

127:11 129:13,18

133:13 134:11 135:6

135:8,13,18,18

136:17 138:9 141:6

147:9 151:10 154:18

158:6 160:3,15

164:21 165:18 167:21

169:18 171:6 172:14

172:14 174:14 178:8

180:6 181:14 202:5

202:18 203:14

lots 13:4 76:4 142:10

196:8 205:17

loudly 28:18

loudspeaker 106:14

love 84:6,7 118:22

119:8 120:12 127:22

low 23:7 44:10,14 45:4

45:13,16 177:3

lower 20:22 96:9

lunch 179:1,4

Lynn 107:14

M

machine 164:10

macro- 153:4

magnesium 196:20

main 75:22 187:14

Maine 69:16

mainstay 29:12

maintain 87:6 94:15

114:18 193:6

maintaining 6:9 87:16

114:22 154:14

maintenance 10:8 33:9

maize 62:4,5

Majestic 1:8

major 181:10 186:18

majority 42:1 53:13

66:3 70:14 152:9

186:4,5

making 48:2 58:22

76:15 123:18 133:9

140:8 142:16 143:8

150:3 151:3 168:13

168:20 204:8

mammals 95:15 170:21

man 120:4

manage 33:22

managed 177:3

management 27:6

Manager 2:13

manganese 3:10 47:13

47:19

manner 26:16,20

manual 57:19 181:4,13

181:19 182:15 200:5

manufacture 16:11

34:5,8

manufactured 31:10

manufacturer 18:14

manure 81:15 153:1

162:19 170:4

map 28:4

Marian 80:11

marine 3:14 65:9 67:18

67:21 69:15 70:13

168:1 194:17 196:13

market 16:7 29:7 58:11

58:14 63:8 79:22

100:22 107:10 132:11

140:14,16

marketer 131:17

marketplace 101:21

106:19

material 6:19 22:2,21

30:5 32:20 33:2,6,7

33:20 34:8,11 39:11

55:3 56:3 64:9 82:8

82:14 83:7

materials 2:18 3:4,16

4:11,12,15 5:3,19 6:5

6:12,22 8:4,6,9,14,17

26:15 27:13 32:6,9

49:18 50:21 51:1 67:6

70:5 81:14 82:10,16

154:2,12 169:7
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matrix 82:1

matter 72:6 78:17

152:22 158:1 182:16

207:18

maximum 5:7 162:5

McEVOY 2:17

mean 15:12 28:13 29:3

29:6 35:19 36:10 41:6

44:5 45:5,8,9 54:3

64:15 73:11 88:4

90:20 94:7 99:19

100:1,17 101:3

106:17 111:19 114:16

114:20 132:5 137:19

156:20 157:21 159:8

170:12 171:21 172:22

175:18 177:12 189:3

means 91:17,19 107:18

109:3 118:1 127:9

129:10,11 131:4

147:18 149:14 152:10

156:20,21 169:7

meant 12:19 74:15

measure 60:10 67:2

164:11

meat 159:12

mechanical 91:19

mechanism 179:16

mechanistic 91:15,19

100:11

medical 201:10

medicine 92:9,12

161:20 162:15 163:10

medium 82:17 83:4,6

meet 16:20 84:13 85:19

85:20 105:21 108:12

111:17 120:21 121:22

142:9 154:13 178:9

188:21 206:4

meeting 1:5 4:4 27:3

40:22 41:11 61:20

73:3,5 141:20 142:8

143:7 145:22 146:4,5

147:12 166:13 179:14

183:19 185:2 200:10

200:15,15,20 201:17

201:18 202:1,2,4,13

202:16 203:9,14

204:7 206:17 207:1

207:10,13,16

meetings 68:4 141:4

185:20

meets 16:12 117:3

121:12

Member 34:1,15 91:8

93:13 108:16,18,19

108:21 113:5 117:12

117:14 120:14,16

123:8,10 128:9,11

133:8,10 136:6,8,12

142:12,22 143:11

146:8,10,12 147:7,20

147:21

members 76:16 86:18

88:22 93:10 99:4

109:1 123:13 127:18

130:22 182:2,4,6

201:1,2,8 203:12,13

207:14

memo 17:14,15 19:5

49:16 50:3

memorandum 16:3,15

57:19

mention 115:12 144:17

198:20 202:1

mentioned 12:11 34:19

42:6,19 43:15,17 55:8

58:7 90:4 97:19,21

122:12 162:13 168:17

184:4 200:3 201:4

mentioning 130:21

mentions 115:13

menu 17:13

met 1:8 47:9 123:15

155:3 169:17 180:4

metals 18:4

methionine 198:10

method 48:18 49:8

methods 14:9 21:1

50:13 51:1 52:1

124:14 179:17,19

180:2 199:19,21

Mexico 165:3

Michelle 2:11 187:4

191:14 195:3

micro 51:6

microbes 85:12

microbial 37:20 84:15

85:11 175:5,7,14

176:15

microbiologist 130:2

micronutrient 41:1,19

43:22

micronutrients 3:9

31:17 40:9,13 41:15

41:17 42:7 43:4,8,11

44:8 47:12,17 48:22

49:2 51:11 153:5

microorganisms 31:21

mid-America 37:8

middle 46:17 88:3

103:5 111:19 156:4

178:9 187:21

Midwest 107:21 136:16

migrated 51:6

miles 2:17 62:6 151:20

168:17

mimic 144:10

mind 78:6 102:1 114:4

122:15 157:17 158:4

179:10 184:9

mine 113:9 120:18

157:13

mined 154:3

mineral 31:19 196:12

minimize 26:3 122:20

minimizes 26:16,20

minorities 84:1

minority 84:2

minute 72:2

minutes 77:6 167:5

171:12 200:3

miscanthus 37:16

missing 138:14

mission 84:11 133:22

203:20

Missouri 117:20 119:3

misspeak 152:16

mistake 161:9

mite 19:15

mix 143:18

mixed 67:18

modification 59:1

63:13

modified 74:17

moisture 37:12

molecular 124:21

molybdenum 3:10

47:14,20

Monday 105:16

money 119:5,6

monitoring 23:5 24:17

25:5 26:1

monitors 24:16

Monsanto 141:5

Montana 79:12

months 156:3 181:21

morning 4:3,6 94:22

mortality 186:14

MORTENSEN 1:15

25:21 61:3,11,14,17

71:5 123:10 174:21

176:11 191:2

MOSA 56:13 79:10

moss 31:12

MOSSO 1:16 9:2 61:1

71:3 128:11 175:1

190:22

moth 97:17

Mother 205:3,14

motion 59:18,21 60:2,7

61:7 65:15 68:2 70:6

70:9,11,12 71:10

190:4,9,11

motions 148:20

motivating 125:4

move 9:15 19:12 22:20

40:8 47:10 52:4 55:12

60:11 65:8 83:12 95:5

103:5 106:2 115:19

115:20 117:2 144:6

150:12 157:11 165:22

166:5 179:11 180:21

190:4 193:15

movement 91:6 130:18

150:13,19 151:15,16

moving 10:5 14:5 19:14

30:11,14 54:19 61:9

103:8 104:9 123:6

156:8 178:7 195:19

199:13

mud 204:21 206:11

mulch 3:6 14:3,7,13,22

15:1,5,17 36:12 194:2

mulches 14:6 15:5

multiple 95:11 173:7

mushroom 193:9

myristate 10:22

N

nailed 106:21

name 117:18

names 89:20

naming 66:17,17

nano 43:3,4,5 48:14,22

49:2 50:8

nanotechnology 43:7

48:5,11,15 49:8,16,20

49:21 50:7,14 51:22

52:2

natamycin 193:8

National 1:3 2:12,13,14

2:16,19 4:20 11:14

14:14 17:4 27:10

32:12 49:18 54:6,19

55:21 115:9 185:4,9

187:6

nations 110:14

native 111:21 162:14

165:3 167:17 170:18

191:20

natural 39:4 41:15

91:18 92:9 94:15

98:15 170:17

naturally 30:16 32:14

34:13

nature 91:16,21,22 92:1

92:1 100:12 132:15

168:13 205:3,14
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navigate 78:3

near 205:20

nearby 62:2

Nebraska 12:18

nebulous 75:15

necessarily 47:7

101:18

necessary 6:6 66:20

need 13:16 16:13 17:14

17:16 21:14 25:18

36:5,9 40:6 47:2 49:9

49:21 54:11 62:10

64:3 78:6,15 83:13

84:4 85:1,5,7,10,19

85:19 95:4,19 98:21

99:10 103:20,22

115:2,17 116:14

120:10 122:9 123:1

127:8,18 128:4 129:6

135:14 141:9,12

147:12,16 149:1

157:1,7,8,12 159:3

165:15 166:19 167:9

168:6 169:12 171:9

174:16 175:13,22

177:5 181:5 183:11

188:16 194:11 195:12

196:18 199:4 202:19

needed 6:16,16 9:13,14

68:10 73:16 75:4 83:1

122:6 200:5

needs 80:17,21 96:6

97:15 103:21 152:20

153:12

negates 36:7

negative 56:2

neighbor 65:5

neighbors 64:3,16 65:1

65:4

nematocide 192:21

nematodes 95:14

nest 138:20

Netherlands 80:11,12

81:13 83:2

never 48:16 88:12 97:1

148:13 166:21

new 12:3,4 18:7 47:2

49:20 54:19 80:15

92:12 93:13 106:15

123:13 127:17 137:21

163:18 168:18 169:8

179:18 184:20 201:1

203:12 205:18

Newspaper 194:8

nicotine 55:16,20

nitpicking 176:15

nitrate 85:2

nitrates 40:15

nitrogen 81:13 85:2,15

nodding 25:3

NOFA-NY 79:13

non- 59:7 193:8

non-biobased 14:15

non-dispersive 21:1

non-GM 62:1

non-GMO 108:3 114:7

132:8,10

non-organic 58:22

non-synthetic 32:7,8

52:14 54:20 55:22

non-target 24:2,8

non-toxic 52:13

non-use 139:2

nonanoate 11:4

noon 167:6

NOP 14:16 16:4,14

17:13,20 19:4 23:16

57:18 182:9

normal 183:17

normally 200:20

Northeast 42:5

northern 144:13

NOSB 2:11 4:4 6:18

27:3 34:1,15 35:2

40:21 41:11 48:14

49:17 50:6 56:5 76:6

76:16 86:19 142:8

182:2 185:17,19,20

186:21,22 204:16

note 30:2 32:14 39:5

65:19 113:8 140:5

noted 28:6,9 30:3,7

52:18 53:20 65:10,19

66:1

notice 138:14 206:17

206:20 207:3,9,10

noticed 116:5

notices 203:4

novel 132:21

November 206:18

NPEs 194:5

nuanced 146:22

number 14:17 29:6 30:7

55:7 98:6 123:14

135:8

numbers 107:19

nutrient 45:19 82:2

152:20 196:11

nutrients 31:16 52:13

84:16 85:13 104:16

104:18 143:19 152:10

152:22 153:13

nutrition 43:21 82:18

nutritious 84:7

O

OAKLEY 1:16 12:10

13:12 23:4 24:21 26:2

36:21 52:11 60:18

65:10 68:19 69:2,7,11

69:14 70:8,20 71:13

71:16 86:17 89:22

102:4 136:8 146:10

147:21 157:15 173:13

178:5 183:2 189:13

190:17

objection 35:18

objections 56:5

objective 116:19

124:14

observed 143:6

obvious 67:22

obviously 93:17 140:19

151:5 155:12

occasionally 94:9

occupational 5:22

occur 201:10

occurring 30:16 32:14

34:13 206:18

October 27:3 40:21

202:3,4,7,7 206:18

OFA 42:19

off-farm 149:7 154:4

off-target 12:13

offend 108:22

offer 141:6

offers 113:2 137:13

OFPA 27:13 77:14

115:5,11 143:13

152:13,20

oh 7:20 9:21,22 14:2

15:18 17:22 21:22

31:1 58:19 59:21

61:13 67:19 102:16

118:3 120:4 159:14

164:7 174:22

oil 160:6

okay 4:3 6:22 9:15

10:14 13:21 14:4,12

15:18 19:12,19 20:1

21:16 22:19 23:1 26:5

26:6 28:20 30:10,11

40:7,11 44:2 46:2

47:10 48:8 50:18 51:4

51:10 52:3 54:15,16

55:11,19 57:7,14

59:10 64:3 67:20 72:1

72:9 73:2 75:20,20

90:2 102:12 104:16

108:13,21 128:11

131:3 136:12 139:21

142:22 143:10,11

147:17 155:12 158:20

159:21 165:10 174:22

178:3 188:15 192:6

194:20 195:5 204:11

204:11

Oklahoma 189:16

old 12:3 111:17 128:17

168:19

older 97:6

oldest 109:7

oleate 10:22

OLPP 184:6 198:6,15

199:1

OMRI 56:13 66:6,14

once 76:22 184:20

199:1

one-by-one 206:3

ones 105:20 110:17

118:6 148:21 149:1

159:5

ongoing 50:15 65:20

178:13 200:4

open 89:8 94:1 143:17

157:17 158:2 164:13

174:10 183:18 187:13

191:15 203:5 206:15

opened 123:17

opening 159:11

operate 96:10

operating 83:18

operation 94:16 98:19

116:8,10,12 170:1

operations 52:17 76:5

79:5 83:20 85:5 99:4

99:5 105:9,10,12,19

121:11 122:12,21

123:3 141:17 147:11

155:3 164:22 165:2,5

186:16 201:6

opinion 77:12 78:2

opportunity 142:20,21

206:21

oppose 79:14

oppose-- 79:13

opposed 33:2 34:20

142:20

opposite 121:1

optimal 153:20

optimism 157:17

optimize 153:14

options 62:18 142:10

oral 200:17

orchard 25:20

orchards 13:15 25:5

order 72:10 89:21 162:4

165:22 188:21

organic 1:3 2:12,14,16

2:19 3:13 4:21 12:16

17:1,2,7,8,10 19:17

23:16 27:5 28:8 33:16
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33:18 34:9,21 38:6,13

42:5 43:13 48:16

49:22 52:17 54:1,21

57:10,11,20 59:5,8

60:8 62:1 63:6,11,21

64:22 68:17 69:8

77:13,14 78:22 79:7

79:12,14,20 80:12

81:14 82:10 83:15,21

83:22 84:13 85:18

86:5 90:21 94:10,11

96:15 97:3,5 98:9,10

100:7 101:7 105:21

106:5,11,15,17 107:3

107:4,8 108:3,12

114:6,6,11,12 115:10

115:11 117:21 118:1

118:8 121:13 122:16

126:4 130:17,17

131:1,4,6,22 132:5

134:7 136:14,19,20

137:3,7,20,22 139:3,7

139:7,17,19 140:21

141:6,11 143:12,22

145:2,4,9,21 146:1,6

146:16,18 147:4

149:11,13,14 150:21

151:16,18,19,22

152:18,22 153:7,21

154:8,16 160:19,20

161:7,10,16 168:12

170:5,15,16 184:5,13

185:4,5,7,9,12,15,22

186:3,6,10,10,15,19

186:20 187:2,6,8,8,10

188:17 189:9,15,16

191:21 192:17 193:7

198:5 201:3 204:18

205:21 206:6,8

organic-approved

145:3

organically 97:5 169:20

organically-approved

145:5 146:3

organics 99:9 100:1,5,6

100:20,20 101:2,13

115:4,8 132:9 151:5

151:13 189:14

organisms 12:5 14:8

52:14 176:19,20

organization 80:12

organizations 78:22

original 98:7 110:15

originally 97:4

ornamental 10:10

OSHA 56:7

OSP 43:11

ought 86:14

outcome 134:16

outdoors 186:12

outlawed 83:8

outlet 151:6

outlines 115:11

outset 126:7

outside 114:5 144:2,6,6

153:4,19 154:1

161:14 170:8,9

over-prescripting

39:10

over-use 28:17 36:19

45:20 95:22

over-using 27:15

overall 203:17

overflow 202:8

overlapped 26:8

oversight 145:9

overuse 34:16

overwhelmingly 11:12

owe 156:15 175:2,12

owls 138:12

owners 169:17

oxidation 35:4

oxide 26:13

oxides 3:9 47:12,18

oxidized 31:10 35:3

oxychloride 26:13

oxygen 10:17

P

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

4:1

p.m 207:19

pack 20:2,9 22:15,18

packing 7:3

page 200:15

paid 182:11

panel 135:4,5

panic 204:20 206:10

paper 15:1,10,10 16:1

160:17

paradigm 91:15

paradigms 91:14,14

paragraph 10:5 14:5

19:14 23:2 26:11,19

30:14

parameters 152:21

paramount 114:17

parasiticides 198:2

parcel 152:1

parents 119:10

part 13:2 25:20 27:5,8

44:22,22 50:15 55:14

68:21 93:10 95:16,16

114:9,12 115:22

132:4 143:22 151:9

151:15 157:12

partially 15:13

participate 135:4

particles 51:7

particularly 11:21

131:10

partly 135:6

partners 167:14

pass 39:14,15 185:2

201:16

passed 118:19 187:20

passes 61:7 71:10

191:9

passing 77:3 204:13

passionate 113:11

188:6

pasture 138:21

patent 64:12

Paul 2:15 140:2 147:9

201:17,22 203:8

pause 178:1

pay 95:19

PCA 44:18

PCAs 44:16

PCO 43:15

peat 31:12 154:4

pedagogic 127:5

penny 133:22

people 11:3,12 12:12

18:15 24:10 33:5,7

34:19 37:14 41:10

53:16 56:15 58:6,9,12

65:7 69:4 70:4 79:8

82:9 83:6,17,17 84:5

87:10,20,22 89:14,15

89:20 94:2,8,9 99:2

101:1,7 105:4 106:14

108:8 109:6,19 110:1

110:11,14 111:6

113:3,21 119:4 125:6

127:6 128:4,6 134:22

135:8,18 136:15

137:21 140:13,15,20

143:15 145:6 149:22

151:1,7 158:16

160:14 166:4 171:6

171:13,21 172:3,4,14

173:1 174:9 176:7

180:4,5

people's 150:4

peoples 110:18

pepper 195:21,21

peppers 107:21 108:1

perceive 163:16,19,20

percent 14:18 15:7,8,10

16:5 18:1 77:20 80:16

80:19,21 81:13 98:4

104:15,18 107:17,20

140:18 144:1 145:15

149:12 155:17 156:2

186:9

percentage 107:10

121:20,20 149:11,15

150:2 155:18

perennial 42:17 44:5

perimeters 10:9

period 32:19

periods 185:21

periphery 112:3,4

permanently 179:4

permitted 23:13 32:9

69:20

peroxide 35:4

persistent 23:8

person 82:4 83:3 90:1

116:9,11 121:17

126:1,2 134:13

202:16

personal 87:10,11

106:1 110:22 111:2

123:18

personally 29:15 56:20

100:2 121:4 127:20

130:16 201:8

perspective 9:3 77:10

109:22 119:22 122:2

130:14 148:17 155:5

158:2

perspectives 89:5,18

112:20 173:7 204:1

207:15

pertains 182:2

pessimist 167:4

pest 19:16 20:18,20

21:6 23:5 25:6 56:22

pest/insect 26:1

pesticide 7:8 26:4 56:1

pesticide-free 108:4

pesticides 5:20 43:17

Pete 206:5

Peter 127:4

petition 35:2 50:1,4

192:10

petitioned 49:22 51:21

193:3,8

petitioner 192:11

195:14 196:1

petitioners 197:15

petitions 193:21 195:9

195:18 197:6 199:12

petroleum 15:20

petroleum-based 18:21

pH 85:3

Ph.D 2:13,15

Phil 106:20

philosophic 91:12,14

philosophical 94:5
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96:21 111:18 174:15

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picture 168:4

piece 7:12 33:22 40:2

67:16 134:19

pieces 51:8

pike 46:15

pipeline 46:16,17

place 1:9 75:12 88:15

92:17 100:15 102:1

111:10 125:2 141:1

177:22 178:9

placement 14:13

places 22:5 57:18 63:12

107:6 127:21

plan 28:8 43:20 86:9

142:9 153:7,22

154:16 178:22 197:6

203:5

plane 105:15

planet 137:11 205:2

planner 198:22

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plant 26:11 30:14 41:12

42:12 52:8 78:16,19

96:3,4,6 144:2 162:15

162:22 163:3,6 164:3

164:16

plant's 80:21

plant-based 34:9

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planting 132:21

plants 31:16 77:22 78:7

80:16 84:21 96:8

111:5 144:15 163:15

163:15,19

play 33:17 205:11

playing 105:6

podium 188:3

poem 204:10

point 8:20 29:10,17,22

35:15 41:8 63:8 68:16

78:4 88:12,19 92:7,17

93:16 95:4 100:13

110:21 112:22 114:3

115:22 116:21 124:1

126:6 127:12 148:12

150:6 151:7 152:4

153:16 161:4 164:18

164:19 176:12,13

177:19 181:14 187:14

195:11 198:21 201:16

pointed 78:5 94:1

points 89:10 113:17

116:2 159:22

polarity 35:11

Policies 181:4,12,19

182:14

policy 3:17 16:3 17:13

19:5 49:7,16 50:3

57:19 124:4 179:5

180:21 182:1,1,3,19

183:12 200:1,5

political 169:4 189:15

189:22

politics 109:11

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Polyaxon 192:16

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pome 27:8

ponics 73:20 74:6

75:10

poor 175:6

pop 191:15

popular 105:2

population 7:10

portion 34:12

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Portland 106:8

pose 159:19 173:9

position 134:21 149:9

positions 173:16

positive 169:3 178:6

possibilities 75:2

possibility 24:6

possible 36:16 79:16

91:11 92:14 105:11

155:21 178:10 203:7

possibly 17:20 27:16

42:22 140:17

posted 200:15

pot 85:2 144:12

potassium 10:18,20,21

10:21,22,22 32:10

potatoes 32:3

potential 33:15

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134:11

poultry 118:5 184:6,13

185:16 187:2,11

198:5 199:6

pound 45:5,9,10

pounding 124:11

powder 20:14 21:2 22:7

22:11

powders 22:11

PPM 183:10

practical 42:14 75:8

177:20

practices 33:18 126:3

152:21 153:1 184:6

184:13 185:16 186:7

187:2,11

pragmatic 88:2 155:9

prana 162:2,5

pray 206:7

pre- 5:3

precisely 122:16

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premise 52:20 133:11

prepare 162:4

prepared 31:4 173:9

preparing 204:7

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presence 41:15

present 1:11 2:9 33:13

56:6

presentation 172:1

200:9

presiding 1:10

pressing 182:16 201:9

pressure 25:7 81:7,10

168:18

pretty 8:14 25:19 26:8

28:18 47:22 74:13

105:20 120:17 126:16

199:17

prevailing 62:4

prevent 114:18

preventing 6:10

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previous 73:12

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price 63:7 84:9 139:10

pricing 114:10

principles 111:18 134:7

printing 55:21

prior 13:1 179:1 188:2

priorities 180:15

199:11

probably 11:2 65:7

74:17 87:17 91:3 94:1

95:8 97:17 105:2,5,20

108:11,13 111:21

140:6 143:21 144:21

155:20 156:21 158:15

161:1 175:21 196:21

199:15

problem 67:4 99:16

123:19 124:1,11

126:14 131:5 138:2

problematic 45:20

problems 6:2 137:8,14

procedure 181:19,20

procedures 142:7

172:2 181:4,13

182:15

proceed 125:14 177:5

190:12

proceeding 23:16

process 7:13 11:1

46:15,20 50:2 88:11

89:1 112:9,10,12

126:21 167:3 168:13

168:16,21 171:11

183:4

processes 35:6 112:16

135:20

processing 118:5 193:5

193:7

processor 58:14

processors 185:22

187:9

produce 8:12 35:7

43:14 106:6,11,15

produced 11:1,5 14:8

53:22 63:5

producers 17:1,3 27:5

41:4,14 42:1 58:5,8

58:16 59:6 63:21

121:2 139:4 149:13

158:12 159:4 169:21

185:22 186:5,20

188:20 189:4

produces 43:13

producing 84:7

product 3:8 16:1,9 17:1

17:9 18:7,16,21 29:2

29:20 34:5 40:19

41:12 42:4 48:4 49:20

56:10 65:3 67:9 68:17

84:7,8 115:12 145:9

185:19

production 4:21 5:10

12:20 17:10 23:17

25:5 32:2,3 33:8

34:22 48:16 49:22

54:1,22 63:7 73:10

75:7,8,13,14,21 76:8

87:21 100:7 115:10

116:6,7,16 117:1

139:9 152:6 154:1,21

155:9 186:6 191:21

193:10

productions 33:16

116:7

productivity 33:10 96:9

153:14

products 5:9 7:6 8:16

23:7 26:14 27:7 40:9

40:17 53:4 66:3,7,12

90:16 169:20 186:10

professors 161:9,15

program 2:12,14,16,19

7:18 25:17 29:13

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191:11 203:19 204:3

programs 40:5

progress 174:5

progressed 121:9

prohibit 48:22 49:4

50:3,4 104:2 107:11

129:19 136:3

prohibited 54:21 55:7

55:22 56:4,12 57:4

prohibition 74:10,20

75:12

prohibitions 74:8

prohibits 77:15

project 114:7 181:10

projected 185:1

projects 196:3 198:1

promiscuity 64:19

promised 167:6

promulgation 185:11

proper 142:7 184:10

proposal 3:13,14 57:10

60:8 61:7,17 65:8,11

65:14 68:1,2,21 70:4

70:12 71:11 74:14

76:11 88:20 116:4

117:5 140:7,8 147:14

148:20 156:12,12

159:7 173:4 174:6

183:12,14 191:21

192:4 194:13,19

195:10 196:17,21

198:3,11 199:20

proposals 74:5 80:6

183:13,17 184:1

Proposals/final 3:18

propose 183:2

proposed 74:8 102:22

103:17 118:3 180:1

188:4

proposing 80:15 148:6

184:22

protect 63:22 188:19

protected 157:14

protecting 110:1

protection 28:8 69:5

protections 68:18

protects 109:18 141:1

proud 118:17

prove 86:3

provide 16:22 31:15,21

151:5 152:19,22

153:11 167:2,3

173:12 174:10 189:1

206:22

provided 26:15 166:12

provides 43:20 206:21

providing 42:20

proving 31:17

provisions 110:8

public 12:1,10 13:13

16:17,18 18:13 27:20

28:1,16 32:17 41:22

44:17 48:13 53:11

56:5 61:21 64:1 65:17

66:6,11 67:17 70:1

74:4,18 77:1 93:20

101:6 113:1 135:8

140:10 141:20 143:7

167:16 175:4,9

178:21 183:18 185:20

185:21 186:18 195:15

196:9 200:17,19

202:15,16 203:1,3

206:21

publish 49:16

published 92:15 183:13

198:7,16 203:6

publishing 206:16

207:3

Pueblo 109:6

pull 159:8 178:20

punished 62:22 63:3

purchase 186:10

purchased 64:17

purity 180:12,12 199:16

purported 162:16

push 58:16

pushing 81:1

put 17:4,20 22:11 25:17

39:2 41:9 43:1 44:12

51:22 63:19 74:9,10

75:12 76:1 89:9

104:18,22 119:10

125:8 133:21 144:8,9

148:19 149:4 160:5

170:3 177:14,16

179:8 180:1 181:18

182:13 195:14

putting 16:8 17:15 45:5

64:13 102:3 130:5

Q

quality 94:16

quandary 18:12 44:13

quantified 84:20

quantify 39:6 85:1,11

quantities 23:6 41:14

question 18:20,22

24:14,22 35:20 36:5

36:18 50:12 53:9

61:12 66:11 68:14

85:22 91:13 100:15

124:20 126:8 128:17

128:20 137:6 141:14

173:3,8 181:22 182:2

203:2

questions 6:21 12:8

17:19 18:5 19:11

24:12 28:21 30:11

32:18 35:14 44:3

54:14 57:7 70:3 74:2

75:3 93:22 95:10

107:9 122:18 124:15

125:6,15,18,19,21

136:17 159:13,19,20

173:15 175:19 180:19

181:15 182:19 183:20

187:1 195:13 196:1

197:15

quick 20:17 61:11

133:16

quicker 165:22

quickly 176:12 191:15

quit 79:20

quite 8:3 11:9 16:17

18:12 20:8 38:10

121:1 124:13 128:11

141:22 143:14 198:21

quote 98:5

quoting 160:14

R

rabbit 105:7

radiation 52:2

radionics 164:10

rain 13:4

rainfall 13:5

raise 89:21

raised 32:18 61:22

raising 176:16

ranchers 184:18 187:9

range 6:7 77:12 189:2,7

ranging 134:1

rarely 53:3

rates 186:14

ratio 85:15,15

raw 95:5

reach 27:16

reached 92:17

reaching 204:19 206:9

reaction 11:6

reactive 82:9

read 4:17 9:20 26:9

27:22 58:1 74:22

93:19 118:2 148:2,5

152:14 171:16,18

185:3 197:1 204:10

204:13

readily 8:14

reading 12:10 24:22

reads 62:10

ready 4:7 166:5 186:22

199:4 203:13

real 13:2 37:14 46:1

95:1 171:4,14 207:9

reality 88:2

realize 87:19 134:10

148:9 173:21 174:2

179:7

realized 84:5

really 6:4 15:6 17:3,6

20:4,6,7 30:3,8 32:17

33:7 36:1,4 37:12

38:5,10,11,11,13 42:8

43:12 44:14 46:21

47:6,7 48:16 51:2

55:6 57:1,16,22 58:17

75:4,21 76:5 77:11

82:5 90:7 91:1,5

92:16 94:11 97:15,22

100:12,19 101:4,21

101:22 102:16,19

103:3,9 104:1,3,9

106:1,7,18 107:13

108:2,7 116:13,21

121:7,12 122:5

123:15 126:22 131:1

131:11 133:18,21

134:2,8,20 135:11,17

135:21,22 138:14

143:13 145:22 149:10

151:15 153:16 156:9

156:11 157:3 159:17

160:8,13 161:22

162:22 164:8 168:2

169:11 171:11 175:6

175:7 188:1,12

201:13 203:15,18

reappear 163:13

reason 13:11 17:14,15

81:21 82:21 101:3

110:5 132:4 159:19

reasoning 35:5

reasons 17:16 73:21,22

101:7 189:1

recalcitrance 81:20

recalcitrant 34:12

81:17 82:15,15

166:14

received 23:18 164:21

197:14

receptivity 123:12

recess 72:2,5

recognize 93:14 96:6

98:16,16 188:17

189:21

recognizes 185:5

recommend 21:13
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recommendation 17:20

44:18 45:8,10 48:15

49:17 50:6 185:17,19

recommendations

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143:9 185:13 187:21

188:4

recommended 79:5

record 4:17 9:20 26:10

72:7 140:10

recreate 98:13

recreating 98:12

red 66:8,13 68:10

reduce 170:21

reduction 125:3 163:11

171:2

reductionist 115:2,18

reductionists 174:14

redundant 36:2 172:16

reemphasize 133:17

refer 60:7 70:12 74:3

reference 194:1

referenced 13:14

references 160:12

referred 33:19 61:8

71:11 191:22 192:4

reflect 112:19 189:19

reflection 160:1

regarding 53:11 128:15

174:10,11,12

regards 128:21 131:16

regionally 58:9

Register 41:9 43:1

206:17,20 207:3,8,10

registered 5:19

regs 90:6

regular 182:7,8,11,12

regularly 81:18

regulated 56:7

regulation 122:1 140:1

143:12,14 145:18,19

168:18,20 177:16

189:3

regulations 83:16 91:5

120:21 152:20 168:19

169:8 185:8 188:18

regulatory 9:8 73:17

74:8 177:14

Reiki 162:1

rejected 28:18

related 7:15 31:7 33:7

39:16 53:9 73:21

171:16 182:5

relates 31:19

relation 122:20

relationship 111:3

162:21

release 42:11

released 12:4

relevant 7:18

reliably 99:1

reliance 167:22

relies 153:22

religious 109:12

relist 19:1,2,3 43:9,9

relisted 20:7 56:4

rely 37:13 41:15 159:5

relying 144:1

remarks 3:2,20 200:10

201:20 206:15

remember 37:4 43:5

90:8 127:18 167:10

169:6

reminds 161:6

remove 54:2,7 96:5

removed 27:9

removing 36:17 138:17

replaceable 9:5

replanting 13:1

replicate 91:18

report 52:18 171:18

182:17 186:8

reported 78:9 79:4

reporting 123:18

reports 92:10

represent 86:19 87:3

99:10 135:17 149:10

155:5

representing 99:9

149:9,21 184:15

186:5 187:8

represents 150:10

reproach 193:19

reproduce 85:12

republicans 189:17

requesting 198:22

require 80:16 93:9

required 9:12 85:16

requirement 47:9 75:7

requirements 69:5

154:21 194:15

requires 78:7

requiring 48:2 58:14

rescind 16:14

research 18:2,8,18 28:4

29:1,4 92:13,15

161:16 163:18 180:15

183:16 199:11

researched 29:22

residing 7:17

residual 5:4,7

residue 18:4 28:11

153:3

residues 7:9 27:18,22

resilience 98:14 99:11

126:7

resilient 126:8 146:6

resistant 83:7

resolution 73:5 184:11

185:1 187:18 190:7

190:10,14 191:9

resolved 187:5

resolving 113:21

resonate 133:14 169:12

169:15

resource 169:16 207:6

resources 94:15

respected 17:7

respiratory 20:14

respond 156:8

response 44:11 73:18

124:6 146:12

responsibility 64:14

81:17

responsible 52:21

181:3

rest 47:11 195:18

restaurant 58:15

restore 100:2

restrict 22:9 40:4

restrictions 104:17

result 134:16

resulting 41:20

results 153:6

resumed 72:7

retail 58:15

retailer 106:12

retailers 184:17 187:9

retain 16:19

retaining 11:13

reverence 118:11,12

review 4:16 6:15 9:11

11:17 12:2 13:17 16:8

17:18,19 23:10 34:2

35:13 46:20 53:2,9

172:6 181:17 191:13

194:22

reviewed 4:12 27:2

53:5 200:14

reviewing 7:13 32:1

179:16 191:16

revision 181:7 192:10

revisions 181:5,11

200:4

revolutionary 132:22

rice 1:17 25:4,11 46:3

60:15 70:17 120:16

165:6 191:7,19

rich 82:2

Richardson 65:13

ricinoleate 11:1

rid 131:18 168:19

right 9:3,10 10:1,4,9

14:17 15:7 18:7 22:20

23:1 26:9 30:13,19

45:6 46:19 52:3 55:13

60:6,7 64:4 65:2,5

69:7 84:18 85:4 95:1

103:20,21 104:2

108:14 112:17 118:9

125:15,18,19 131:15

138:20 144:10,15,22

145:6 147:2,9 157:2

159:6 166:6 171:19

174:8 176:12 178:22

183:20 185:1 188:19

195:4,8 198:11 200:6

200:8

rigorous 62:15

ring 206:5

rise 131:20

risk 62:10

risk-based 62:19

roaches 20:2

road 164:5

roadmap 117:4

roadways 10:8

rockweed 69:17,19

rockwool 82:7

role 33:17 151:21

185:10

ROMERO-BRIONES

1:17 60:20 70:22

108:18,21 190:19

room 11:5 112:15

155:11

root 52:21 53:6,17

84:22

rooting 82:17

roots 162:8

rotation 138:19 146:5

round 103:19

roundtable 89:11

Roundup 136:21

routine 45:14

routinely 36:8

row 170:6

rude 205:5

Rudolf 163:1

rule 40:6 48:18 51:19

75:12 77:15 102:22

118:3 146:1 184:4,6

185:16 186:7,17,19

187:3,11,16 198:6,15

rulemaking 88:11

rules 94:12

ruling 69:22

rulings 69:18

run 12:20 91:6 136:14

138:3 166:9 191:15

runoff 11:20
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rush 157:1

rushed 157:16

S

safe 5:8 8:12 30:5 84:7

157:9

Safer 7:17

safety 7:19 9:3,7,8 43:3

171:1,5

Saint 206:4

salaries 125:7

sales 125:3

Salinas 7:4 169:18

170:19

salt 192:16

salts 3:11 10:20,21

54:17,22

sand 141:8 174:3

sandy 98:16,18

sang 204:16

sanitation 6:8

sanitizer 5:1

sanitizers 5:20 6:15

7:14 9:4

saponification 11:2

satisfy 134:16

satisfying 62:13

save 202:19

saw 58:4 164:20 166:9

saying 16:19,21 35:3

36:9 37:6 53:17 83:1

85:17 91:3 94:2

108:22 115:4 120:10

127:4 144:19 145:6

145:17 147:10,10

says 91:4 198:6

scale 151:18 154:20

scary 93:15

schedule 4:13

scheduled 179:2

193:12 203:1

scheduling 127:20

134:11 202:6

schizophrenic 91:9

school 126:13 161:8

schools 7:15

science 51:9 92:10,12

92:19 93:6,8 123:19

124:1,2,7 163:11,22

science-based 124:9

124:12

scientific 91:17,19

92:21 130:13 135:5

186:1

scientist 123:21 161:6

scientists 67:19,21

69:15 81:18 124:13

124:14 189:6

scope 193:22 197:11

Scott 1:17 25:2 46:2

65:10 66:20 70:15

113:6 120:15 123:8

191:18

SDBS 195:9

se 22:8

seal 83:15

searching 167:18

seat 207:4,6

seaweed 66:4,8

second 26:18 60:1,3,4

68:2 70:8,10 119:1

179:9 180:10 190:6

190:10 194:21 200:12

seconded 60:5 70:11

secondly 160:9

Secret 163:14

Secretary 1:14 184:20

185:14 187:1,10,18

189:21 191:11

section 4:19 14:7 47:16

48:18 51:19 52:7

54:19,20 56:21 62:9

74:10 106:15 115:5,9

174:7 178:15 184:2

191:17

sections 57:3

sector 100:5 104:22

see 6:15 10:2 14:20

16:10 19:6 22:16,18

25:6 36:3 38:3 43:9

48:1 58:19 66:15

67:14 72:20 74:3 76:7

76:7,12 79:16,17 81:2

89:19 100:10 103:5,8

103:10 104:3,6,9,19

105:1,9,11,12 106:2

106:19 107:19 115:3

119:2 127:13,14,15

127:19 128:2 132:10

133:19,22 136:9

138:7,11 139:4

140:22 142:22 143:14

147:11 150:9,16,17

150:18,19 152:3

153:21 154:15 155:8

155:20 156:11,13

160:17 161:2 170:19

181:18 183:17 188:13

192:8,9 194:18

199:20 204:18 206:8

seed 3:13 57:11 59:6

60:8 62:1 63:3,4

144:9 162:10 180:11

194:14 195:22 199:16

205:11

seeds 57:20 58:10,22

59:8

seeing 30:8 105:22

142:16 143:2,5

163:22

seek 185:12

seeking 57:20

seen 12:16 37:14 45:1

76:5 77:12 80:7

105:10 114:6,10

121:10,11 134:4

SEITZ 1:18 60:14 71:8

90:3 168:10 181:1

182:22 183:6 191:6

200:3

selectively 131:3

selenium 3:10 47:14,20

self 113:8

self-reliant 168:3

sell 119:13 139:18

selling 64:19 79:20

149:6

send 59:22 60:13 70:7

sending 59:12 71:18

sends 70:15

sense 22:4 172:16

176:1

sensitive 154:5

sent 88:20 195:22

196:4

sentence 41:2

separate 24:18 52:1

63:17 104:12 116:22

148:20 168:5

separately 75:11

separating 75:9 76:7

sequential 171:12

serious 32:18

seriously 94:18

service 125:5,9 207:5

services 126:2 170:12

171:7

session 4:5

set 75:6,19 85:6,6 93:3

94:13 116:14 117:8

166:18 186:7 192:14

198:6 204:22 205:12

206:12

settled 179:10

setup 86:7

seven 137:12

severe 46:1

sewage 52:2

shake 140:2

shallow 165:2

share 113:20,22 121:14

205:18

shared 114:1 121:15

203:11 204:1,3

sharing 137:10 206:14

Sheraton 1:9

shirt 163:21

short 177:9,10 184:6

204:10

short-term 140:17

shortly 203:6

shot 131:14

show 32:2,19 43:12

85:4 188:21 201:11

showed 11:18 103:16

113:15

showing 164:1

shown 11:19

shows 12:4 163:18

187:18

side 58:21 98:21 115:4

115:7 118:13,14,15

167:4 177:7

sides 78:14 79:16 93:18

115:3 150:5

significant 186:14

signs 41:5

silent 205:8

silicates 3:9 47:13,19

Silver 195:20

similar 21:3 132:8

202:15,22

simple 47:5

simply 92:13 101:2

189:22 205:8

sing 204:14,15

single 95:19 188:9

Siri 146:22

sit 184:15

site 142:4,10,16 143:5,5

site- 37:5

site-specific 43:19 46:7

sites 86:7

situation 67:13 69:12

94:3 129:19 169:4,5

situations 8:21 9:5

six 74:16

skin 6:1 119:19

slaughter 193:6

slides 182:20,21

slightly 113:10

slow 42:11

sludge 52:2

small 8:9 41:13 51:7

100:4 106:13 108:6,7

118:18,20 119:2

145:13 147:3 151:18

154:20

small-scale 8:18 150:9

150:20

smaller 150:2

smart 177:6
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smell 163:20

smoke 56:12

snakes 138:13

soap 10:21

soap- 6:19

soap-based 3:5 9:16

10:7,15,15 11:14 12:8

socialize 47:3

societal 92:18 109:11

society 109:18 131:21

163:7

sod 138:19

Sodium 5:15 193:2

195:12

soil 5:6 13:8 18:3,10,22

26:17,21 30:6,8,14

31:16,20,21 33:9 34:1

34:13 35:22 36:1

37:10 38:12 40:15

41:2,16 43:17,20,21

52:8,20 56:11 77:22

78:15,16,18,19 80:14

80:17,19 81:18 87:4

87:21 94:16,17 98:9

98:18,19 104:20

105:3,4,5 107:1 108:7

111:4 115:5,6,13,14

120:4 121:3,8 127:15

130:10 131:13 140:15

144:1,10,11 146:18

147:4 152:19,22

153:6,11 155:16,17

155:18 158:16 161:1

161:6 162:4,5,11,21

163:3,5 205:16

soil- 90:12 192:21

soil-applied 192:21

soil-based 11:19 79:21

100:21 107:1 133:20

144:11 172:5

soiled 73:10

soilless 73:9

soils 27:17 30:4 36:6

37:21 45:14 55:5

98:16 160:18,20

solely 153:18

solid 130:11

soluble 3:8 40:9,17

solution 63:15,15 82:2

88:13 115:21 165:20

solutions 114:15 128:8

somebody 59:17 63:2

99:9 129:12 138:1

164:9

somewhat 16:7 59:4

63:14 140:6

song 204:14

soon 207:9

sorry 9:21 14:2,16 31:1

50:4 56:12 67:20

102:17 108:22 146:10

146:21 158:22 160:1

179:6 183:1 190:8

191:12 193:4 201:22

sort 54:6 64:13 121:17

125:22 135:16 152:6

177:4

sorts 126:9

sounds 22:8

source 33:15 34:22

39:4

sources 34:4,9 52:15

52:15 149:8 153:4

sourcing 33:20 35:17

South 107:22

soybean 160:6

space 101:11 127:6,8

Spanish 126:13

speak 29:5 89:13,20

123:1 129:14 136:10

149:19 152:15 184:9

speaker 144:18

special 158:17

Specialist 2:12,18

specific 37:6 53:8,16

96:12 98:5 146:19

specifically 29:5 49:3,9

51:20

spectrum 87:4 99:19

121:18 129:1,4

146:17 148:10 150:5

151:17

speed 42:18 203:15

spend 77:6 141:16

spent 125:15,16 188:1

201:5

spiraling 123:22

spirit 121:12,22 141:12

152:13 162:15 168:14

split 78:22

spoke 147:22,22

spoken 109:2 136:10

spontaneously 184:8

spot 179:8

spray 25:18

sprays 25:18 27:15

205:1

spread 6:10

spreads 162:19

spring 103:15 156:14

156:19 196:2 205:8

sprout 5:10

staff 2:9 182:9

stage 130:8

stake 174:3

stakeholder 87:13

120:18 148:15 157:22

159:18 176:3 183:4,8

stakeholders 12:12

86:20 135:2,10,17

148:9 151:17 156:15

159:10 173:8,21

175:22 185:13 189:7

203:21

staking 88:14

stand 120:2 184:21

standard 16:12,21 67:7

67:11 75:14,21 76:3

85:6,20 152:5 154:17

177:15

standards 1:3 2:15

23:16 28:8 44:16 67:8

84:13,14 85:7,9 86:5

115:10 126:5 152:3

154:13 155:2 185:4,9

185:11 186:7 187:6

188:22

standing 188:3

standpoint 101:14

stands 186:22

start 39:22 60:12 70:14

108:22 110:21 116:14

116:16 128:19 146:19

199:5

started 72:3 118:8

130:5,7 138:16

145:17 151:14 158:7

starting 4:19 29:13

89:13 112:22 115:22

116:2 117:5 163:13

190:13

state 29:11 43:13 45:8

45:10 173:15

statement 68:16 113:11

146:15 173:3 182:3

statements 34:21

states 37:5 38:1 43:14

49:8

stating 73:5

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transition 33:17 38:4,5

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177:4,11 183:14

ways 10:9 12:13 13:7

67:15 109:18 198:9

We'll 10:4

we're 35:15 107:17

171:6

we-- 14:15

weakening 47:7

web 205:7

webinar 200:19

webinars 202:6

weed 10:6

week 107:10 188:9

weigh 54:11 114:4,14

131:8

weighs 132:2

weight 149:20

Weighty 113:13

weird 101:11

welcome 4:4 76:19

174:9 177:17

Welcome/opening 3:2

welfare 187:20 188:4

well- 17:6

went 72:7 126:12

weren't 132:20

western 163:7

wetlands 97:21 98:1,2

98:4,7

whatsoever 144:3

whichever 90:9

white 144:8 166:18,21

whoa 118:9 120:3

Wholesome 172:3

wide 6:7 77:12 151:17

wide-ranging 57:16

59:15

widely 6:6 54:8

wider 117:7 139:18

widespread 23:11,18

43:12 67:22

wife 138:3

wild 67:6 68:16,18 69:5

wildlands 97:21

wildlife 138:11 139:15

willing 199:5

willingness 117:15,18

win/lose 168:20

wise 205:4

wish 101:2 133:10

woke 94:21

wonderful 123:15 141:2

169:3 189:14 205:21

wondering 21:10 62:8

107:9

word 38:22 81:16 82:15

94:17 95:22 110:7,8

167:19

wording 181:18 182:14

183:3

work 3:19 6:8 7:2 16:14

19:4 39:15 54:4 57:14

64:8 65:13 66:22

67:14 71:19 87:7 92:1

97:13 124:3,4 127:11

129:14 136:13 156:3

157:18 168:16 169:19

174:17 176:8,9

178:12 182:6,10,11

191:14 192:5 198:22

199:4,13 200:4,7,14

202:5 203:13,20

204:4,6

worked 49:13 89:6

118:21 128:8 180:4

worker 7:10 28:8

workers 7:3,4,5

working 46:20 62:16

66:13 80:9 87:7,15

107:14 118:20 136:9

158:7 159:17 179:14

180:11 191:10 192:11

196:14 197:21 206:16

207:2,5

world 13:3 92:6 99:15

99:17 111:2 118:9

122:17 148:18 167:11

205:13

worms 97:17

worry 132:11

worth 54:6

wouldn't 75:15 93:7

wrap 179:1

wrapped 205:9

write 148:4

writers 192:13

written 16:18 68:1

171:15 190:10 200:17

wrong 83:18 164:8

wrote 204:12 205:6

X

X 101:10

Y

Y 101:10

yeah 19:21 24:21 25:4

25:12,14 26:2 31:2

39:21 40:1 45:19 46:3

51:12 57:13 89:3

100:5 102:17 172:22

173:13 187:22

year 13:3,4,4 18:8

23:11 45:9,11 63:19

81:14 96:14 181:13

year-round 90:16

years 18:8 38:5,9 42:16

44:11 45:7,9 87:8

96:14 97:6 98:3

106:10 121:5 133:2

137:20 138:7 141:4,4

141:5 143:12 164:5

165:9 205:1,2

Yep 72:1

yesterday 12:1 39:5

65:11 79:10 82:3

97:20 110:13 144:18

175:19

Z

Z 101:10

zinc 3:9 47:13,19

192:16

Zone 69:20

0

0 61:7 71:10

1

1 5:13 10:7 33:2

10 33:3 96:14 98:3,4

164:5

10:00 72:3

10:07 72:8

100 14:18 15:7,8,10

16:5 77:20 125:7

140:18 144:1 145:15

155:16 156:2

105 52:1

11 169:7

12 202:14

12:15 179:3

12:37 207:19

13 33:1

130 79:4

14 3:6

140 203:1

15 61:7 71:10 72:2

86:18 87:20,22 88:7

97:5 98:3,4 191:9

15-1 16:3

15-2 49:16

15:1 85:16

1550 1:9

16 164:2

1600 118:16

170 43:16

179 3:16

18 103:15 164:2

181 3:17

187 3:18

19 3:6 187:12 204:16

191 3:19

1995 55:21

2

2 5:14 14:5

20 18:1 104:18 137:20

200 3:20

2002 204:16

2010 81:21 116:3

2011 185:18 187:21

2012 35:1

2014 186:4

2015 4:12 27:3 40:21

41:11 52:18
(202) 234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

233

2017 1:7 187:12 198:3

2019 55:15 197:21

205 52:1

205.2 14:7

205.601 4:19

205.601(j) 40:12 52:7

205.601(j)(6) 47:17

205.602 54:20 55:16

207 3:22

21 1:7

215 32:16

22 3:7 11:12

23 107:16

24th 202:7,9,12

25 11:10,13 80:20

250,000 149:13

26 3:7

27th 202:8,10

29 40:21

2nd 206:19

3

3 5:15 33:2

30 3:8 78:10

31st 206:18

4

4 3:2,3,5

40 3:8

44 107:20

47 3:10

5

5 18:8

5-acre 152:1

5,000 78:12 106:13

5.105 74:11

50 80:16,19 133:1 205:1

205:2

52 3:11 118:19

54 3:11

55 3:12

57 3:13

6

6 3:5 40:13

605 68:22 69:6

605.04 115:9

606 68:22 69:6

65 3:14 81:13

6513 115:6

7

70s 161:7 163:14

72 3:15

75 149:12

8

8:1 85:16

8:30 1:9

8:33 4:2

80s 161:8

83 182:21 186:9

9

9:44 72:7

905 43:10

98-'99 117:22
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

234

Board Meeting

USDA National Organic Standards Board

04-21-2017

Denver, Colorado