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 UNITED STATES DEPARTMENT OF AGRICULTURE

 AGRICULTURE MARKETING SERVICE (AMS)

 NATIONAL ORGANIC PROGRAM (NOP)

 + + + + +

 MEETING OF THE NATIONAL ORGANIC

 STANDARDS BOARD (NOSB)

 + + + + +

 WEDNESDAY

 OCTOBER 27, 2010

 + + + + +

 The National Organic Standards

Board convened at 8:00 a.m. at the Best

Western InnTowner, 2424 University Avenue,

Madison, Wisconsin, Daniel G. Giacomini,

Chairman, presiding.

MEMBERS PRESENT

DANIEL G. GIACOMINI, Chairman

STEVE DeMURI

JOE DICKSON

KRISTINE "TINA" ELLOR

KEVIN K. ENGELBERT

JAY FELDMAN

BARRY R. FLAMM

JOHN FOSTER

WENDY FULWIDER

JENNIFER M. HALL

KATRINA HEINZE

TRACY MIEDEMA

JEFFREY W. MOYER

JOSEPH SMILLIES
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STAFF PRESENT

MILES McEVOY, Deputy Administrator, National

 Organic Program

MELISSA BAILEY, Director, Standards Division,

 National Organic Program

LISA BRINES, Standards Division, National

 Organic Program

MARK LIPSON, Organic and Sustainable

 Agriculture Policy Advisor, Office of 

 the Secretary

ARTHUR NEAL, Director of Program

 Administration, National Organic Program

EMILY BROWN ROSEN, Agricultural Marketing

 Specialist
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S

Call to Order - Dan Giacomini . . . . . . . . .4

Public Comment. . . . . . . . . . . . . . . . .7

Lunch Break . . . . . . . . . . . . . . . . .244

Public Comment (continued). . . . . . . . . .245

Adjourn . . . . . . . . . . . . . . . . . . .521
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1 P-R-O-C-E-E-D-I-N-G-S

2 8:06 a.m.

3 MR. GIACOMINI: If we can bring

4 the meeting back to order please. 

5 All the Board Members are in their

6 seats. Everybody in the gallery please find

7 a seat. And if you need to continue

8 conversations, please take them out in the

9 hallway.

10 Thank you.

11 Today is, I believe, entirely

12 public comment. We have a few items that we

13 need to accomplish before the meeting is over

14 that are not actually on the agenda.

15 Presentations and things we're going to hope

16 that was can get some of them in today. 

17 I'd like to encourage the Board to

18 try to have as much consideration and feeling

19 for what's going on. The same concern in the

20 morning session as they would for the late

21 afternoon session between 5:00 and 9:00 p.m.

22 We tend to be a little more freewheeling in
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1 the morning. It's not a problem. But then

2 there's times in the evening when some people

3 begin to feel that we shouldn't have -- should

4 cut people off in time or not ask questions

5 and that's not fair to them either. So, let's

6 try and be as consistent as possible. 

7 I do want to make one statement

8 regarding a statement that I made yesterday in

9 the sunset discussion on the time line for

10 resetting the sunset clock. I'm fairly sure,

11 I'm almost positive that a new listing for an

12 annotation change based on a complete

13 technical review would reset the clock. I'm

14 not sure if a re-listing based on a technical

15 correction would reset the clock. That may

16 not be considered a complete enough review by

17 the Board to reset it. But in my experience

18 of working with the government, it may be

19 determined that the re-posting of a new

20 annotation change is the re-posting of a new

21 annotation change and it's easier just to

22 start it over -- start the clock over. So,
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1 that may be something that would adjust what

2 I -- Miles?

3 MR. McEVOY: Yes, we looked into

4 that this morning and we could -- if there's

5 an annotation change during sunset we would 

6 just make it effective on the same date of the

7 sunset date so it would not reset the clock.

8 Just make it effective on the date -- the

9 sunset date. So, there's no need to reset the

10 clock if you change the annotation during the

11 sunset process. 

12 MR. GIACOMINI: Okay. Thank you.

13 We are ready to proceed -- are

14 there any other announcements or comments?

15 We're ready to proceed with public comment and

16 I have only the screen behind me to know

17 what's going on. So, Charlotte, Julie and

18 John in the hole. 

19 So, Julie, you will be --

20 Charlotte's first, you'll be going on this

21 podium. We have two podiums for the people

22 who were not here before. We're alternating
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1 speakers. It does create some discomfort and,

2 you know, hair on the back of your neck but

3 standing up for some of the Board Members

4 where someone is talking right behind their

5 head. We apologize for that. They would

6 prefer to be able to look at them in the face

7 and we understand that. We're trying this to

8 see how much we can expedite the process with

9 two podiums. But there's always the

10 constraints that you have to work with

11 regarding the layout of the room and the

12 length of AV cords. So, we're doing the best

13 we can. If this doesn't work with two podiums

14 we'll go back to one or we'll try to change

15 something else next time. But we're seeing if

16 we can proceed with this at this meeting.

17 Thank you. Go ahead. 

18 MS. VALLAEYS: Good morning. 

19 My name is Charlotte Vallaeys. I'm

20 with the Cornucopia Institute. 

21 First off I'd like to thank the

22 NOP for their April 2010 memo on Accessory
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1 Nutrients and I urge you to set a firm

2 deadline for companies to come into full

3 compliance, especially formula and baby food

4 manufacturers who are currently putting

5 Marteks DHA and ARA in there.

6 We've become involved in this

7 issue because it was brought to our attention

8 that DHA and ARA, hexane-extracted ingredients

9 from algean soil fungus manufactured by Martek

10 Biosciences Corporation are not found in the

11 National List who are nevertheless being added

12 to organic infant formula.

13 We soon discovered reports have

14 been filed with the FDA of adverse reactions

15 to formula with these additives. Diarrhea,

16 vomiting and other gastrointestinal symptoms

17 experienced by infants disappeared as soon as

18 they were switched to the exact same formula

19 but without DHA and ARA. 

20 I completely understand that one

21 of the major concerns is that by taking these

22 additives out of formula you are creating an
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1 inferior product and that organic babies would

2 be missing out. I understand that concern

3 because that's exactly how I felt three years

4 ago when I started gathering scientific data

5 on this topic. 

6 I was astonished to see a real7 life example of corporate interest influencing

8 science. Two independent scientists who

9 conducted meta-analysis studies published in

10 peer reviewed academic journals come to the

11 same conclusion. I will quote one of them.

12 "The results of most of the well-conducted

13 randomized clinical trials have not shown

14 beneficial effects of DHA and ARA

15 supplementation of formula milk on the

16 physical, visual and neuro-developmental

17 outcomes of infants." Dr. Beyerlein in

18 January 2010, Journal of Gastroenterology and

19 Nutrition, a completely separate independent

20 study review comes to the exact same

21 conclusion. 

22 Scientific data does not support
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1 the hypothesis that adding DHA and ARA to

2 infant formula is necessary or beneficial for

3 infant development. And this is why neither

4 the FDA nor the American Academy of Pediatrics

5 has recommended it. Why then are we led to

6 believe that DHA and ARA are necessary and

7 beneficial? Because it's a great marking tool

8 and scientific data has been interpreted in

9 such a way that it leaves mothers to believe

10 that they have to buy the more expensive DHA

11 supplements in formula. 

12 One example, again, just don't

13 take my word for it. A study led by a

14 scientists from Abbott Laboratories which

15 makes Similac formula found no benefits to

16 adding DHA and ARA. Yet in an article

17 published in Pediatrics they write --

18 MR. GIACOMINI: Charlotte, could

19 you please refrain from using company names? 

20 MS. VALLAEYS: Oh, okay.

21 MR. GIACOMINI: Thank you.

22 PARTICIPANT: No, Mr. Chairman, I
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1 need to hear --

2 MR. GIACOMINI: No. You're not

3 even at the podium now, Mark, so please sit

4 down. No. You're out of order. You're out

5 of order, Mark.

6 MS. VALLAEYS: Okay. This is a

7 public meeting and apparently I have the right

8 to say whatever I'd like. 

9 MR. GIACOMINI: We are asking you

10 to -- you can state your issues, you can make

11 your points, but this is a public meeting. 

12 It's on the public record. We are not a jury. 

13 We're not a court of law. We're not any of

14 those things and we just -- we would

15 appreciate if you would please not use

16 specific company names and which would be

17 viewed as that type of an attack. That's all

18 we're asking. 

19 The full policy is fine. Okay.

20 Miles?

21 MR. McEVOY: Yes. I don't see why

22 they can't mention company names. If it's in
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1 the public record, why can't they mention

2 company names? You're making the request that

3 they don't but I don't see -- this is a public

4 comment period. They're able to express their

5 opinions. 

6 MR. GIACOMINI: Okay. The Chair

7 has been overruled by the program. Please

8 proceed.

9 MS. VALLAEYS: The conclusion from

10 this article was they intentionally misled

11 pediatricians into believing that the

12 researchers found benefits they didn't. 

13 As Will mentioned on Monday, the

14 infant formula manufacturers got these

15 additives into organics by lobbying the former

16 head of the NOP who then overruled her staff

17 which had concluded that they were not allowed

18 in organics. 

19 This story that I just told of

20 hexane-extracted additives, insider lobbying

21 to bypass federal regulations, corporate

22 interest influencing science to get people to
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1 spend money on things they don't really need.

2 All of that sounds like it's part of the

3 conventional food system. Organic is supposed

4 to be an alternative from that.

5 One mother, Suzanne Stock, gave me

6 permission to share her story with you. She

7 knew about the possibility of DHA causing

8 adverse reactions so she always bought Baby's

9 Only organic formula for her daughter which

10 does not contain Martek's oils. 

11 When the family ran out of formula

12 she sent her husband to the store. And he

13 knew enough to look for the organic seal. But

14 he picked up a different kind of formula which

15 is organic but contains Martek's oils. 

16 Their daughter experienced

17 diarrhea pretty much right away after drinking

18 her first bottle of this formula with DHA. And

19 it disappeared again immediately when she was

20 switched back to the Baby's Only formula.

21 Suzanne's husband was right about

22 choosing formula with the organic seal and
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1 such incidents should not happen to organic

2 families. Please keep unnecessary and

3 potentially harmful ingredients out of the

4 organic food supply.

5 The standards as written are fine,

6 allowing vitamins and minerals which by the

7 way includes Vitamin K but do not open the

8 door to just about any synthetic accessory

9 nutrient out there.

10 Thank you. 

11 MR. GIACOMINI: Thank you. We do

12 have one other announcement that I would like

13 to request. We have an additional

14 videographer in the room and if you could find

15 a program microphone I'd like you to please

16 state who you are so that we know -- or

17 actually the microphone there with the podium

18 Julie is at. Just state who you are and why

19 you're here. 

20 MS. SHILL: Hi. I am Donna Shill.

21 I'm a University of Iowa student and this year

22 I'm working on my Master's project studying
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1 organic farmers in Iowa actually. And I

2 thought it would add to my project to see how

3 decisions are made and was excited that you're

4 doing a meeting in the Midwest. So, that's

5 why I'm here.

6 MR. GIACOMINI: Joe. 

7 MR. SMILLIE: Your focus on the

8 issue is that the hexane extraction that you

9 feel is the problem or the AHA/DHA? 

10 MS. VALLAEYS: The hexane

11 extraction is how this issue was brought to

12 our attention initially. Right now the hexane

13 extraction is not the focus. 

14 MR. SMILLIE: Okay.

15 MS. VALLAEYS: It's the fact that

16 an accessory nutrient not on the National List

17 which says vitamins and minerals was put into

18 organics and so that's why we're asking the

19 NOP to take enforcement action because we do

20 believe that right now they can do that based

21 on what the standards currently say. 

22 And, second, asking the NOSB to
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1 clarify that it's vitamins and -- vitamins and

2 minerals, but if you open the door to -- by

3 adding accessory nutrients to that, you would

4 open the door to -- I mean, if anything that's

5 FDA GRAS can be in organics which I know some

6 people have argued for it, you open the door

7 to just about anything out there. 

8 MR. SMILLIE: Well, just to follow

9 up. I think we're clarifying what the

10 intention of the 1995 recommendation from the

11 NOSB to the program was and my understanding

12 is that it was allowing accessory nutrients.

13 So, I don't think it's necessarily opening the

14 door. The door may be open, although that's

15 what we're trying to clarify whether that door

16 was opened or not. 

17 So, if an extraction of AHA from

18 an algal organism, you would still -- that

19 wouldn't change your opinion on the product

20 then? I'm just trying to --

21 MS. VALLAEYS: I'm sorry?

22 MR. SMILLIE: If there is a non-
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1 hexane extraction of AHA/DHA from algal

2 sources in algae, that wouldn't change your

3 opinion on this?

4 MS. VALLAEYS: It -- I think if

5 it's an accessory nutrient I think it would

6 still need to be individually petitioned for

7 inclusion because currently the rule does

8 refer to 21 CFR 104.20. And meaning, it needs

9 to be required by the FDA, right, which this

10 isn't. Or it says recommended by an

11 independent professional organization, which

12 again I think you're going to run into

13 problems because what is an independent -- you

14 know, the American Academy of Pediatrics has

15 not recommended it. So, you know, it is an

16 organization that has some funding from the

17 industries that are independent or not because

18 that, again, is going to get very tricky. 

19 MR. GIACOMINI: Tracy. 

20 MS. MIEDEMA: Thank you, Mr.

21 Chair, and thank you, Charlotte, for sharing

22 your thoughts with us again.
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1 There seems to be two issues each

2 time you've got up and given testimony. One

3 is the legalistic argument that nutrient

4 vitamins and minerals don't include accessory

5 nutrients. And we're really working hard on

6 that to understand exactly what is and is not

7 allowed and what was the intent of 95 and how

8 we're going to move forward. 

9 It seems that there's another

10 issue that you persistently bring up and it's

11 this implication that people in this room

12 don't care about babies. And that there is

13 some sort of deliberate lack of care or love

14 for babies. And that, you know, that there's

15 even a machine that's working against babies.

16 And since you have put on the record, you

17 know, about these companies deliberately doing

18 things, I'd like to put on the record that

19 this room is just chock full of parents who

20 love babies and have absolutely no intent with

21 any of our discussions to ever do any harm.

22 And I wondered, do you take this argument to
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1 American Pediatric Association because I

2 assume you care about all babies, not just

3 organic babies? And if these are really true

4 concerns about baby formula, it seems like

5 it's a much bigger question mark than an

6 organic question. 

7 MS. VALLAEYS: Definitely. First

8 of all, I know from experience that this room

9 is indeed full of people who love babies. I've

10 experienced that over the past couple of days. 

11 So, by no means am I, you know, would I by

12 what I'm saying that people don't love babies

13 and that it's intentional. I don't think that

14 at all.

15 Your second point. Yes, we have

16 done that. We are very concerned and this is

17 not just an organic issue. It's an issue for

18 all babies out there and, in fact, our Board

19 has questioned why as a farm policy group are

20 we getting involved in childhood nutrition by

21 doing things like, you know, we have contacted

22 the formula makers. We have shared these
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1 reports with them and these are formula

2 manufacturers who are not even involved in

3 organics. And so we are working on the issue

4 of these adverse reactions in general, not

5 just in organics who are certainly involved in

6 that. But at the same time, as a farm policy

7 group we have to focus on the organic issue.

8 MR. GIACOMINI: Further questions?

9 Okay. Thank you, Charlotte. 

10 Next up, Julie, John and Jim. I'm

11 trying to get this document from Lisa and

12 hopefully I'll just be able to just have it on

13 my screen here in a bit if we can get that

14 together.

15 Julie is next up. This reminds me

16 of another request I had yesterday. Just very

17 briefly, Julie is a former NOSB member. Went

18 off the Board this last year. I was able to

19 spend four years with her. The request was,

20 could we have all former members of the NOSB

21 and NOP staff that are in the audience to

22 please stand up so that we can all see who you
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1 guys have all been over the years. There we

2 go. 

3 (Applause.)

4 I think there were a lot more of

5 them two days ago. We've had a few additions

6 this morning and yesterday. Welcome. Thank

7 you for coming back and back to public

8 comment.

9 Julie.

10 MS. WEISMAN: Those other former

11 members are sleeping late because they can

12 nap.

13 Hello, everyone. I actually -- I

14 don't have to say who I am now because Dan

15 just introduced me. But I will. My name is

16 Julie Weisman and, yes, I am a former NOSB

17 member. And I thank you for this opportunity

18 to address you.

19 Now that I no longer have to worry

20 about conflict of interest in this room I am

21 finally free to speak on behalf of my

22 companies which I guess I can mention, Elan
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1 Vanilla and Flavorganics who began producing

2 certified organic vanilla extracts,

3 concentrates and flavors in 1996 for both

4 commercial and retail use.

5 As a former member of the NOSB,

6 who participated in the first sunset review,

7 I'm acutely aware of the effort you are making

8 on behalf of the organic industry and of the

9 task before you.

10 At this time, I specifically wish

11 to address the matter of the continued listing

12 of flavors non-synthetic on 205.605(a). I'll

13 ask you to refer to my written comments for a

14 more detailed description of the growth of

15 organic flavors and I apologize for not having

16 a copy in front of all of you. The toner in

17 the business center wasn't doing so well at

18 2:00 this morning.

19 But for now, suffice it to say

20 that in 14 years we have gone from one

21 manufacturer that were my companies to what

22 according to one certifier's recent estimate
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1 is 30 certified operations offering 1,500

2 different flavor formulations. It seems as if

3 this ought to meet anyone's definition of

4 commercial availability. Yet despite the

5 breadth of certified organic flavors now

6 available, many certified organic food and

7 beverage makers do continue to use what are

8 called in the flavor industry, NOP-compliance

9 flavors, aka flavors non-synthetic. 

10 I'm starting to sound like a hop

11 grower right now, right? But it would be

12 difficult to discover the exact percentage,

13 but go with Katrina the next time for a trip

14 down the grocery aisle and you'll see.

15 As long as the current listing of

16 flavors non-synthetic remains unchanged, and

17 it's the current position on 605(a) where they

18 are immune from commercial availability

19 requirements, there is little motivation for

20 some -- there's no motivation for some makers

21 of organic products to switch to certified

22 organic flavors. And I say some because there
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1 are certainly organic product makers who have

2 always gone beyond what is required and it was

3 one such maker that actually pushed my company

4 to develop organic extracts in the first

5 place.

6 So, anyway, there's a strong case

7 to be made for allowing flavors to sunset from

8 the National List. But that is not what I am

9 here to do today. I am here to support the

10 handling committee's recommendation to relist

11 flavors non-synthetic. What? Is she crazy?

12 Why would she do that? Here's why. I'd like

13 to bring to the attention to the NOSB, the NOP

14 and the organic industry a little known fact

15 for your consideration. 

16 Most, though not all, certified

17 organic flavors make use of flavors non18 synthetic as is currently listed within five

19 percent of nonorganic ingredients that are

20 allowed. 

21 If flavors were to sunset

22 completely with no other accompanying rule
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1 change such as, I mean, additions to the

2 National List, the vast majority of currently

3 certified organic flavors would need to be

4 reformulated in such a way that organic food

5 makers and consumers would find the flavor

6 profiles of their products substantially and

7 negatively altered.

8 Given that this is the case, there

9 are two -- not only but I would like to

10 outline two possible courses of action. 

11 One, allow flavors non-synthetic

12 to sunset requiring flavor manufacturers to

13 petition 100 to 200 individual flavor

14 ingredients onto 605(a), (b) and 606 in order

15 to avoid a major disruption to organic

16 commerce. And requiring the NOSB to consider

17 those petitions. So, dropping -- the zeal to

18 drop one item from the National List would

19 prompt potential addition of hundreds of new

20 items in order for commerce to continue. And

21 in order for the demand for organic

22 agricultural products to continue, more
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1 importantly.

2 Both options require that the

3 industry petition the NOSB for either the

4 addition of new materials or a change of

5 annotation. And yesterday's discussion on

6 Sunset Review policy notwithstanding. I wrote

7 these comments before that discussion

8 happened.

9 So, the first option. Sunset date

10 of October 2012 seems far enough away to allow

11 time to bring the necessary petitions before

12 the Board. But it would be a huge gamble. You

13 know, most of you, the amount of time it takes

14 to consider the volume of petitions that would

15 have to be generated for a 100 flavor

16 ingredients to be placed on the National List.

17 And so for this reason I believe the second

18 alternative is the best way to raise the bar.

19 So, please refer to my written

20 comments for more detail. I do want to end by

21 making two offers. It's my intention to bring

22 such a petition, either individually or with
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1 a group before the Board, and I volunteer to

2 participate and would perhaps even be willing

3 to co-chair any working group that might be

4 formed to do a more thorough review of the

5 category as you described in your

6 recommendation.

7 MR. GIACOMINI: Thank you.

8 Questions, comments? 

9 Steve. 

10 MR. DeMURI: Julie, thank you very

11 much for your comments and as you and I have

12 talked in the past, flavor has been on our

13 work plan for, you know, a couple of years

14 now. Kind of on the back burner. Now that

15 we're getting through all these sunset items,

16 it will rise to the top -- near the top at

17 least. So, I appreciate your offer to help us

18 with that because we will definitely take you

19 up on that.

20 MS. WEISMAN: Thank you. 

21 MR. GIACOMINI: Julie, in your

22 experience on the Board would most of those
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1 substances that you would look at that would

2 need to be added, especially because of their

3 processing and everything else would require

4 a TR? 

5 MS. WEISMAN: A lot of them would.

6 MR. GIACOMINI: Okay. 

7 MS. WEISMAN: Yes. 

8 MR. GIACOMINI: That's also a

9 substantial factor.

10 Any other questions/comments? 

11 Katrina. 

12 MS. HEINZE: I just wanted to

13 thank you, Julie, for helping to articulate

14 why flavors is complicated. Not being a

15 flavor person, it's been hard for me to

16 explain. So, I really appreciate the

17 perspective that you brought. 

18 MR. GIACOMINI: Comments and

19 questions? Are we ready on the next podium

20 please whoever is -- oh, there you are. I'm

21 sorry. I didn't see you sitting there. 

22 MR. PECK: That's fine. 
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1 MR. GIACOMINI: Thank you, Julie. 

2 So, John, Jim and then Richard. 

3 Go ahead, John. 

4 MR. PECK: My name is John Peck.

5 I'm the Executive Director of Family Farm

6 Defenders. We're a national group based here

7 in Madison. We have about 5,000 members in

8 all 50 states, Canada and Mexico. And we've

9 been involved with defending organic integrity

10 since the founding of our group years ago. We

11 were one of the first group to oppose bovine

12 growth hormone and the attempts to put bio13 tech into the organic standard way back when.

14 I was here mostly to speak on

15 three different topics. One is the organic

16 hops concern. We have many growers here in

17 Wisconsin now going into organic hops and

18 they're very concerned and now I guess it's

19 okay to mention corporations. Anheuser Busch,

20 just because they're the largest beer brewer

21 in the world should not be dictating organic

22 hop rules at the Organic Standards Board. 
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1 There are going to be organic hops

2 available. We should not make a loophole so

3 they can find other hops. 

4 On the issue of nanotech. We're

5 very concerned that nanotech is even being

6 considered. It should not be approved at all.

7 We've had the same problems, the substantial

8 equivalence arguments that Michael Taylor

9 brought up at the FDA years ago for biotech.

10 Nanotech is not -- should not be approved at

11 all. They already are using two million

12 pounds of titanium dioxide in our food supply.

13 Under the GRAS rules, GAO came out with a

14 report in February showing that GRAS is a huge

15 loophole for food safety concerns in this

16 country.

17 The European parliament is

18 considering a ban on nanotech in all food. We

19 can kiss organic exports goodbye if we put

20 nanotech into our organic food. So nanotech

21 should not be even on the plate for

22 consideration by this body. I hope you reject
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1 any further discussion of nanotech as part of

2 organic.

3 The last point I want to bring up

4 is pasture rules. Many of our farmers, our

5 organic dairy farmers, some of them are

6 pioneers of the organic dairy movement in

7 Wisconsin. They are very concerned about the

8 pasture rule not being adequately enforced.

9 Still is not being adequately enforced. We've

10 been trying to get enforcement for years. 

11 Cows eating chopped food on a

12 concrete tarmac is not grazing. Lactation is

13 not a stage of production. That should be

14 exempt from organic rules, including pasture

15 access. And now we're dealing with the same

16 situation with eggs and the poultry industry.

17 I grew up on a farm in Minnesota.

18 I was one of the investigators for Cornucopia

19 on this report. I went and visited farms. I

20 was very proud to find large-scale organic egg

21 producers in Minnesota who are using pasture.

22 You saw some of the photos I took yesterday
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1 apparently at the Shultz Farm near Owatonna.

2 He as 5,000 chickens out on pasture. It's not

3 a hobby operation. But he is being driven out

4 of business by fake organic production

5 facilities. His eggs go all the way to Texas

6 he told me. North Dakota, Minnesota,

7 Wisconsin, Texas. So, that is not a hobby

8 farm. But, unfortunately, as long as they

9 don't enforce genuine organic standards in the

10 poultry industry in egg production, he is not

11 going to be able to stay in business. And I

12 spent over two hours talking with him about

13 the struggles he has.

14 He has been in organic egg

15 production for a long time and we need to

16 really respect the hard work of these farmers.

17 I mean, I grew up on a farm. I did pasture

18 chickens as a kid. That's how I made money

19 for FFA. It's work, but we need to give these

20 producers a fair shot at the marketplace. And

21 by not enforcing these pasture rules, not

22 enforcing, you know, standards, it just makes
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1 -- it really jeopardizes consumer confidence

2 and integrity to the organic standard.

3 And I was in Copenhagen in

4 December, the Climate Change Conference. And

5 sad to say, a lot of Europeans -- their

6 opinion of U.S. organic is not as good as it

7 once was. And that's unfortunately a market

8 we'd like to be involved with. If you have

9 any questions. 

10 Thanks for the opportunity to

11 speak today. 

12 MR. GIACOMINI: Questions,

13 comments?

14 MR. SCHAHCZENSKI: Yes, just for

15 the record, while we're bashing everybody

16 these days.

17 Anheuser Busch doesn't produce an

18 organic beer anymore. I don't really drink

19 their beer and I'm not a big Anheuser Busch

20 fan. But they had nothing to do with this

21 issue. In fact, Anheuser Busch signed on to

22 the hops petition for organic hops just to
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1 make the record clear. 

2 MR. PECK: Well, that's after they

3 had gotten -- I'd talked to some independent

4 brewers here in Wisconsin. They said that

5 they were pushing -- they wanted to have a

6 loophole originally and then they got pressure

7 and maybe they changed their mind. But that's

8 not what I heard from talking to microbrewers

9 here in Wisconsin. 

10 MR. SCHAHCZENSKI: Well, we got

11 the original petition and it wasn't from

12 Anheuser Busch as was falsely reported. It

13 was from a smaller organic brewery but anyway

14 --

15 MR. GIACOMINI: Joe, there were --

16 there were two petitions for hops submitted to

17 the program which in 2007 -- 2006/2007. One

18 of them was from Anheuser Busch but it was

19 never deemed to be complete. It was not

20 presented to this body. And it was not what

21 we reviewed to put hops on the list and I

22 don't even -- I don't recall but I'm not aware
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1 that Anheuser Busch had any public comment on

2 this or made any statement at all that

3 influenced this Board's decision in any way.

4 MR. PECK: Okay. Well, that's

5 reassuring but I'm still concerned about

6 what's happening in the industry.

7 MR. GIACOMINI: Miles. 

8 MR. McEVOY: Yes, just a comment

9 about the EU organic standards. There is some

10 perception in Europe that the U.S. standards

11 aren't as strict, but that is a misconception.

12 U.S. standards are much more strict than the

13 European standards in terms of European

14 standards allow antibiotics in nonorganic feed

15 for livestock production and they certainly

16 don't have anywhere close to the oversight and

17 enforcement capacity that the NOP has. So, I

18 just want to put that into the record. 

19 MR. GIACOMINI: Further questions?

20 Okay. Thank you. 

21 Excuse me, Jim. Jim, Richard and

22 Jeff in the hole.
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1 MR. RIDDLE: Thank you. Thanks

2 for the opportunity to comment.

3 My name is Jim Riddle. I work as

4 Organic Outreach Coordinator, University of

5 Minnesota. I also was an organic inspector

6 for 20 years and founding chair of the Organic

7 Inspectors Association and served my term on

8 the Board. Thanks for the acknowledgment of

9 that.

10 And, first, I'd just like to thank

11 the outgoing members for your service and to

12 all the NOSB members for your hard work

13 leading up to this meeting once again. You'd

14 think it would get easier but it doesn't.

15 I was going to comment on hops but

16 it appears the Board is doing the right thing

17 so I'll just say cheers on that one. But I

18 will comment on the corn steep liquor and it's

19 not in my written comments.

20 Just a couple of things on that. I

21 think the Board should really focus on the

22 first part of the definition of synthetic
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1 that's in OFPA and the NOP and that is a

2 substance that's formulated or manufactured by

3 a chemical process or -- you're focusing on

4 the chemical change aspect. The first part

5 is, is it manufactured by a chemical process?

6 I think everyone can agree that, yes. Corn

7 steep liquor is manufactured using a chemical

8 process. And the analogy is not hair or

9 holding hands but fish. Fish emulsion. It's

10 on the National List. It appears natural. You

11 could soak fish in water and have fish

12 emulsion. But once you've added an acid it

13 became synthetic and had to be petitioned and

14 on the National List. It's a direct analogy

15 to what you're considering today.

16 I did submit some comments to the

17 Livestock Committee on apiculture draft which

18 I really appreciate. I had chaired the

19 working group that did the initial work on

20 that. I think you've done some excellent

21 improvements from that original work. Have

22 some specific language changes. I'm
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1 suggesting -- I'm not going to go through

2 those orally right now except to say I do

3 think there should be a clear prohibition on

4 maintaining organic and conventional hives at

5 the same BER. That's not in the draft and I

6 think it would strengthen it and be a good

7 step to prevent contamination and potential

8 co-mingling.

9 On the nanotech, for the Materials

10 Committee, a few issues with your draft. I

11 think it's really good work. You say in there

12 that the nano materials are synthetic

13 particles that should be prohibited. Well as

14 synthetic materials they actually are

15 prohibited. And I would ask that you correct

16 that. Not that they should be. They actually

17 are prohibited and in the draft there's no

18 mention of language that's both in OFPA and

19 the Rule pertaining to packaging materials,

20 storage containers and bins. They're

21 prohibited if they contain synthetic

22 fungicides, preservatives or fumigants. And
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1 the nanomaterials if added to packaging would

2 be added for those functions so they're also

3 prohibited in packaging if those are

4 functions. And I just on your current draft

5 I suggest one change on the second to last

6 bullet point where it says "whether compliance

7 is possible." Change that word "whether" to

8 "how" compliance is possible. And that's a

9 summary.

10 I guess, you know, I was reading

11 through all the draft recommendations and

12 everything was going fine until I hit the one

13 from the CACC creating this new label -- front

14 panel label claim "certified to USDA

15 regulations." Now it's been changed. I

16 really feel that that is deeply flawed and

17 should be either removed, tabled or rejected.

18 It's based on some really quite

19 unsubstantiated claims that should be

20 substantiated if they are indeed true. It

21 says that most organic producers have chosen

22 to use the USDA's seal. Well, in the Midwest,
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1 most organic products are actually, you know,

2 being sold by farmers are bulk commodities.

3 Grains, beans, milk. They don't carry the

4 USDA seal. And a lot of the organic producers

5 at farmers markets don't display the USDA

6 seal. So, there would need to be some factual

7 analysis to back up that claim. 

8 It also says that the actual size

9 of the organic products market is

10 underestimated due to the amount of Made with

11 Organic products that are sold without any

12 substantiation. And I would posit that the

13 opposite is probably true where a lot of made

14 with products are being counted as organic.

15 And if you shift to giving the made with

16 category this front panel status of saying the

17 word "USDA" you're going to have manufacturers

18 moving more to that because they can cash in,

19 sell at a higher price without going to the

20 full USDA organic level. 

21 MR. GIACOMINI: Questions,

22 comments, John.
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1 MR. FOSTER: Thanks, Jim for

2 pointing out that the Materials Committee

3 recommendation closes the door on nanotech by

4 calling it synthetic. Thanks for pointing

5 that out. 

6 Also, I have a question. When

7 juice manufacturers use ascorbic acid, right,

8 which is a synthetic on the National List, is

9 that in your opinion -- I think this is yes or

10 no. I think. I am phrasing it that way on

11 purpose. Is that juice synthetic as a

12 function of the addition of synthetic ascorbic

13 acid? 

14 MR. RIDDLE: Is it being used as a

15 farm input because that's really where the

16 synthetic/non-synthetic paradigm applies. It

17 depends on the use. 

18 MR. FOSTER: We will get to that

19 question later. My question is, is that juice

20 synthetic by virtue of the use of synthetic

21 ascorbic acid, in your opinion? 

22 MR. RIDDLE: I don't have an
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1 opinion on that. I'd need to know more

2 information.

3 MR. FOSTER: Okay. Thanks. 

4 MR. RIDDLE: How it's going to be

5 used. 

6 MR. GIACOMINI: Questions,

7 comments? 

8 Okay. 

9 MR. FELDMAN: Thanks, Jim.

10 I guess I need to return to your

11 question, John, about closing the door by

12 virtue of defining nano as synthetic. Is that

13 a correct characterization of what it is?

14 MR. RIDDLE: Well, I think if the

15 recommendation were strengthened and the

16 language cleaned up a little bit I think it

17 would for the time being take the steps

18 necessary to close the doors. But, yes, we

19 need a lot more training information,

20 knowledge to keep that door closed. But I

21 think it's a good first step and sends the

22 right signal if it's tightened just a little
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1 bit. I think it sends a signal to consumers

2 that nanotech is not allowed. 

3 MR. FELDMAN: Can I have another

4 question please?

5 MR. GIACOMINI: Yes.

6 MR. FELDMAN: Thank you. 

7 You mentioned the fish emulsion. I

8 love the analogies. We're all looking for a

9 clean analogy that we can relate to on this on

10 the CSL issue.

11 Do you think that the effect of

12 that decision if it were to be deemed non13 synthetic would cause other previous decisions

14 to have to be reversed such as fish emulsion?

15 Are there any other examples? 

16 MR. RIDDLE: Well, I think fish

17 emulsion sets the precedent for something that

18 appeared natural but in analysis was deemed

19 synthetic and therefore -- and then went

20 through the review process and appeared on the

21 National List. So, it's clear to everyone

22 that it is allowed. 
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1 So, I don't think it means you go

2 back. You deal with the topic at hand but the

3 precedent is already there with fish emulsion,

4 aquatic plant extracts, other things that

5 start off natural but some acid or base has

6 been added.

7 MR. FELDMAN: Well, I guess, we

8 rely heavily on previous Board decisions. It

9 seems to be the default in a lot of our

10 decision-making but if, in fact, this Board

11 were to set the precedent of defining corn

12 steep liquor as non-synthetic, even though

13 we're adding a synthetic into the

14 manufacturing process, would that -- for

15 consistency sake, would that at least require

16 to some degree us revisiting these issues

17 around fish emulsion and other extracts? 

18 MR. RIDDLE: It would reverse the

19 precedent. You know, I can't predict what it

20 would take to revisit but the precedent has

21 been set.

22 MR. FELDMAN: But you say it would
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1 inconsistent. 

2 MR. RIDDLE: It would be

3 inconsistent for sure. 

4 MR. FELDMAN: Very good. Thanks.

5 MR. GIACOMINI: Jim, I don't know

6 if there's any other questions.

7 Could you for the sake of our

8 time, could you please get at least to me

9 those references in OFPA and the Rule

10 regarding packaging and bins and all that kind

11 of stuff? The specific notation?

12 MR. RIDDLE: They are in the

13 written comments I circulated. 

14 MR. GIACOMINI: Okay. Ill try to

15 pull that out. 

16 MR. RIDDLE: In Point Number 3.

17 You mean as it applies to nanotech?

18 MR. GIACOMINI: Yes.

19 MR. RIDDLE: Yes. They're right

20 there.

21 MR. GIACOMINI: Okay. All right. 

22 Good. 
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1 MR. SCHAHCZENSKI: Hold on, one

2 more question. 

3 MR. GIACOMINI: Save my sanity. 

4 But a couple of the other corrections aren't,

5 Jim. 

6 MR. RIDDLE: Right. How rather

7 than the whether?

8 MR. GIACOMINI: Right. I was

9 hoping, Joe, that Board Members --

10 MR. RIDDLE: I think we can find

11 that one. 

12 MR. GIACOMINI: We can find that

13 one and, yes. Okay. Yes. It's just that the

14 annotation, I mean, the citations that I'm

15 concerned with not having to read through 300

16 pages tonight.

17 Jay. 

18 MR. FELDMAN: Thanks. Another

19 question on sunset. Given your vast

20 experience dealing with these issues, what's

21 your sense of the sunset proposal and moving

22 forward on that?
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1 MR. RIDDLE: Yes. Unfortunately,

2 my time sunsetted before I got to that issue.

3 But I was on the Board when we formulated the

4 original proposal for the sunset process. And

5 I actually was the person who was very firm

6 that annotations are not open to change during

7 sunset. And I'm sorry for that. Because it's

8 left us stuck with bad annotations.

9 I think there should be some

10 flexibility to correct them and the Board has

11 the authority to further restrict them. But I

12 was very concerned that annotations would not

13 -- that uses would not be expanded either

14 inadvertently or deliberately without going

15 through the full review process during sunset.

16 And so that's why I really was firm about

17 that. 

18 But, no. I think your

19 recommendation corrects that, allows the Board

20 some flexibility to make -- to improve the

21 annotations during sunset. But without -- but

22 you still draw a line so that they can't --
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1 uses cannot be expanded during that process

2 without a full review. 

3 MR. GIACOMINI: Any other comments

4 or questions? 

5 Thank you. 

6 Okay. Richard, Jeff and John with

7 a proxy. 

8 MR. SIEGEL: Okay. Good morning.

9 I'm Richard Siegel of Washington,

10 D.C. Richard D. Siegel Law Offices, an

11 attorney. I'm not going to speak about yeast

12 this morning even though that may be my

13 billing. 

14 I was not planning to use my time

15 for yeast. However, while since arriving at

16 the meeting I was contacted for the first time

17 by a company that asked for my assistance on

18 another matter pending before the Board

19 through the Handling Committee. And these are

20 two materials that on 605(a) -- 605(b) for

21 sunset. The glycerides and silicon dioxide.

22 The company that I'm speaking for at this time
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1 is RIBOS, an organic ingredient manufacturer

2 in St. Louis that has a produce called Nu3 RICE, N-U-R-I-C-E, which is an organic rice

4 alternative to glycerides and silicon dioxide.

5 Now, I will first talk about

6 glycerides and then silicon dioxide. 

7 On glycerides I heard the

8 discussion yesterday. I gather that the

9 Handling Committee wants to continue to

10 consider the sunset decision for glycerides

11 because of public comments. 

12 One of the public comments that

13 has been received -- that was received prior

14 to the deadline was from Richard Theuer in

15 which he said that as a member of the original

16 Board that determined the listing for

17 diglycerides if he knew at that time that

18 there had been an organic rice alternative,

19 their vote would have had a different outcome. 

20 Now, there were several comments that were

21 submitted on diglycerides by the deadline. 

22 The company that asked for my assistance has
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1 given me additional comments which it

2 collected but did not manage to submit by the

3 deadline. So, I have brought these comments

4 here. And if they're circulated to the Board

5 in some way so that they can be in their

6 books, I have 30 comments here for that.

7 The second point -- the second

8 topic is silicon dioxide. Now, in light of

9 the discussion yesterday, there is support to

10 continue the listing of silicon dioxide under

11 the sunset because a petition is pending to

12 remove silicon dioxide. 

13 There were additional comments on

14 silicon dioxide that were also collected but

15 not submitted by deadline. I did not bring

16 them to this meeting, to this session this

17 morning, but I can see that they're filed and

18 through the appropriate vehicle. Maybe by

19 just sending them to the website post the

20 meeting.

21 So, those are the two matters that

22 I have and I thank the Board very much for all
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1 its work and for all its patience and I have

2 been sitting through a lot of the meetings and

3 I know that the Board has to sit through even

4 more than I do. I can at least cherry pick

5 what I'm going to listen to. But the Board

6 has to listen to everything. And that's a

7 very admirable and a very diligent performance

8 on the part of the Board.

9 Thank you very much. 

10 MR. GIACOMINI: Questions and

11 comments? 

12 Thank you, Richard. 

13 Next up Jeff, John and Julie. 

14 MR. SCHAHCZENSKI: Good morning. 

15 My name is Jeff Schahezenski.

16 First of all, I want to invite everyone in the

17 room, including the Board, to a great meeting

18 next week because you're going to need a

19 vacation to Montana. Beautiful Montana and

20 not at least of which we're going to have

21 Maria Rodale. We're going to have Robert

22 Quinn, a former member of this Board. And
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1 last but not least, Barry Flamm will be there.

2 So, you're all invited to Montana next week

3 and we have a great program.

4 My name is Jeff Schahczenski. I'm

5 a Program Specialist at the National Center

6 for Appropriate Technology, a national

7 nonprofit organization. 

8 I want to take a few minutes today

9 to inform everyone about a new joint project

10 between the National Organic Program and the

11 National Center for Appropriate Technology. 

12 The outcome for the project will

13 be a set of publications which will be helpful

14 for certifiers as well as organic and

15 transitioning farmers. 

16 NCAT's mission is to help people

17 by championing small-scale local and

18 sustainable solutions to reduce poverty,

19 promote healthy communities and protect

20 natural resources. 

21 Our work on organic agriculture is

22 an important part of that mission. The
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1 organization has nationally recognized

2 programs in sustainable agriculture and

3 renewal energy as well as successful track

4 record for state and regional projects. We

5 have offices in Montana, Arkansas, California,

6 Iowa, Pennsylvania and now Texas. 

7 Many of you are familiar with

8 ATTRA, the National Sustainable Agriculture

9 Information Service, ATTRA provide free

10 information to farmers through a toll-free

11 information line, over 350 publications and a

12 website which millions of visitors frequently

13 visit each year. 

14 Through ATTRA, I and other

15 specialists answer questions related to

16 organic certification, marketing and

17 agriculture which we receive by phone, email

18 and on the web. 

19 This summer a cooperative

20 agreement was signed to allow NCAT to develop

21 compliance tools for organic agriculture

22 producers and certifying agents. Many of
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1 these publications were developed several

2 years ago and are being revised and updated to

3 reflect new standards. These materials will

4 be available both on the National Organic

5 program and ATTRA websites and will be

6 available through hard copy through request to

7 NCAT's ATTRA project. 

8 The publications are as follows:

9 Understanding the NOP Access to Pasture Rule.

10 This is a new workbook for livestock producers

11 that explains the calculations that will be

12 needed for ruminant livestock feed and

13 provides worksheets that will simplify the

14 calculations for the farmer.

15 Organic System Plans for both crop

16 production, ruminant livestock and nonruminant

17 livestock. The system plan templates are

18 primarily for the convenience of the

19 accredited certifier agencies. Some ACAs may

20 choose to use these templates where certifiers

21 may choose to design their own.

22 The templates were reviewed and
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1 approved by the National Organization Program

2 before they were posted. 

3 Inspection Report Forms for crop

4 production, ruminant livestock and non5 ruminant livestock. The Inspection Report

6 Forms are primarily for certifiers and

7 inspectors. They will be designed to be

8 parallel with the organic system plans. 

9 This will be reviewed and again

10 approved by the National Organic Program

11 before they are posted. 

12 Documentation forms for livestock

13 producers. The documentation forms assist

14 producers with the record-keeping required for

15 organic operations. Organic Certification

16 Workbooks again for crop production and

17 livestock production. The two workbooks are

18 geared toward farmers, new to organic

19 agriculture. They explain the certification

20 process and serve as a guide to the national

21 organic standards. 

22 And number six, compliance
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1 checklists for producers, again for crop

2 production and livestock production. In the

3 checklist, there are a series of questions to

4 help farmers assess whether their operation

5 complies with the National Organic Program

6 standards. 

7 And we'd be happy to answer any

8 questions and feel free to contact us anytime

9 about this.

10 Thank you. 

11 MR. GIACOMINI: Questions and

12 comments? 

13 Thank you.

14 John, Julia and Amelia please.

15 You're ready to go. 

16 MR. PECK: The dairy farmer I was

17 hoping to be here is not here. So, I'd like

18 to yield the time -- I guess he must still be

19 milking his cows -- yield the time to a future

20 farmer in the afternoon which I'm sure

21 Cornucopia can identify at that time. 

22 Thanks. 
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1 MR. GIACOMINI: Okay. I am not

2 sure that fits into our schedule but we will

3 see. 

4 MS. WEISMAN: Hello. It is me

5 again, Julie Weisman. I'm a former NOSB

6 Member who chaired the Handling Committee for

7 several years. I was also Vice Chair of the

8 Board for the time and my comments now are my

9 personal opinions and do not represent those

10 of my company or other groups of which I may

11 be a member.

12 Thanks again for this opportunity

13 to address you. It is killing me that I can

14 no longer be recognized by the Chair. This is

15 like now the only way -- one of the only ways

16 I can make my opinions heard. It's hard. And

17 I also want to say that I have new and deep

18 respect for the commenters I have been

19 listening to for the last five years.

20 It is hard to keep to five minutes

21 on a subject about which one feels

22 passionately. And commercial availability,
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1 606, is one such subject for me. 

2 I originally promised Joe that I

3 would address this issue because, at the time

4 about a month ago, he was being skewered along

5 with the program in the media for recommending

6 the relisting of hops. But the beauty of this

7 participatory transparent process with

8 adequate advance notice and public comment --

9 you can tell I love it. Right? Is that the

10 matter seems to have been somewhat amicably

11 resolved for all parties at least for now. 

12 Also, I was challenged by our

13 deputy administrator a couple of weeks ago to

14 provide proof of my strong belief that listing

15 materials is an incentive, not a bar to the

16 development of organic alternatives to listed

17 substances.

18 Miles, I'm still working on the

19 facts you asked for. I do believe that I

20 provided some metrics in my previous comments

21 on flavors. The sound bite would be 1 to

22 1,500 in 14. That's one organic certified --
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1 one certified organic flavor to 1,500

2 certified organic flavors in 14 years.

3 I would like now to turn back to

4 hops as a case in point. 

5 First of all, I would like to say

6 that hops are not just hops in my opinion and

7 I'm not involved in growing hops or brewing

8 beer. But I see them as flavors in a way. I

9 hear brew masters talk of notes contributed by

10 different variables the same way I hear

11 flavors talk about notes of different flavor

12 ingredients that they add to their most prized

13 and secret formula. 

14 There will surely be other

15 instances in which something was put onto the

16 list as a single substance but progress

17 towards full commercial availability and de18 listing will only be made in a step-wise

19 fashion, form by form. 

20 Lecithin and flavors to name two

21 also seem to be taking this course.

22 Secondly, the issue is not only
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1 whether or not it is possible to produce high2 quality hops via organic production, that's

3 not even a question at this point, it is a

4 fact in the field. But a question that is

5 just as important is whether it is possible to

6 produce high-quality beer with the varieties

7 that are currently available? So, what's

8 possible isn't always the same thing as what's

9 actually happening at any given moment. And

10 all this is to say that commercial

11 availability should not be seen as an event

12 but as a dynamic, even a dialectical process

13 between ingredient producers and the makers of

14 organic products.

15 But back to my main point. That

16 listing is an incentive, not a bar. Clearly,

17 since 2007 -- since the listing in 2007 of

18 hops on 606, the number of varieties available

19 and the number of regions where it's being

20 cultivated have expanded. This is the outcome

21 that we hoped would result from listing on 606

22 The fact that brewers do not yet
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1 have all the tools they need available to them

2 should not be viewed as evidence that listing

3 on 606 is a disincentive to the development of

4 organic alternatives, if anything, the fact

5 that so many organic hop growers have been

6 clamoring both before this meeting and at this

7 meeting for the listing not to be renewed is

8 evidence of just how well listing on 606 works

9 as an incubator for even minor ingredients.

10 I do not dispute that there are

11 some amount of specing out that goes on and

12 this goes to another point about commercial

13 availability that I cannot stress enough.

14 I believe that the way to address

15 specking out is through certification process

16 and the producers annual review. But this

17 burden should not be borne alone by ACAs. ACAs

18 need the assistance and support of the program

19 which, for instance, could, as part of

20 periodic certifier training, give ACA better

21 tools to vet out the claims by handlers that

22 organic varieties do not meet their
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1 requirements.

2 And in a few seconds, I just want

3 to comment that I support annotation change at

4 Sunset but they should only be introduced and

5 come before the Board after having made it

6 through committee and the public comment

7 process.

8 I refer people to Tim Dietz's

9 comments, written comments about the possible

10 consequences.

11 Flavors, you already heard my

12 comments. Yeast, an elegant solution. Bravo.

13 Colors. I support the annotation to exclude

14 those made with synthetic substance carriers

15 and relisting of mono and diglycerides. I

16 agree with the recommendation, NOSB Sunset

17 petition process should not be used to further

18 the interests of the single manufacturer or

19 interest group for that matter. 

20 And for the record, anyone who

21 thinks that the NOSB has been using EPA or FDA

22 minimums as the bar for listing materials does
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1 not know the history of this Board, which is

2 a very well documented matter of public

3 record. My advice is to go learn it, the rest

4 of the commentary.

5 Thanks. 

6 MR. GIACOMINI: Thank you. 

7 Comments or questions for Julie? 

8 Julie, you will always be

9 recognized by the Chair. You just may not

10 always be allowed to speak. So, I think, you

11 know, as I'm getting ready to go off the Board

12 in my work I talk to -- as I'm so active in

13 the dairy industry. A lot of dairymen go out

14 of business and there is no one who finds

15 themselves more frustrated and less

16 influential in the process than a former

17 dairyman. They may have been the most active

18 political when they had a cow. But when they

19 don't have cows anymore, nobody will listen to

20 them. I don't think that is true with the

21 NOSB. I think the current Board and existing

22 Boards and I hope the future Boards always
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1 give extreme respect to the inputs from former

2 Board members and the experiences they can

3 bring back to the table. So, thank you and

4 thank you to all of us.

5 Okay. 

6 Amelia, Harriet and John. 

7 Can you send me that document

8 please? You did? Okay. Great. Thank you.

9 MS. SLAYTON: Hello. My name is

10 Amelia Slayton. I'm the Managing Director of

11 Seven Bridges. We're an exclusively organic

12 hop broker. And we have been since 1997. And

13 I'm here to talk about the favorite subject of

14 the week. And I came prepared with a lot of

15 comments that don't seem relevant now that you

16 have decided to take hops off the list. And

17 that's really encouraging news for us. So,

18 some of my comments are more about concerns

19 about the implementation.

20 When I came to the meeting in the

21 spring, I was asked to work on some industry

22 statistics and so I do have some of those
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1 figures and I know that the North American

2 Organic Hop Association already provided some

3 of these. Kind of reinforce that but I also

4 have figures for international hop supply. 

5 So, my projections were for 2012

6 and by 2012 looking at the available supply to

7 U.S. brewers of certified organic hops, we're

8 looking at close to 200,000 pounds of

9 available hops, most of those coming from U.S.

10 growers but significantly 25,000 pounds from

11 Germany, 18,000 pounds from New Zealand,

12 10,000 pounds from Great Britain and Belgium.

13 Those countries are producing far more than

14 those numbers, but those are the numbers that

15 they're currently exporting to the U.S. 

16 And working with figures from the

17 Organic Trade Association for U.S. organic

18 beer sales in 2009 which were 41 million, and

19 projecting a growth of 10 percent when the

20 average for the industry is 15 percent, so

21 just being conservative, we're looking at

22 sales around 55 million in 2012. 
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1 Using industry averages, that

2 translates to roughly 72,000 barrels of beer

3 or 72,000 pounds of hops. It is my hope that

4 with the change in organic standards and the

5 removal of hops from the list that the growth

6 curve will be exponential as more brewers

7 realize the potential for organic beer and

8 we'll see, you know, the supply and demand

9 equaling out over the next few years.

10 Speaking to my concern about

11 implementation, because it has always been the

12 requirement for brewers who want to use non13 organic hops to seek out organic supply first.

14 You know, over the past five years we've had

15 very few calls from brewers and even fewer

16 calls from certifiers checking facts. 

17 And so, my concern is that this

18 will continue right up until the end and we're

19 sitting on, you know, hundreds of thousands of

20 pounds of hops in inventory that we need to

21 see before they expire and we'd like to see

22 that happen. So, I guess I have a question
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1 for the Board if there's a plan for

2 implementation and enforcement of --

3 MR. GIACOMINI: Let's have her

4 complete. Is that your completion?

5 MS. SLAYTON: No, I had a few

6 other comments to make that I just want to --

7 MR. GIACOMINI: Yes, let's

8 complete your comments --

9 MS. SLAYTON: Okay.

10 MR. GIACOMINI: -- and then we'll

11 try and wrap up our answering your questions

12 and any other questions.

13 MS. SLAYTON: Okay. I'm just

14 going to be really brief on the rest of the

15 points since I know they've been made already.

16 Currently, we offer 30 varieties

17 of certified organic hops and so the variety

18 has increased significantly. Most of those

19 varieties we inventory small amounts of

20 because we just can't afford to have 5,000

21 pounds of 30 different varieties of hops. We

22 need communication from the industry to know
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1 which hops they need or want and as we get

2 that communication we'll be able to inventory

3 the types of hops that they want. But the

4 varieties are already out there and growers

5 are willing to grow them.

6 One of the things that we've been

7 investing time and money in is export because

8 we've been so frustrated with the market here

9 in the U.S. and that's obviously going to

10 continue for a lot of good reasons. But, you

11 know, one of the concerns is that if we're

12 exporting all the organic hops, what U.S.

13 brewers going to use when they're required to

14 use them?

15 We've been doing a petition, a

16 consumer petition, for the past two years and

17 we've gathered over 1,000 signatures from

18 individuals and trades people who want hops

19 off the list and I will be delivering those.

20 We will be closing that petition now that the

21 goal or the date has been set.

22 MR. GIACOMINI: Thank you. 
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1 Questions/comments? Joe, do you

2 want to respond to that? 

3 MR. SMILLIE: Yes. We're very

4 clear in our recommendation that we were

5 concerned by the commercial availability

6 function of 606. We mentioned it prominently

7 in our recommendation that there seemed to be,

8 we don't know, but there seemed to be a

9 disconnect between that requirement between

10 the certification organizations and the

11 brewers. We don't know that to be a fact and,

12 in fact, it could be there's been very

13 assiduous work on that. But there seemed to

14 be, because the hops growers and yourself have

15 said we've never been contacted -- so, we've

16 put that clearly in our recommendation to the

17 program that the implementation for hops in

18 January 1st, 2013, also bringing their

19 attention to the fact that the commercial

20 availability requirement and basically we send

21 that -- there's nothing more we can do. We

22 have a 2007 recommendation currently in the
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1 hands of the program that talks about

2 commercial availability and the need for more

3 training and more guidelines on it. And they

4 have that. They now have our recommendation

5 for hops and I think the program will follow

6 through on the question of the commercial

7 availability. 

8 MS. SLAYTON: I did have one more

9 question if I have time. 

10 It's regarding the labeling of

11 organic beer and is there any plan to require

12 additional information on labels before 2013?

13 MR. GIACOMINI: I think we heard a

14 phone. All right. Own up. 

15 I'm sorry, we didn't mean to

16 interrupt you, but that is a significant event

17 here. 

18 MR. SMILLIE: You've been so good

19 so far. 

20 MR. GIACOMINI: I have or

21 whatever. 

22 MR. SMILLIE: That's a thing that
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1 CCOF pointed out very clearly in their comment

2 is that, because of the current alcohol

3 labeling, there's not an ingredient panel

4 required. But I have it upstairs. I should

5 have brought it. But you can. In the

6 enrollments language and the title of beer you

7 can make it known that you're using organic

8 hops. It's just the labeling requirements per

9 se and I'm not even sure, Miles, they don't

10 allow for ingredient panel listing or you

11 don't have to do it? 

12 MR. McEVOY: I believe they do

13 allow for organic or ingredient labeling on

14 beer but you don't have to do it. It's not

15 required. We don't have any plans to make

16 that change. We're waiting for your

17 recommendation on hops and then we'll move

18 forward with that. 

19 MS. SLAYTON: I think the concern

20 is that the -- the consumer concern right now

21 about the distinction and consumers right now

22 can't make an informed choice when they look
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1 at a label on beer and a lot of beer labels do

2 say barley, malt, hops. The list of

3 ingredients. It doesn't distinguish whether

4 the hops are organic or not. And usually it's

5 the brewers advertising that makes that

6 distinction if they are. But a lot of

7 breweries who aren't using organic hops really

8 want to gloss over that. And so the consumer

9 really has no way to know for sure.

10 MR. SMILLIE: I think the market

11 place will fix that. I think that the brewers

12 of organic beer will make it really clear that

13 they are using organic hops. And, again, as

14 of 2013, you won't be able to call the beer

15 organic at all if you don't use organic hops.

16 So, that will be resolved in 2013 and I think

17 the years leading up to 2013, I think the

18 marketing of the people who market organic

19 beers are going to be really clear about their

20 use of organic hops. So, I think we'll leave

21 that one to the market place to settle.

22 MR. GIACOMINI: Dave. 
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1 MR. DICKSON: Thank you for your

2 comments. I'm sorry I have my back to you

3 here. 

4 First of all, what's the shelf

5 life of hops once they're harvested? 

6 MS. SLAYTON: It is somewhat

7 varietal specific, anywhere from a year to

8 three years, depending on package and storage.

9 The value decreases significantly after the

10 first year. 

11 MR. DICKSON: Okay. Secondly, are

12 you aware of brewers that are using nonorganic

13 hops in organic beer when you have hops

14 available for -- organic hops available?

15 MS. SLAYTON: Yes. 

16 MR. DICKSON: And have you lodged

17 a complaint with the USDA?

18 MS. SLAYTON: I'm not aware that

19 you can when it's something permitted. 

20 MR. DICKSON: You can do that and

21 I would highly recommend you do that. If

22 you're aware of any brewers that are using
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1 nonorganic hops when you have some available,

2 lodge a complaint.

3 MS. SLAYTON: Thank you. 

4 MR. GIACOMINI: Especially if it's

5 the same variety. 

6 Okay. Any further -- okay. 

7 Harriet -- we are up for a 9:15

8 break. Let's do Harriet and then we'll take

9 a break and we're already half an hour behind

10 schedule. So, go ahead, Harriet. 

11 MS. BEHAR: Hello. I'm Harriet

12 Behar, the MOSES Organic Specialist and today

13 I have a variety of comments. 

14 On the change to animal health in

15 the regulation, I believe clarification needs

16 to be made that the pain medication mentioned

17 in the recommendation are limited to only

18 those on the National List. 

19 I support adding verifiable and

20 consistent animal welfare standards for all

21 species of livestock to be an LP reg, although

22 I have hesitancy with only outcome based
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1 standards. 

2 Many conventional cattle could

3 have high body scores. However, the process

4 and inputs by which these were achieved are

5 not compatible with organic agriculture. Both

6 the process, such as stocking rates as well as

7 the outcome, healthy animals must be part of

8 the organic animal welfare standards.

9 For nonruminant animals such as

10 poultry and swine, I would like to see the

11 recommendation include a minimum vegetative

12 cover to be maintained in the outdoor access

13 areas such as 50 percent. This honors the

14 mandate for soil and water conservation as

15 well as providing a healthy environment that

16 a bare lot would provide.

17 I'm going to tie animal welfare

18 and corn steep liquor together. The corn

19 steep liquor, this product is distinctly

20 different from the corn from which it was

21 made. There is more sulphur as a result of

22 the addition of the synthetic sulphur dioxide.
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1 Again, it is not just the outcome but the

2 process and the inputs by which the outcome

3 was achieved that must be reviewed.

4 I strongly urge this Board to

5 postpone your decision on corn steep liquor

6 due to the lack of clarity of the organic

7 acceptability of the method, input and

8 outcome. What is at stake is too far-reaching

9 and should not be made without clear Board

10 agreement and broad consensus on this core

11 definition relating to chemical change. 

12 This decision will set precedent

13 causing a chain reaction affecting many

14 materials currently approved or not approved

15 under the USDA organic seal. The Board's

16 fundamental responsibility is first to OFPA.

17 Legal consequences and market disruption have

18 been the result when statutory mandates were

19 not followed in the past. 

20 I urge more investigation and

21 research before making what could be a

22 problematic decision. 
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1 For the Made with Organic label

2 recommendation. I do not believe we need to

3 provide greater visibility and, therefore,

4 higher stature to the Made with Organic label

5 than it currently has in the marketplace. This

6 is the label where manufacturers can go when

7 they choose to not use organic ingredients

8 that are commercially available, usually due

9 to price. This is not the case with all Made

10 with Organic products but it does happen. 

11 If the concern is that consumers

12 do not view the Made With Organic label as

13 equivalent to organic or 100 percent organic,

14 well, they're saying it truthfully. It is not

15 equivalent. The 30 percent of the ingredients

16 of the Made with Organic product can contain

17 non-approved flowing agents, use non-approved

18 processing aids such nitrates and, of course,

19 have them produced with conventional

20 agricultural inputs. 

21 The non-organic agricultural

22 ingredients in the Made With Organic category
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1 does lower the organic integrity of the

2 product since it is a co-mingling of organic

3 with non-organic. 

4 The non-organic ingredients are

5 produced with non-approved inputs from the

6 field through processing. This product is not

7 equivalent to organic or 100 percent organic

8 even though it goes through the inspection and

9 certification process. 

10 If we want to increase organic

11 lands, we need to promote the organic label.

12 There are products in the marketplace using

13 the organic word incorrectly on their label.

14 I agree. But that can be dealt with as a

15 separate issue. 

16 The argument that now technology

17 is a synthetic that organics should leave the

18 door open for future possible use is the same

19 door that the GMO community would like us to

20 give for their methods. Just as GMOs are

21 banned under the precautionary principle, so

22 should nanotechnology be banned.
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1 And lastly, I just want to say to

2 remember that we are a process-based standard.

3 We are not a standard that tests the final

4 product to see if it is free of whatever we

5 don't like in it. We are process-based. So,

6 I ask you again to keep remembering to look at

7 the process, look at the inputs and then also

8 look at the outcome when you're reviewing

9 materials and methods. 

10 Thank you. 

11 MR. GIACOMINI: Questions? 

12 MR. FELDMAN: Thanks, Harriet. 

13 When you look at previous Board

14 decisions on this issue of synthetic, do you

15 concur with Jim Riddle on the previous

16 classification of chemical change, his example

17 being fish emulsions or extracts?

18 MS. BEHAR: Yes, I do. Yes, I

19 think that that was a very good analogy.

20 MR. FELDMAN: Yes. Okay. Thank

21 you. 

22 MR. GIACOMINI: Wendy. 
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1 MS. FULWIDER: What is your

2 hesitancy on the outcome-based standards for

3 livestock? 

4 MS. BEHAR: I believe that we

5 should be looking at the outcome. But we also

6 need to be looking at the method and the

7 inputs used to get that outcome. So, it's not

8 just only outcome. That's too narrowly based.

9 You're supposed to be looking as well. We're

10 a process-based standard which -- so, we have

11 to have a process to get to that outcome and

12 so that's what I'm saying. And it can be a

13 slippery slope like I said for body scoring.

14 A lot of conventional cattle operations can

15 have excellent cattle that score very high.

16 But the way they got to that score, those

17 things are not compatible with organic. 

18 MR. GIACOMINI: Joe. 

19 MR. SMILLIE: I used to sell fish

20 emulsion. In fact, I remember one time when

21 it exploded on me and I wasn't allowed in the

22 house for three days. 
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1 Fish emulsion is not a

2 fermentation product. Creation of fish

3 emulsion is definitely a chemical process. I

4 watched it being made. It's a chemical

5 process. There's no question about it. The

6 way we dealt with it is absolutely correct.

7 It's not a good analogy to corn wet milling.

8 Corn wet milling is a lactic acid fermentation

9 process. It's not designed to be a chemical

10 process, whereas, fish emulsion is a chemical

11 process. You're basically taking the acids,

12 pulling it off and we've allowed it because it

13 was a traditional method of nitrogen

14 fertilization in the organic industry and I

15 think it's a good allowance. It's one of

16 those synthetics that I think we need and we

17 want farmers to have and it is synthetic and

18 it is a chemical process. It's been correctly

19 handled in the past and I think it will stay

20 that way.

21 Our decision on CSL will not

22 affect the view of fish emulsion because it's
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1 not a good analogy. Maybe we'll find a good

2 analogy sometime today. But that's not a good

3 one based on my understanding of both of those

4 processes. 

5 MS. BEHAR: My response would be

6 that I just do not believe that there is

7 clarity yet on that. You've heard from public

8 comment that some people do feel it is

9 chemical change. And so, therefore, I really

10 think you should postpone this until you have

11 more broad consensus because this would have

12 far-reaching effects. And so until the Board

13 -- when you're going to get, you know, a 14 to

14 1 vote versus a 7 to 6 vote or whatever. 

15 MR. SMILLIE: That's different. I

16 wanted to point the analogy is not a good

17 analogy. 

18 MR. GIACOMINI: Jennifer. 

19 JENNIFER: Thank you, Mr. Chair.

20 Thank you, Harriet, for your comments.

21 I kind of want to nip this growing

22 idea about the fact that I see either I or the
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1 committee but certainly me as a representative

2 that I see Made with Organic as equivalent to

3 the other two categories because that is

4 clearly not the case. But I do think that

5 there are those cases where either

6 manufacturers or consumers do need to make

7 choices because of price and not everybody can

8 afford to be perfect but a lot of people

9 really do want to try to do better with their

10 diet. And we have this tool called the Made

11 With Organic label in our tool kit and I think

12 that we're potentially missing a huge

13 opportunity to satisfy the needs that exist

14 and just help consumers do better.

15 Thanks. 

16 MR. GIACOMINI: Any further?

17 Okay. Before we wrap up, you made

18 a reference to qualifying the 238(c)(2)

19 document for only pain relief on the National

20 List. 

21 A strict interpretation of right

22 now would be that even natural non-synthetic
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1 pain relievers would not be allowed in the

2 absence of illness. And so we're trying to

3 make sure that those are reasonably to be

4 used. The other thing more directly to your

5 point is that again we deal with, we have this

6 recommendation but when it's enforced it's

7 enforced to the final rule. No synthetic pain

8 relief medication that's not on the National

9 List would ever be allowed. Okay. If it's

10 synthetic it would have to be on 603.

11 What we're trying to do here is

12 now that it's on 603 you need to be able to

13 use it to relieve pain in the cases where

14 you're using it in the absence of illness.

15 Where, again, in the strict interpretation of

16 what that language says, you could be

17 prevented from doing that and really harm

18 animal welfare. 

19 MS. BEHAR: Well, I think the same

20 logic could be made that in the strict

21 interpretation we should be very clear for

22 preventative measures and pain medications
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1 that things that are consistent with our

2 material inputs which would be natural or on

3 the National List.

4 MR. GIACOMINI: Okay. I think the

5 committee would feel that that's --

6 MS. BEHAR: Redundant.

7 MR. GIACOMINI: -- included. Yes,

8 maybe. Yes. Yes. Okay. Thanks. 

9 MS. BEHAR: Redundancy doesn't

10 hurt.

11 MR. GIACOMINI: Okay. 

12 Twenty five after. Fifteen-minute

13 break. Please be prompt.

14 Thank you. 

15 (Whereupon, the above-entitled

16 matter went off the record from 9:27 a.m. to

17 9:42 a.m.) 

18 MR. GIACOMINI: Okay. We have a

19 quorum of the Board. Hopefully, the speakers

20 we have -- on my stuff here is a flash drive. 

21 Is this anyone's flash drive? Tracy is this

22 yours? Okay. Maybe Tina. I'm certainly not
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1 going to put a strange flash drive into my

2 computer. No, but they hacked into CIA or

3 something. Somebody hacked into CIA doing

4 that once. They dropped flash drives in their

5 parking lot and people went into the -- oh,

6 what's in the flash drive? Got a virus in

7 their systems so they could hack in.

8 Okay. We have a missing flash

9 drive if anybody is looking for it. 

10 Okay. First of all we're ready to

11 resume. Joan Smiley, Tony and Paul. 

12 Before you get going though, Joan,

13 we've had some conversations among members of

14 the Board. Miles. It's always been the

15 policy of the Board not to allow derogatory

16 statements specifically related to a company

17 or an individual. I guess there could be

18 debate over how that company name was

19 addressed in that public comment, but the very

20 next person came up and said, okay. Well, now

21 I can make statements about Anheuser Busch,

22 about another company. 
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1 We would respectfully ask you to

2 review FACA and OGC and see what the ability

3 of this Board in that regard really is. 

4 MR. McEVOY: Yes, certainly

5 support a very respectful dialogue and respect

6 of all the companies, all the people involved

7 in the business. So, we will take a look at

8 that and get back to you specifically about

9 that. 

10 I would say that it is a public

11 comment session so people do have the right to

12 make public comments but they need to do so in

13 a respectful manner. 

14 So, mentioning a company name, I

15 don't see how we could censor that. Certainly,

16 we have a very well-informed and educated

17 public here and I think they can discern

18 between what is a truthful statement and not. 

19 You can certainly enter into the public record

20 things to put a different perspective into

21 what a comment is speaking.

22 MR. GIACOMINI: Okay. 
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1 MR. McEVOY: So, respect is

2 certainly very, very important, but I don't

3 see how we can censor someone mentioning a

4 company's name. 

5 MR. GIACOMINI: Okay. But just so

6 everyone knows, we will I guess re- evaluate

7 the line but the Chair will not tolerate

8 disparaging, derogatory comments to companies

9 or individuals. Maybe the question there was

10 whether it was truly derogatory or factual. 

11 But we'll just proceed from there.

12 So, any other announcements or

13 anything? We're ready to go so Joan Smiley.

14 MS. SMILEY: Yes. Well, my name

15 is Joan Smiley. I'm with Falcon Lab and

16 Falcon Lab is a developer or herbicides based

17 on naturally occurring sustainable resources.

18 Thank you for the opportunity. I'd

19 like to outline for the Board a petition for

20 ammonium nonanoate which is currently in

21 technical review. 

22 To familiarize you with this
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1 substance I will quote from June 2010 EPA

2 document. "Ammonium nonanoate is a naturally

3 occurring substance, has a non-toxic mode of

4 action and has a significant history of

5 exposure to humans and the environment.

6 Ammonium nonanoate is closely related to other

7 salts of fatty acids known as soap salts."

8 As a soap-based herbicide,

9 ammonium nonanoate is current NOP allowed for

10 organic use with restrictions to non-food

11 areas. But it is also EPA approved for food

12 use as a bio-herbicide. Ammonium nonanoate

13 has its own distinct singular substance CAS

14 number and it is the only ammonium soap that

15 both occurs in nature and has herbicidal

16 qualities. 

17 The essence of the current

18 position is to add ammonium nonanoate as a

19 synthetic substance allowed for use as a

20 herbicide in organic food crop production as

21 follows: (1) One, prior to planting food

22 crop; (2) As a directed spray at the base of
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1 grapevines and fruit trees; and (3) using

2 shielded hooded sprayers between food crop

3 rows.

4 I'd like to begin with some

5 supporting evidence for the need for another

6 organic herbicide. Here is a quote from the

7 USDA's own June 2009 economic information

8 bulletin titled "Emerging Issue in the U.S.

9 Organic Industry.

10 Despite the potential for organic

11 agriculture to improve the environmental

12 performance of U.S. agriculture, the national

13 standard is having only a modest impact on

14 environmental externalities caused by

15 conventional production methods because the

16 organic adoption rate is so low."

17 And another quote from the

18 Northwest Agricultural Research Foundation

19 from 2010. "Weed management in new wine grape

20 vineyards was identified as a primary

21 constraint to organic production in the region

22 at a meeting of the NARF alternative crops
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1 grape advisory committee composed of

2 representatives from the area grape grower

3 groups.

4 USDA itself has been funding

5 research through IFR studies to identify

6 better, more cost effective organic herbicides

7 and on several occasions has included ammonium

8 nonanoate in their field tests. Each time

9 ammonium nonanoate performed substantially

10 better than other naturally occurring

11 substances and ammonium nonanoate is, at

12 minimum, a third the cost of other substances

13 and one-fourth the cost of almost all organic

14 herbicides. 

15 In addition to cost and efficacy

16 issues, there are other challenges with

17 currently certified organic herbicides. For

18 example, clove oil and lemon grass oil are

19 only available from foreign sources and have

20 the potential risk of an unreliable less pure

21 supply. 

22 Higher strength acetic acid at 20
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1 percent which is needed to kill weeds is very

2 corrosive to human tissue, to metals,

3 including stainless steel and the use of such

4 would likely violate OSHA handling

5 requirements plus require the signal word

6 danger. 

7 None of the herbicide substances

8 currently considered organic are a part of the

9 normal human diet. Ammonium nonanoate is.

10 Another compelling reason for an

11 efficacious cost-effective organic herbicide

12 aligns with the performance objective 1.3.1

13 stated on Monday morning at this very meeting.

14 Increase the number of organic production

15 operations by 25 percent by 2015."

16 As noted in the earlier quotes,

17 the high cost of weed control in organic crops

18 will almost certainly impede the progress of

19 this objective. As far as being natural

20 organic and sustainable as noted in detail in

21 the petition, ammonium nonanoate is constantly

22 forming in nature. It is only synthetic in
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1 that it biodegrades within 24 hours so it

2 never accumulates and, therefore, is not

3 harvestable. It is produced identically to

4 how it forms in nature using FIFRA 25(b) raw

5 material, folic acid which is part of our

6 daily diet and oxygen from the air. 

7 The EPA Red states that ammonium

8 nonanoate has low toxicity and that residues

9 from its pesticide use are not likely to

10 exceed the levels which are naturally

11 occurring and it would be indistinguishable to

12 know if the source was nature or intentional

13 spray.

14 Lastly, we would like to highlight

15 for the Board as we wonder how can some

16 substances be organic for some crop use and

17 non-organic for others? Insecticidal soaps

18 were renewed in April 2010 for use in organic

19 crop production with no restrictions. Ammonium

20 soap can be sprayed on crops as an animal

21 repellant. Soap-based herbicides were renewed

22 in April 2010 with restrictions but as stated
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1 earlier, ammonium nonanoate is the only

2 ammonium soap that both occurs in nature and

3 has herbicidal quality.

4 Thank you. 

5 MR. GIACOMINI: Thank you. 

6 MS. ELLOR: Thank you for coming.

7 Just one comment.

8 Herbicides are not certified

9 organic. They're allowed for use in organic

10 agriculture. It's a very important line.

11 MS. SMILEY: Good point. 

12 MR. SMILLIE: Where is this on the

13 crops work plan or --

14 MR. GIACOMINI: Its out for TR. 

15 Questions? Thank you. 

16 I'm working on getting an update

17 on my system so we're Tony, Paul and Jackie.

18 MR. DRYAK: Thank you for the

19 opportunity to present today and I'm here

20 presenting on behalf of my organic farm

21 located in Wisconsin as it relates to how

22 organic layers are handled. 
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1 When I began farming out of

2 college I viewed the opportunity to farm as an

3 opportunity and a privilege and a situation in

4 order to enable me to do something right that

5 was dictated by the growing season. There are

6 many jobs out here that give a person many

7 chances to get it right. But when you're on

8 the land and committed to do doing things

9 correctly on the land and you stay in one

10 place, whatever God's gift is for our life

11 dictates how many times we get to do it

12 correctly. The organic opportunity which we

13 began to participate in early '90s gave us and

14 afforded us that chance. 

15 We have a multi-faceted organic

16 farm in west central Wisconsin. And have had

17 the chance to travel around the world to see

18 how other people do things. And we know that

19 the kind of standard that I believe this Board

20 would like to work toward in allowing chickens

21 to exhibit their natural behaviors, whether it

22 be within a laying house or outdoors is very
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1 possible. 

2 Earlier there was some exchange

3 between what the Europeans believe and what we

4 believe and I truly believe because I am in

5 those economies in another venture that I'm

6 part of, the U.S. organic standard really

7 tries to ascribe for one of the highest

8 standards out there. 

9 It is true that, for example,

10 between the European standard as it relates to

11 layers that they do allow certain, what they

12 call exceptions to allow production to occur.

13 Here, as soon as we can settle on

14 a true standard that's meaningful and gives us

15 teeth to bite into the opportunity, we can

16 have the highest standard and still allow for

17 efficient egg production. 

18 When we began producing organic

19 eggs we started out with an experiment of

20 2,000 layers. And the opportunity was brought

21 to us by Organic Valley and they had some

22 general guidelines. This is back in the mid-
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1 '90s. 

2 We took that as a challenge and

3 tried to find ways of making it work. At the

4 end of our production, we were in a house

5 situation with 8,000 birds that had true

6 outdoor access and not limited to two square

7 feet. We did not beak trim or DB whatsoever.

8 We had no cannibalism. 

9 And what we learned as we explored

10 other opportunities around the world is that

11 the housing can work if you allow for flex

12 housing. So, given one's location in this

13 country you can create a living environment

14 for the bird so that as we have to deal with

15 very extreme winters, we still can have the

16 allowed space for the bird but still preserve

17 a lot of heat in the building.

18 The arguments that the industry

19 will have to go through change and that it

20 will be higher to produce an organic egg,

21 those are valid arguments. And as we move on

22 and explore the opportunities, we have to find
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1 ways of making it work.

2 Lastly, I want to just emphasize

3 since I've talked about opportunity that the

4 organic poultry producer that produces eggs

5 for this market has a great chance to get this

6 thing right. 

7 I have as an operation begun

8 experimenting with the use of heritage breeds

9 to see what their efficiencies are and that as

10 I stand here today can say that there may be

11 some solution there. 

12 Thank you. 

13 MR. GIACOMINI: Thank you.

14 Questions or comments? 

15 Wait -- wait, sir. Questions. 

16 Wendy. 

17 MS. FULWIDER: What is your

18 experience then with the heritage breed? 

19 MR. DRYAK: Using five heritage

20 breeds, I can give you more information. I

21 have the data, but out of the five we

22 selected, two looked to be promising Rhode
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1 Island Red and Barred Rock. 

2 The challenge with poultry

3 breeding because most organic layer operations

4 use what we call a GM type of chicken that's

5 highly genetically changed from the way it

6 used to be and it was all designed around

7 efficiency. And as a result we have aberrant

8 behaviors that are exhibited in birds. 

9 But there's an opportunity there.

10 It's just that there has to be funding and

11 there has to be renewed research directed in

12 that in a meaningful way. Throughout Europe

13 they're doing it. 

14 MR. GIACOMINI: Kevin. 

15 MR. ENGELBERT: What are your

16 specific allowances for your birds for

17 outdoors? How many square feet and in the

18 barn?

19 MR. DRYAK: For 10,000 birds

20 allocation to 25 acres. I don't have it

21 computed to the exact square footage because

22 my -- I have visited egg-laying operations in
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1 five countries in Europe and there they use

2 outdoor access in the truest sense of the word

3 where there are acres and acres devoted. And,

4 frankly, the birds use a lot of that space. 

5 In my experiment this year, 100

6 percent of the birds go outside, if given the

7 opportunity. The larger the population

8 though, how they participate in the outside

9 varies on what other activities they need to

10 be up to whether it's scratching, creating a

11 nest, laying an egg and so forth. 

12 So, the space requirements you're

13 suggesting here or at least I would view as

14 very minimum requirement. Now, the California

15 operations don't have to deal with the winter

16 that have here. So, again, the concept of

17 flex housing, and there are many examples that

18 can be found, that will enable this to work

19 and be commercially feasible. 

20 I didn't answer your question of

21 square footage, but I'm allocating 25 acres

22 for 10,000 birds. 
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1 MR. GIACOMINI: Thank you. Further

2 questions/comments? 

3 MR. MOYER: Yes. Thank you for

4 your comments. 

5 Thinking about methionine in feed,

6 do you have any in your feed that you're

7 using? If so, how many pounds per ton? 

8 MR. DRYAK: I'm buying a

9 commercially available organic layer feed. But

10 in the past and the last time I made comment

11 at NOSB which was in LaCrosse many years ago,

12 I had withdrawn all methionine from the feed

13 and I saw a direct impact of 10 to 15 percent

14 reduction in yield. As long as the market

15 understands that's a possibility, it's going

16 to lead to a higher cost egg.

17 When birds have access to

18 supplementing their feed in a truest sense,

19 they can augment that. 

20 And one last comment around that.

21 I'm trying to create an operation that will

22 meet the EU standard organic. The EU standard
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1 requires that chickens be fed silage. This

2 year we'll begin that experiment by through

3 the wintertime providing silage to them. It

4 is labor-intensive. But it also allows the

5 bird behavior to be maximally expressed in a

6 positive manner. You simply don't have the

7 issues of pecking in a manner that they go

8 crazy in a barn. 

9 MR. GIACOMINI: Kevin. 

10 MR. ENGELBERT: What type of

11 silage and did you see any health -- did you

12 have any health issues? You say you lost

13 production, but did you have any increased

14 health issues when you set the methionine?

15 MR. DRYAK: I didn't notice any

16 aberrant behavior. At that time, which was a

17 number of years ago, we weren't measuring

18 exactly how the outdoor interaction was

19 working. But to have a house full of 10,000

20 birds and to not have it beak trimmed, as an

21 example, how dangerous that was when I raised

22 this bunch of pullets and one of the Amish
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1 testifiers here day before yesterday was one

2 of the people I was involved with. I told

3 them, don't beak trim the birds that you're

4 providing -- and I got them as 10-week old

5 birds. He said, well, what do you mean? I

6 said don't trim the beaks. He said well I do

7 it for everybody. I said, well, you're not

8 doing it for me.

9 We had a really excellent result

10 with that flock of birds. We didn't have

11 cannibalism and then I asked myself, well,

12 what am I doing differently than what the

13 industry claimed as an impossibility? And by

14 giving the bird the opportunity to express

15 itself in a natural manner really enhanced

16 that production.

17 Now, I used to be in the retail

18 trade in a small regional market and consumer

19 feedback was they tasted very good and they

20 like the color of the yolk. So, I guess

21 another way of concluding. When I finally

22 slaughtered that flock the USDA/FSIS inspector
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1 came up to me and said, what did I do to the

2 birds? I said I allowed them to exhibit

3 natural behaviors. They didn't find any

4 significant parasite load and it was the

5 lowest condemnation rate they'd ever seen in

6 an organic flock. 

7 So, that was testimony that it's

8 more than just luck. 

9 MR. ENGELBERT: And what silage

10 did you feed and how much? 

11 MR. DRYAK: I have put into silage

12 clover and grasses. Less stemming because it

13 has to be almost, you know, a clover petal

14 size, the bird will eat and swallow and

15 digest.

16 MR. GIACOMINI: Jennifer. 

17 JENNIFER: Yes, back to the

18 methionine questions. And when you reduced

19 your methionine --

20 MR. DRYAK: I took it completely

21 out. 

22 JENNIFER: Took it completely out.
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1 Did you at that time have any heritage birds

2 or have you ever seen any studies of lower

3 methionine diets with heritage birds?

4 MR. DRYAK: I haven't seen any

5 studies. At that time I did not have a

6 heritage breed. 

7 JENNIFER: Thank you. 

8 MR. GIACOMINI: Jeff. 

9 MR. MOYER: Quick follow to the

10 methionine question. You say you're using

11 commercial feed. How many pounds --

12 MR. DRYAK: I don't know the

13 inclusion rate. 

14 MR. MOYER: Thank you. 

15 MR. DRYAK: It's according to this

16 standard because they're inspected by MOSA.

17 MR. MOYER: Got you. 

18 MR. GIACOMINI: Wendy. 

19 MS. FULWIDER: Do you vary your

20 methionine levels by the feathering of the age

21 of the birds?

22 MR. DRYAK: I have not. I have
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1 not. This year's experiment of the five

2 heritage breeds, we used a commercially

3 available feed. We noticed that feed

4 consumption was severely reduced because they

5 had outdoor access to basically white and red

6 clover. 

7 MR. GIACOMINI: Any

8 comments/questions? Thank you. 

9 Paul Frey, Jackie and Lisa.

10 MR. FREY: Good morning. My name

11 is Paul Frey and I'm with Frey Winery. We've

12 been making organic wine for about 30 years

13 without sulfites added. 

14 So, this is a brief Power Point

15 presentation. We tried to condense it all

16 because what normally takes about an hour,

17 we're going to condense it down to five

18 minutes. 

19 So, organic wine standards must be

20 upheld. The proposed sulfite amendment would

21 weaken organic standards. 

22 Next slide please.
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1 We can go through a brief history

2 of organic wine-making. This is sort of the

3 finest part.

4 Most of nearly 8,000 year history

5 of wine-making was from organic grapes with no

6 sulfites added. Organic no sulfite added

7 wine-making is nothing new. There's no solid

8 evidence sulfites were used in either

9 Egyptian, Greek or by the Romans. The Roman

10 writer Cato has said as Pliny said that live

11 oil with the fruition which is boiled down for

12 each use for a pound and a half of salt from

13 time to time crushed marble, sulfur and resin.

14 He's not specified burning sulfur or to create

15 sulfite. This single passage is worth

16 something. The Romans used sulfites. 

17 The real way to use it is

18 consequently unknown. 

19 There were prohibitions against

20 sulfites in adulteration of wine in Europe and

21 the 14 countries and after. 

22 Next slide please.
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1 This is a so-called Roman natural

2 wine movement. Again, there's no proof they

3 added sulfite but they wanted pure stuff. For

4 that line which is most excellent which is

5 given pleasure by its own natural quality.

6 Beautiful. Nor should anything at all be

7 mixed with it by which its natural flavor

8 would be obscured. 

9 We regard as the best line any

10 kind that can be kept without preservatives.

11 They did have resin and other things as a

12 preservative, but that is no longer the course

13 because of filtration. 

14 Here we have the European natural

15 wine movement of the 1400s. 1472 Sturm-wine

16 having sulfites was prohibited in Frankfort,

17 Germany. 1495, sulfur in wine was prohibited

18 in Freyburg and Lindau, Germany. From the

19 extract of the law 1497. Wine shall be kept

20 in its natural form and not be destroyed by

21 noxious, detrimental additions.

22 The decrease of 1487 and 1497
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1 declared that to sell wine that contained

2 added sulfites as a wine that was made without

3 added sulfites. This is 500 years ago. They

4 had rules, they had to specify. 

5 Wines had to be declared that they

6 contained sulfite or did not. So, the

7 purchaser knew what they were buying. The

8 same as today. 

9 Prohibitions against adulteration

10 of sulfites were established to protect

11 regional wine reputations that were being

12 damaged by adding excessive sulfites and to

13 protect the consumer because they have related

14 consequences. 

15 Another prohibition of changing

16 the natural character of wine was raised by

17 King Albert II. 

18 Next slide.

19 Some say that sulfite use was

20 extensive over the last 500 years. That isn't

21 quite the case. Here's a quote by Jules

22 Guyot, famous French wine viticulturist. There
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1 was actually an institute named after him in

2 France. He's the inventor of the Guyot

3 Trellis. Anybody who has studied wine-making,

4 the Guyot Trellis and vineyard management. 

5 He says, wines well made are never

6 unsound. With regards to sulfur in the cask

7 which is where they added the sulfite by

8 bringing the solution into the wine, I cannot

9 recommend it for it kills the wine and give it

10 a bad taste. 

11 So, here you have one of the

12 premier wine people over 100 years ago in

13 France saying it's basically not necessary.

14 There is one more under that. 

15 Another guy, Jules Chauvet who is

16 really the father of the no sulfite movement

17 in modern France in 1960. "Sulfite in wine is

18 not indispensable. The idea would be not to

19 sulfur."

20 Next slide please.

21 Sulfites are unnecessary in

22 advanced organic wine-making. Micron
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1 filtration solved the microbial problems.

2 Zurosh in bottling which is standard now and

3 understanding the wines micro chemistry solved

4 the oxidation issues.

5 Other recent advances in wine6 making equipment and understanding wine

7 chemistry make the use of sulfites

8 unnecessary.

9 Next slide please.

10 This is since we've run metals,

11 gold, silver and so on and these wines compete

12 with any wines on the market. 

13 Next please.

14 The proposal to allow 100 percent

15 of the allergen sulfite into USDA organic wine

16 would be dangerous and damaging. The proposal

17 would allow up to 100 times the amount of

18 sulfite that occur in wine naturally. A

19 hundred times. Most organic red wine has euro

20 parts per million sulfite. Organic whites

21 have about five parts per million. 

22 The proposal would allow up to ten
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1 times above the U.S. and the EU governments

2 consider as safe. All wine must have a

3 contained sulfite warning label if they

4 contain about 10 parts per million. The

5 proposal would mislead consumers who today

6 know that USDA organic wine has never had any

7 added sulfites. 

8 The World Health Organization

9 recognized that four percent of the adult

10 asthmatic population is dangerous for them. 

11 Next slide please. 

12 MR. GIACOMINI: Okay. Can you

13 wrap it up please. That's your five minutes

14 and a summary as quick as possible.

15 MR. FREY: Yes. World Health

16 Organization says it's an allergen. 

17 Next for the conclusion.

18 The European Commission rejects

19 proposal on sulfite organic wine. I'm not

20 really compromising organics generally because

21 it sends the wrong signal to consumers on the

22 quality policy. Organic wine has to be true
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1 organic wine.

2 Conclusion please. Just go to the

3 next slide.

4 Synthetic sulfite is a known

5 allergen that is not allowed in organic foods

6 and has never been allowed in USDA-certified

7 organic wine. Recent events as wine-making,

8 one the methods used to historically prove

9 that sulfites are not essential. Consumers

10 know that USDA certified organic wines have

11 never had the synthetic allergic preservative

12 sulfite added which can cause human harm.

13 MR. GIACOMINI: Thank you. 

14 MR. FREY: Thank you. 

15 MR. GIACOMINI: Questions/comments?

16 Jay.

17 MR. FELDMAN: Thanks, Paul. 

18 We're being asked to review the

19 Made With label. How do you feel about that

20 label and its impact in the market and

21 protection of consumers?

22 MR. FREY: It would be a --
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1 MR. GIACOMINI: If you would stand

2 at the podium it would be on the record.

3 MR. FREY: Yes, okay. To allow a

4 synthetic allergic preservative into that

5 category is -- the question is?

6 MR. FELDMAN: In terms of the Made

7 With label, which is current practice. 

8 MR. FREY: Yes. That's true in

9 practice. That's true to labeling that

10 there's no problem with that. 

11 MR. FELDMAN: Okay. Why do you

12 think more wineries -- I mean, you list eight

13 or nine here that are producing wine without

14 sulfites. 

15 MR. FREY: Yes, there's more than

16 that. That's just a few of them. 

17 MR. FELDMAN: Why do -- can you

18 explain to us why the market has not gone more

19 toward the, you know, organic labels as

20 opposed to the Made With? What's holding back

21 the other wineries from moving to the organic

22 label?
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1 MR. FREY: Most of the wine makers

2 are educated at universities where they

3 basically say you cannot make wine without

4 sulfites, even though there's an 8,000 --

5 actually 10,000 year history, evidence of

6 wine-making in China 9,400 years ago. Even

7 though most of the history is made without

8 sulfites and most of those people have never

9 made wine without sulfites.

10 MR. FELDMAN: So, do you believe

11 that use of sulfites in organic wine is

12 unnecessary?

13 MR. FREY: You don't need sulfites

14 in any wine-making including organic wine.

15 MR. FELDMAN: Okay. Thank you.

16 MR. GIACOMINI: Okay. The Chair

17 is going to please ask the public to be as

18 responsive as possible to the buzzer. We've

19 had a number of people already this morning

20 that have gone on and on a bit. We're going

21 to try to be more responsive to the buzzer

22 without the Chair needed to resort to be
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1 appearing rude. 

2 So, thank you.

3 MR. FREY: Thanks a lot. 

4 MR. GIACOMINI: Thank you. 

5 Yes, if you can just stay at the

6 podium with the microphone there, I think it

7 will come up better on the record. 

8 Next up Jackie, Lisa and Shannon.

9 MS. VonRUDEN: My name is Jackie

10 Von Ruden. I'm the Farm Certification Manager

11 for MOSA. I'm speaking for Holly Born who is

12 unable to be here today. She is also a

13 Certification Specialist and Staff Inspector

14 for MOSA. 

15 I would like to comment on the

16 handling and slaughter discussion document. 

17 First, from the processor's prospective and

18 second from the certifier prospective. 

19 I recently surveyed all the meat

20 and poultry processors that are currently

21 certified by MOSA for their reaction to

22 proposal parameters. Meat processors did not
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1 express any concern. I'd like to note some

2 concerns that two MOSA-certified poultry

3 processors have expressed regarding the

4 proposed guideline.

5 Both of these processors are small

6 scale and like most small scale poultry

7 processors, do not stun the birds before

8 placing them in a scalder, but they put them

9 in cones and cut the juggler vein to kill the

10 bird before it goes into the scalder. 

11 One processor in Illinois says he

12 feels that the proposed guidelines would add

13 excessive time and cost to his operation. 

14 Additionally, this operation is

15 operated under the Amish church rules as much

16 as possible so any camera systems would not be

17 allowed. 

18 A Wisconsin processor says that in

19 his opinion, stunning does not produce any

20 adequate bleed out of the birds and that this

21 has a negative effect on meat quality. He is

22 also not convinced that stunning is really
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1 more humane. He thinks that the proposed

2 guidelines as biased towards larger processors

3 and points out that in small scale operations

4 like his he can give more time and care in

5 handling the birds properly and observing that

6 they are indeed dead before they enter the

7 scalder. 

8 However, he is open to adopting

9 these guidelines but needs more research-based

10 data to show that stunning is superior in

11 terms of meat quality and animal welfare and

12 access to training to learn how to stun

13 properly. 

14 Next, I'd like to comment on the

15 proposed guidelines from MOSA's point of view.

16 Although MOSA supports the intent

17 of the guidelines, however, we have a lot of

18 questions regarding how as organic inspectors

19 and certifiers we will need to verify that

20 these parameters are being met. 

21 The discussion implies that

22 organic handler inspections will need to take
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1 place on slaughter days at processing plants

2 which are certified processors have told us is

3 really difficult to manage. Additionally,

4 most inspectors will need training on how to

5 effectively verify that the stunning has been

6 effective.

7 We also wonder how scoring methods

8 described in the document would be

9 implemented. Will inspectors need to observe

10 100 animals being stunned? This could really

11 increase inspection time and thus cost. 

12 For a small-scale plant how would

13 the score be aggregated over time? Would more

14 than one inspection be needed to achieve the

15 100 animal score? 

16 The discussion also implies that

17 organic inspections of crop producers would

18 need to take place on days when animals are

19 being handled for transport to the plant so

20 that handling and condition of transport can

21 be observed. How would this translate into

22 real life? For example, would an inspector
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1 need to verify the poultry were caught after

2 they had settled in for the night and then

3 return the next morning to further observe the

4 handling and processing? 

5 Further clarification will also be

6 needed. For example, the discussion document

7 notes that Halal and Kosher slaughter method

8 with some conditions would be allowed for

9 mammals but does not say whether these methods

10 are allowed for poultry. Thought discussion

11 yesterday did clarify that both methods would

12 also be acceptable for poultry, we request

13 that this be clarified in the document. 

14 In summary, it appears that these

15 guidelines, if implemented, would increase

16 animal welfare and could be quite acceptable

17 to both processors and certifiers. But a more

18 defined inspection and certification protocol

19 procedure would need to be -- would be needed

20 for certifiers to be able to truly verify that

21 they're being met. 

22 MR. GIACOMINI: Comments/
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1 questions? 

2 MS. VonRUDEN: Thank you. 

3 MR. GIACOMINI: Thank you. 

4 Lisa, Shannon and Bea James. 

5 MS. McCRORY: Hi. My name is Lisa

6 McCrory and I work for the Northeast Organic

7 Dairy Producers Alliance. And I'm going to be

8 making some points on the animal welfare

9 discussion document and if time permits,

10 origin of livestock.

11 NODPA is an organic dairy farmer

12 organization with a membership of 836 organic

13 dairy farmers. NODPA's mission is to enable

14 organic dairy family farmers situated across

15 an extensive area who have informed discussion

16 about matters critical to the well being of

17 the organic dairy industry as a whole. 

18 We want to first take this time to

19 thank Kevin Engelbert for his excellent work

20 and dedicated service as a member of the NOSB.

21 We also want to recognize that it takes a

22 family to support a farmer as NOSB member and
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1 Kevin's wife and children have worked along

2 side to make it possible for him to donate his

3 time and knowledge to his NOSB work on behalf

4 of organic agriculture.

5 We hope he continues to share his

6 knowledge with the Board in the future and

7 wish he and his family every success in the

8 future. 

9 And we also want to make note that

10 the financial sacrifices if Kevin and his

11 family while serving ont he Board highlights

12 the need to provide stipends to NOSB members

13 who are either full-time farmers or self14 employed industry professionals. The lack of

15 a stipend has prevented many good farmers how

16 earn their living from farming from

17 volunteering their time to serve on the Board.

18 For a dairy farmer this would include the cost

19 of a relief milker, extra help to complete

20 field work and an acknowledgement that when a

21 farmer leaves their farm in the control of

22 someone else, there are inevitable losses of
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1 income if only through a loss of milk

2 production.

3 We urge the USDA and NOP to

4 address this issue to insure that we have a

5 balanced membership on the Board that truly

6 reflects the unique mix of organic

7 agriculture.

8 And NODPA welcomes the recent work

9 of the NOP to provide guidance and more

10 clarity on how inspectors and certifiers

11 interpret different regulations. The most

12 recent recommendation by the NOSB Livestock

13 Committee assumed a certain level of knowledge

14 and understanding of livestock behavior during

15 the annual inspection by inspectors on behalf

16 of certifiers. 

17 While we applaud the large number

18 of highly qualified inspectors that do a

19 tremendous job with their interpretation of

20 the health and welfare of livestock, we also

21 have reports that some inspectors prefer to

22 work only from a checklist and have little
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1 experience and knowledge of livestock. 

2 We hope that the NOP as a creditor

3 of the program will increase their oversight

4 when it comes to the qualifications of

5 inspectors and the training that they received

6 from certifiers. 

7 And in relation to 205.239,

8 livestock living conditions, the mammalian

9 section. Regarding the invitation for public

10 input on stock rate charts. We strongly

11 believe that the organic animal welfare

12 guidance and standards must be sensible and

13 based on reasonable standards that are

14 determined by the realities of farming, good

15 husbandry, grazing, natural animal behavior

16 and natural healing. 

17 We do not support any space

18 requirements within the regulations for dairy

19 animals. Rather, an education of inspectors

20 to insure proper standards are achieved based

21 on guidance from the NOP.

22 We recognize the importance of
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1 requiring adequate space for animals to

2 exhibit their natural behavior during the non3 grazing season or during times of temporary

4 confinement. Dairy animals are managed in a

5 variety of different geographic locations and

6 under many different constraints to preserve

7 soil and water quality. Inspectors need to be

8 trained to recognize conditions that are

9 adverse to the animals exhibiting their

10 natural behavior during the times they are

11 temporarily confined.

12 An animal confined for breeding

13 will have a different requirement to one

14 confined for tabbing or one confined during

15 the winter storms. And animals confined in

16 northern Maine will need different housing

17 than one confined in southern California.

18 Detailing minimum average standards would

19 cause some operations to work to those

20 standards which may be inappropriate to their

21 location and facility.

22 The Livestock Committee's
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1 recommendations contain the table with a

2 minimum square footage for each animal

3 dependent on their size. There's no guidance

4 as to how that area is measured and we have

5 the following questions which have been raised

6 by our members.

7 Thank you. 

8 One, what is included in this

9 space in a free stall barn? 

10 Does it include the feeding alley

11 ways or just the stall area? 

12 In a tie-stall barn does it

13 include the lunging area that a cow uses to

14 stand which could also be the feeding area? 

15 If you have a mixed herd with

16 variable sizes, do you need variable sizes of

17 stalls or is the total designated area for

18 bedding space divided by the weight of the

19 total number of animals using the space to

20 find the average bedded space needed? 

21 Does the inspector need to come in

22 with a tape measure or will they be required
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1 to have the building dimensions and take an

2 average for the whole herd? 

3 So, we recommend that the

4 inspectors use a score card of the general

5 health of the individual cow as a percentage

6 of the whole herd which allows for many

7 different criteria to be used including

8 breeding, time of lactation, age, time of

9 year. That way if a producer is excelling in

10 most areas but weak in others they would not

11 be penalized. 

12 Thank you.

13 MR. GIACOMINI: Thank you.

14 Questions? Kevin. 

15 MR. ENGELBERT: First, thank you

16 very much for those comments we're getting

17 from the farmers. I'm very appreciative.

18 And as far as the stipend, I'd be

19 very careful to go down that road. I'd hate

20 to see that influence whether or not some was

21 put on the Board and I'd hate to see that any

22 type of resentment develop from other Board
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1 members that didn't receive the stipend. I

2 would think if it was considered it would be

3 either all of none for Board members for any

4 type of stipend.

5 And, yes, we have lost income by

6 me being on the Board and as I said Monday, no

7 one is going to be happier when I graduate

8 than my sons. But I knew that coming in and

9 I have a unique situation that they finally

10 came of age where I was comfortable doing this

11 and that's why I decided to run for the Board.

12 So, it could be a very touchy situation, but

13 I appreciate the sentiment. 

14 MS. McCRORY: I just want to say

15 that I recognize that and there's lots of

16 wonderful producers of many areas within the

17 organic sector that I think would also play a

18 critical role and probably they can't be

19 involved on the level that you've performed

20 because of their constraints. And I agree

21 that if there is a stipend that it should be

22 universal.
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1 But if we want to have good

2 representation from the whole organic

3 community, I think we're missing out on

4 certain key contributors. 

5 MR. GIACOMINI: Other comments or

6 questions? 

7 All right. Thank you. 

8 MS. McCRORY: Thank you.

9 MR. GIACOMINI: Shannon, Bea James

10 and Phil LaRocca. 

11 MS. SZYMKOWIAK: Hello. My name

12 is Shannon Szymkowiak. I may have Jim beat

13 with the last name there. 

14 I'm the Promotions and Education

15 Manager at Whole Foods Co-Op in Duluth,

16 Minnesota, current receiving five inches of

17 snow. 

18 Although I don't do inspections I

19 am an IOI trained inspector and a novice bee

20 keeper.

21 I grew up in the State of

22 Minnesota and I'm the granddaughter of two
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1 sets of dairy farmers. And spent a lot of

2 time out on the farm to keep me out of

3 trouble. They were traditional farmers and

4 they focused mainly on dairy, pork and egg

5 production. And they also grew alfalfa and

6 field rotation as their primary methods of

7 completing that cycle. 

8 Their care of the land and animals

9 illustrated the spirit of sustainability and

10 good animal husbandry. They wouldn't consider

11 keeping animals in a barn that wasn't

12 regularly cleaned and they wouldn't let their

13 animals suffer by way of heat, cold or

14 crowding. It was just the way it was done. If

15 an animal was going to give you something,

16 milk, eggs, meat, whatever, it's your duty to

17 care for that animal in a way that you'd be

18 cared for if someone was in charge of feeding

19 and caring for you.

20 Respectfully, panel, this is your

21 job. When I purchase organic food you are in

22 a way in charge of feeding me. The decisions
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1 you make gave a direct and profound effect not

2 only on the life quality of the animals in our

3 care but the effect on my quality of life and

4 the quality of life of everyone who puts their

5 trust on the label reading USDA Organic.

6 When I first began working in the

7 natural foods industry about 17 years ago, it

8 was right before the very first organic

9 standards were released. When the initial

10 rule was presented for comment which allows

11 GMOs, the Radiation Commission of Sewage

12 Slage's field input, I began to pay attention.

13 I stopped being the deli worker who was in

14 charge of the cheese crew every Wednesday and

15 became an agent of change. 

16 Many people including myself spoke

17 up about this and it made a difference and we

18 appreciate that. Thank you very much.

19 I now work for a natural foods co20 op in Duluth that is a certified organic

21 retailer in every department of our store. I

22 train our staff on the basics of the rule and
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1 I do outreach in the community about natural

2 and organic food and I'm asked at nearly

3 everyone of my 50 to 75 presentations a year.

4 Is paying for organic food worth it? Is there

5 really a difference? And I would argue that

6 if we don't take a stand I'll soon have to say

7 no. 

8 The situation regarding chicken

9 and egg production in organics must be

10 addressed both from a food safety and animal

11 husbandry standpoint. We cannot allow the

12 organic label to become pointless. 

13 Organic products do get a premium

14 price in the marketplace and when you're

15 buying from a small to medium farmer who is

16 not gaining subsidies, who uses manual labor

17 and documenting, this premium is a small price

18 to pay to insure good quality for the life of

19 the farmer as well as the animals in his or

20 her care. However, when as a customer I see

21 chicken houses that hold thousands of animals

22 who have little to no access to the out of
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1 doors, I start to lose confidence in that

2 label. 

3 The argument has been brought up

4 that it is impossible to be profitable unless

5 an operation is a large one. But many farmers

6 out there would prove the larger companies

7 wrong. Someone earlier was speaking about

8 Larry Schultz and I've known Larry Schultz for

9 years. I bought eggs from him when I was a

10 dairy buyer at Line Hille Co-Op in the '90s

11 and we purchased his eggs and meat products

12 now at a foods co-op where I work currently.

13 He's a successful example of how

14 you can do the right thing and still raise

15 your family. He got the 5 egg rating and I

16 wouldn't doubt it for a second. He really

17 does a good job. 

18 I ask you today to put firm, clear

19 language into the NOP regarding animal

20 housing, clean water, access to the out of

21 door for all of the animals and enforcement of

22 this rule is imperative to the assurance in
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1 the organic label.

2 I also ask you to disallow organic

3 labeling by companies who do not abide by this

4 clear language. Equal footing for all

5 producers is vital to customer confidence and

6 the survival of the smaller farmer.

7 I do not believe that if a farmer

8 is large they shouldn't be allowed organic as

9 long as those companies play by the same

10 rules. Organic is supposed to be another way.

11 Shoppers make choices sometimes sacrificing

12 other things in their households to buy

13 organically certified food. This label should

14 mean more than another value added product to

15 large producers who have no interest in

16 following the spirit of the law and barely

17 skirt the letter of it. 

18 I'm thankful for the opportunity

19 to speak out about this issue and I hope the

20 interest of the independent organic farmer,

21 the consumer and the animals are considered

22 implemented in enforcement of the national
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1 organic program.

2 Thank you.

3 MR. GIACOMINI: Thank you.

4 Questions/comments.

5 Jay. 

6 MR. FELDMAN: Thanks for being an

7 agent of change. We need that. 

8 I'm curious because you intersect

9 with consumers about some of your thoughts on

10 integrity issues. And have you been listening

11 to the debate on synthetic/non-synthetic?

12 MS. SZYMKOWIAK: I just caught it

13 this morning. I just came in today for this

14 one.

15 MR. FELDMAN: Maybe I'll ask you a

16 more general question then.

17 I find on my experience with the

18 Board so far that we face sometimes questions

19 that lack clarity in terms of their answers.

20 Especially on issues -- this issue of

21 synthetic/non-synthetic. And I'm wondering

22 from a consumer prospectus, where do you think
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1 the precautionary principle on issues like

2 that fit? In other words, where do you think

3 we should air as a Board when we are face with

4 decisions for which there is disagreement on

5 basic issues -- that some would define as

6 issues of integrity -- organic integrity? Do

7 you get a sense from consumers that they would

8 prefer we air on the side of caution or that

9 we just wing it?

10 MS. SZYMKOWIAK: The sense that I

11 get is airing on the side of caution because

12 I do get questions not only about our own

13 ruling on our own organic standards, but I

14 also get questions because we're in northern

15 Minnesota we do get a lot of produce from

16 Mexico, California about the integrity of

17 those products and are they being inspected to

18 the same standards that a farmer in Wisconsin

19 is. There's a lot of skepticism out there.

20 And I run into that just about every

21 presentation I give. 

22 MR. FELDMAN: Thank you. 
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1 Thank you, Mr. Chair. I just want

2 to correct my comments. I don't want to

3 mischaracterize. I know a lot of work has

4 gone into this on the Board of this issue of

5 synthetic/non-synthetic. But I'm trying to

6 grapple with this issue of disagreement,

7 honest disagreement on how we define things

8 without denigrating the important work that's

9 gone on by this Board to try to create clarity

10 around these issues. 

11 Thank you. 

12 MS. SZYMKOWIAK: If I may? 

13 Sometimes you'll see an ingredient

14 label where non-organic producers will list

15 their sourcing, you know, behind the

16 ingredient so that the customer -- the

17 consumer is knowing what it is and that is

18 something that I point out when I'm talking

19 about label reading to groups that I speak to

20 and that may be a possible solution.

21 MR. GIACOMINI: Yes, the -- yes,

22 thank you. 
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1 Are there any other questions? 

2 Yes, thank you. 

3 The presentation of an action of

4 this Board as winging it if I heard you

5 correctly is a bit of a misrepresentation with

6 the amount of work we do on it. 

7 MR. FELDMAN: That's why I offered

8 the correction, Mr. Chair.

9 MR. GIACOMINI: Yes.

10 MR. FELDMAN: I believe that there

11 is sincerity on all sides of this issue.

12 MR. GIACOMINI: Thank you.

13 Okay. Bea James, Phil LaRocca and

14 George Bass. 

15 MS. JAMES: Okay. This is going

16 to be fast forward so hold on.

17 For the record, my name is Bea

18 James. Good morning, Mr. Chairman, esteemed

19 NOSB Board Members and NOP. 

20 I'm here today before you as a

21 retail representative from Lunds Food

22 Holdings, a small family owned 21 store retail
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1 chain in Minneapolis with certified organic

2 produce departments, a certified organic

3 distribution center and over 11,000 organic

4 and natural products throughout the store. 

5 Regarding Made With Organic. The

6 general direction of the recommendation is

7 correct because the majority of consumers are

8 still at an entry level with understanding

9 organic products. Organic food is still a

10 small percent of the total retail sales in the

11 market and your mainstream consumer needs

12 clear direction on the front of the package to

13 help grow the organic industry.

14 Somehow we need to do a better job

15 of explaining the organic content to our

16 consumer on products that fall below 95

17 percent. That's 95. But to add certified to

18 USDA guidelines mocks the USDA seal and adds

19 more confusion to an already puzzling organic

20 packaging.

21 My suggestion is to clearly tell

22 the consumers what they're getting. The NOP
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1 might want to consider requiring manufacturers

2 that fall below 95 percent organic ingredients

3 to put the percent of the organic ingredient

4 in the USDA seals. Yes, I did say in the USDA

5 seal. Just say it like it is and add the

6 percent of the organic ingredients right in

7 the USDA seal. Yes, bold. Yes, possibly a

8 nightmare for certifiers and manufacturers,

9 but consumer would love it. And this would

10 eliminate any consumer confusion and cut down

11 on my training and education time in the

12 store.

13 Exhibit A for your consideration.

14 Animal welfare discussion. 

15 Consumer expect animal welfare

16 from organic production and the pictures on

17 organic packaging has led them to believe that

18 we are taking good care of our smiling,

19 dancing, happy cows and chickens. Please

20 carefully consider the use of the word

21 "access". Access does not mandate animals to

22 be outside and as we learned from the pasture
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1 rule you need to look carefully at where you

2 should be prescriptive to restrict loopholes.

3 I ask these questions for the

4 Livestock Committee. 

5 1. Do animals go outside just

6 because there's a small door for access or is

7 this a learned behavior that must be

8 encouraged by the farmer? 

9 2. Should inspectors just look

10 for access to outdoors to be in compliance or

11 should they also be inspecting from our

12 concrete evidence that animals are accessing

13 the outdoors for a healthy amount of time?

14 Animal welfare is so important that I thank

15 the Livestock Committee for bringing it to the

16 forefront.

17 Nutrient vitamin and mineral

18 discussion document. Fortification is a

19 byproduct of over-processing. Industrial

20 processing often removes nutrients to get to

21 a final product that generally is developed

22 for longer shelf life and to mask the hardy
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1 fibrous and favorable quality that comes from

2 unaltered whole foods. However, if the

3 organic industry is going to have highly

4 processed organic versions of junk food then

5 we should fortify it. 

6 There's a nutrition value program

7 for retailers called New Val. Retailers like

8 Wegman's, Coburn's and HI-V and many more are

9 using it. In a nutshell, the program tells

10 consumers what to eat based on a number that

11 is shown on the shelf tag. 

12 The algorithm considers nutrient

13 sin the numerator and trans fat, sodium and

14 sugar and such the denominator to determine a

15 score. A high score is good and means lots of

16 nutrients and a low score is bad and means

17 poor nutrients. Added nutrients go a long way

18 in the New Val program. And so it is

19 troubling to see Strawberry Captain Crunch

20 score higher than Peace Cereal or Alvarado

21 Street Sprouted Wheat Bread score lower than

22 Wonder Bread.
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1 Now, Exhibit B for your

2 consideration, information on the New Val

3 Program. 

4 Personal care. Last year the NOSB

5 directed the NOP to solve the problem of

6 mislabeled organic personal care. While the

7 NOP has been slow to act, whole foods market

8 is leading the way. In June of this year

9 Whole Foods became the first retail chain to

10 adopt an organic integrity policy for health

11 and beauty care products sold in their store.

12 Congratulations to Whole Foods for setting the

13 bar for our industry and to the many co-ops

14 who have also adopted Whole Foods' lead. We

15 at Lund's believe in this direction and will

16 be following suit in holding not only the

17 natural organic body care industry to the same

18 standards but the conventional body are

19 industry as well.

20 Many of these conventional

21 cosmetic companies misuse the word "organic".

22 Although the USDA has no authority over
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1 production and labeling of non-agricultural

2 body care products, they should have authority

3 over the use of the term "organic" on these

4 products. 

5 205.300 needs stronger language

6 regarding the use of the term "organic" as a

7 marketing or branding term. I respectfully

8 ask the NOP to consider this in their response

9 to the NOSB personal care recommendation to

10 reduce this type of mislabeling in my

11 exampling. 

12 In my examples, Exhibit C for your

13 consideration and for your grooming pleasure

14 if you're brave enough to use those

15 conventional products.

16 And last, congratulations Kevin,

17 Dan, Jennifer, Jeff and Joe for your five

18 years of service. Enjoy your soon to be open

19 slots in Outlook. I know your family, friends

20 and pets will enjoy seeing you again.

21 I have a huge box of chocolate as

22 a way to show appreciation and respectfully
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1 submit them as Exhibit D and there is plenty

2 for everybody. 

3 Thank you.

4 MR. GIACOMINI: Thank you. 

5 Comments or questions for Bea? 

6 Kevin. 

7 MR. ENGELBERT: I was very

8 interested in your comments about fortifying

9 food. Even if you had all the vitamins and

10 nutrients that were certified organic you

11 couldn't live on them alone. You've got to

12 have wholesome food. 

13 How do we go down the road of

14 allowing organic food to be fortified because

15 of all the processing that's done and yet

16 still make the distinction between that food

17 on the shelf and the one that is local, hasn't

18 been processed and get consumers to pay

19 assuming the extra cost and what is, I would

20 consider to be, a true organic food as opposed

21 to one that's been fortified?

22 MS. JAMES: Well, I agree with you
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1 wholeheartedly, Kevin, and I think that's a

2 question that should have been posed when we

3 decided -- the organic industry decided to get

4 into processed food.

5 If we're going to have processed

6 food a lot of the nutrients are taken out of

7 processed food and you've got conventional

8 like products that are being fortified with

9 synthetics. And to Joe's point, you know, and

10 I know it might shock him to hear me say this

11 that some synthetics are not all bad. And

12 when you've looking at the nutrition of a

13 product and if you need to fortify it to re14 enter the nutritional value that was lost

15 during processing, then I just ask the Board

16 to respectfully consider that. 

17 MR. GIACOMINI: Joe. 

18 MR. SMILLIE: Right. On the Made

19 With label, you recommend the direction of our

20 recommendation but not the details of it. So,

21 in other words, you also believe that this

22 label claim needs some support? You just
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1 didn't like the way we proposed the support by

2 adding the word?

3 MS. JAMES: Yes. I think it's

4 confusing.

5 For instance, if on the shelf you

6 have a product with the USDA organic seal, and

7 then you have a product right next to it that

8 doesn't have the seal but says Made to USDA

9 Guidelines or Regulations, that is very

10 confusing for the consumer and it dilutes the

11 message that I think we've tried to build

12 around the USDA seal.

13 So, somehow -- we just need to

14 have truth in labeling and that's why I passed

15 around -- my son helped me with that. He has

16 Photo Shop, that example of the USDA seal

17 where it says organic and then it says the

18 USDA and it has the percent right there. And

19 that opens up the door for truth in labeling

20 and it cuts to the chase and it tells the

21 consumer exactly what they're getting. And I

22 know certifiers are probably cringing at the
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1 idea. But I do think that it's a healthy

2 solution for the consumer. And the consumer

3 perspective is one of the things that I think

4 needs to be more highly acknowledged as we're

5 developing what the final end product is going

6 to be on the shelf.

7 So, you know, to answer your

8 question. Yes, the Made With is directionally

9 accurate, but I think that it needs more work

10 in figuring out what the solution is. 

11 MR. GIACOMINI: Jay. Oh, Joe,

12 follow up? 

13 MR. SMILLIE: Yes, I just wanted

14 to go back to Miles. I don't want, you know,

15 to take wind out of your sails or spill the

16 beans or whatever the right expression is. But

17 the upcoming guidance that the department is

18 going to be issuing for the Made With

19 labeling. Do you feel that there's any

20 synergy between what we're struggling, groping

21 to try to present to the consumer and what

22 you're dealing with on an enforcement level
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1 about the Made With label? Is there anyway

2 that our recommendation could be helpful in

3 clarifying and clearing up this what we

4 believe to be valuable label claim that

5 somehow is just really not working out there

6 in the marketplace? 

7 MR. McEVOY: We haven't looked at

8 your recommendation in light of the

9 development of the Made With Organic draft

10 guidance. So, we haven't done that work.

11 We'll take a look at it whether or not you've

12 passed it as a recommendation or not. We can

13 take a look at it in terms of how it relates.

14 What the draft guidance on Made

15 With Organic labeling -- Made With Organic

16 Products addresses is the percentage claim on

17 a Made With Organic Product and the types of

18 ingredients that can go into the 30 percent.

19 So, those are the two issues that are being

20 addressed in that particular draft guidance.

21 So, it's not directly related in terms of what

22 you're doing with your proposed recommendation
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1 on Made With Organic. Certainly doesn't have

2 anything about using the term "certified" to

3 USDA guidelines. On the Principal Display

4 Panel it does talk about the percentage claim

5 on the Principal Display Panel and the draft

6 will say that if you do have a percentage

7 claim on the Principal Display Panel then you

8 must also have a claim that it is a Made With

9 Organic Product. 

10 MR. GIACOMINI: Okay. 

11 MR. FELDMAN: Just one question.

12 Thanks, Pete. 

13 You're talking about labeling

14 percentage ingredients on those products for

15 which -- that fall below the 95 percent

16 category. So, how do you deal with the 95 to

17 100 percent and, you know, wouldn't consumers

18 want to know, for instance, that there is

19 somewhere between 95 and 100? A 100 would be

20 labeled certainly. And then we currently have

21 the organic label which is 95. How do you

22 reconcile not displaying the percentage 95 and
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1 above? 

2 MS. JAMES: Well, I guess and this

3 is just my opinion about this. Ninety-five to

4 100 I think is almost the same thing. I thin

5 kit's very hard to get to a point where you

6 actually can say 100 percent organic and for

7 reasons that I know you are all familiar with.

8 So, 95 percent to 100 is something that we've

9 already done diligently on the packaging by

10 just having the USDA seal having that option

11 that the 95 and 100 are the only two

12 categories where you can actually put the USDA

13 organic seal on the front of the package. 

14 So, why change that? That seems

15 to be working. It's everything below that

16 that's where it falls apart for the consumer.

17 MS. HEINZE: Thank you for your

18 comments and thank you, in particular, for

19 bringing in these lovely personal care

20 products which are a great example of the

21 problems we're seeing on the retail shelf.

22 I was just hoping that once they
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1 get to you, John, you could just directly take

2 them to Miles. 

3 MS. JAMES: I think it's a pretty

4 good example. I think it's a pretty good

5 example of how we're confusing the consumer.

6 When you have that one pamphlet that I have

7 there that shows a bunch of carrots with the

8 wrap-arounds organically grown which is, you

9 know, that's the only thing. It has to be

10 organic on an agricultural product if you see

11 that twist tie in the supermarket. And then

12 that's part of their marketing campaign is

13 saying that, you know, organic carrots,

14 essential oil is in the product and they're

15 calling the front of it organic and I included

16 it in there a list of the percentage of all

17 the different body care products and most of

18 them fall within 30 percent. And they're

19 calling right on the front organic. So, here

20 you've got body care totally messed up saying

21 organic. And then you've got the Made With

22 that actually has organic and they're not
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1 getting credit. And it's just kind of a mess

2 and I think from the consumer perspective, it

3 needs to be fixed. 

4 And I thank you for listening to

5 me. 

6 MR. GIACOMINI: Kevin.

7 MR. ENGELBERT: I spoke with NOP

8 staff years ago when I first got on the Board

9 about the percentages on the label and like

10 you said I got completely shot down. Because

11 I thought it ought to say 100, 95 or 70 and

12 the argument then was and it's probably still

13 valid, some of these labels are so small

14 consumers aren't going to be able to

15 distinguish between those numbers.

16 MS. JAMES: Well, and that's

17 something that should be taken into

18 consideration. 

19 If you go the route of putting a

20 percent right in the USDA seal, there should

21 be guidelines like they're currently are about

22 how to use, you know, organic in labeling.
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1 There needs to be guidelines about how that is

2 actually executed on the package.

3 MR. ENGELBERT: But I had never

4 thought of the idea of only having it for the

5 70 percent. That may very well work. I

6 hadn't thought of that because then if they do

7 see a percentage, no matter how tiny, they

8 know that it's a 70 and anything else is 95 or

9 above. 

10 MS. JAMES: I got you. I got you.

11 MR. GIACOMINI: Okay. 

12 MS. JAMES: Thank you.

13 MR. GIACOMINI: Further

14 questions/comments? 

15 Okay. Thank you.

16 We're reached out time for another

17 break in our scheduling. Since the last break

18 we've gone from a half an hour behind schedule

19 to an hour behind schedule. So, we're asking

20 everyone to please be more considerate of our

21 time requirements as we move on through the

22 day.
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1 Fifteen minutes. I'm asking

2 everybody. Fifteen minutes.

3 If at 10 minutes we could have

4 Miles and if I could have Miles and Richard

5 Matthews and Kim Dietz and Tina, we have some

6 issues to go over. If we could meet with

7 those in 10 minutes and then we'll reconvene

8 in 15.

9 Thank you. So, five after. 

10 (Whereupon, the above-entitled

11 matter went off the record from 10:49 a.m. to

12 11:11 a.m.) 

13 MR. GIACOMINI: We have a quorum

14 of the Board. We're ready to restart, again

15 asking everyone to please be aware of the time

16 situations. We still have a unknown flash

17 drive up here if anybody -- oh, we found that. 

18 Thank you. This time I got a chocolate. All

19 right. I'm not sure you get a chocolate with

20 an unknown flash drive. 

21 Okay. Lisa, are we ready? Sound

22 ready? Okay. 
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1 First up as we continue Phil

2 LaRocca, George Bass and Beth Unger for the

3 proxy.

4 Go ahead. 

5 MR. LaROCCA: Good morning. Thank

6 you for the time to speak here. It's been

7 many years since I've addressed this Board but

8 in the past I have worn a lot of carpet out. 

9 My name is Phil LaRocca. I have been an

10 organic -- in the organic industry for 35

11 years. I was first certified in 1975. I

12 believe I was the first certified apple

13 organic grower in the State of California. 

14 I've been an organic inspector.

15 I've sat on the California Certifier Organic

16 Board. I've been the Vice President-- I've

17 been President on the Board and in the interim

18 of the USDA taking over the standards, my

19 title went from President to Chairman of the

20 Board. 

21 Twenty-six years ago I started in

22 the wine business. I started off with the
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1 French guy at the time that seemed kind of old

2 but as I look back at it now he was only a

3 couple of years older than I am now. But we

4 decided to make an organic wine and there was

5 no rule sand regulations. There was just an

6 organic community and it was in the organic

7 community that we all knew that synthetics

8 weren't allowed in organics. So, I didn't

9 waive this anti-sulphur dioxide flag, it was

10 just that we felt that you couldn't add

11 synthetics in wine and that's why we started

12 making a wine with sulphur dioxide.

13 We started off with 500 cases. My

14 winery is now 25,000 case production.

15 In the early days making an

16 organic wine just says that growing certain

17 organic crops wasn't very easy. But we

18 figured it out with new chemistry that we

19 brought to the table, with new wine-making

20 equipment, we made a damn good wine. I throw

21 this out in jest. But one of the arguments

22 that people say about organic wines is they
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1 won't keep. 

2 Well, on New Year's Eve Martha

3 Stewart drank one of my sparkling wines that

4 we had and gave us a write-up. So, you know

5 that Martha would not drink a bad wine. So,

6 we got Martha on our side.

7 At any rate, I dealt with this

8 issue 10 years ago. And to this day still

9 believe that synthetics should not be allowed

10 in organic production. But I was very much

11 involved with working with this Board and the

12 NOP at the time to come up with the Made With

13 Organic label. And we did that to satisfy the

14 grape growers that were growing grapes

15 organically and then bringing them to a winery

16 that wanted the process some organic grapes.

17 I want to point out at this time

18 too that there are organic wine made before

19 there was Made With Organic Grapes. The Freys

20 in Little Rock is one of the first people that

21 grow grapes organically and then process our

22 wine organically. 
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1 So, we work really close on this

2 and if you don't know the history, this Board

3 should look it up. But to get organic-- Made

4 With Organic label is not an easy thing. We

5 had to do some back dooring and I worked with

6 this Board, a couple of senators from the

7 State of California and Kentucky where they

8 piggy back this Made With Organic because if

9 you remember the Food and Production Act of

10 1990 outlawed sulphur dioxide in any form of

11 organic production. So, this thing was piggy

12 backed and if I remember correctly on a bill

13 to give senior citizens a lower price for

14 genetic drugs. Oh, and by the way, sulphur

15 dioxide can be used in Made With Organic

16 Grapes in the NOP program. So, that's the

17 story behind this. 

18 I, you know, spent a lot of my

19 time and my passion in this thing here.

20 I do teach viticulture in one of

21 the local colleges but 99 percent of my income

22 comes off of my organic wine. I have four
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1 kids. All four kids are making their income

2 off of my organic wine. 

3 And if you'll look at the Frey

4 paperwork, when people say you can't do this,

5 there were 3.75 million bottles and this is

6 just a rough estimate on the low side that

7 were produced and consumed in 2009. So,

8 you're going to tell the 3.75 million people

9 that bought certified organic wine that it is

10 no good, then you should be asked of yourself.

11 And in conclusion, I want to say

12 that I used to testify 10 years ago and this

13 figure has gone up but it was 119 different

14 synthetics that were allowed in the use of

15 commercial wine-making. And the only one that

16 the public has to be notified about is the use

17 of sulphur dioxide. So, it would be an awful

18 oxymoron to have a USDA certified organic wine

19 that has -- that's going to allow the only

20 chemical that the FDA makes it mandatory for

21 wineries to put on their bottle. 

22 Questions. 
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1 MR. GIACOMINI: Questions/

2 comments? 

3 John.

4 MR. FOSTER: Let's just say the

5 rule changes and one would be able to make an

6 organic claim. Would you highlight the fact

7 that you do not use sulphur dioxide even more

8 than you do the same amount you do? 

9 MR. LaROCCA: We've talked about

10 that. We're actually afraid that we might not

11 be able -- just like you can't put-- we don't

12 use genetically modified yeast on our label.

13 They might stop us from using saying that we

14 don't use any sulphites on our label just like

15 the bovine growth hormone issue with wine. 

16 And I'd also like to add on this

17 too, John, that in terms -- I don't know why

18 the opponents are pushing for this if they

19 think that they're going to make -- if this is

20 going to be an economic factor to them which

21 shouldn't be factored into organic. But we

22 have to factor it in because as being the
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1 first people that pioneered this industry,

2 it's going to hurt our business. And I don't

3 think that that would be fair. 

4 Joe. 

5 MR. GIACOMINI: Again, Joe. 

6 MR. LaROCCA: Excuse me. Joe and

7 I go way back. Excuse me. Mr. Chairman,

8 excuse me. 

9 MR. SMILLIE: So, Phil, I just

10 want to be clear for the public record that

11 you're certified organic wine, but you're not

12 opposing the continuation of the Made With

13 Organic Grapes. So, you're more than happy to

14 continue to allow organic grape growers to

15 have their grapes sold as -- in wine that is

16 Made With Organic Grapes and the distinction

17 being that the sulphites aren't allowed and

18 the certification -- that the grape growers

19 could still have a market for their

20 organically grown grapes?

21 MR. LaROCCA: That is correct,

22 Joe, and if you look at what is it. 2118 says
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1 if you can do it naturally, then you shouldn't

2 add a preservative or you shouldn't have to

3 add a synthetic. So, I'm going along with

4 that with organic but I also say, I feel if

5 you make a crappy potato chip when you put

6 organic potatoes in it, you can tell the

7 consumer that. So, I'm not opposed to the

8 Made With category. 

9 MR. GIACOMINI: Jay. 

10 MR. FELDMAN: Thank you for your

11 comments.

12 Are there any examples that you

13 can come up with that would justify the need

14 for sulphites in organic wine production?

15 MR. LaROCCA: Absolutely not. And

16 I say that because it's harder. You can go

17 to, for example, go to an organic carrot

18 grower and ask him if he could use a pre19 emergent Round Up before he plants his

20 carrots. Of course, he's going to make it

21 easier for him. You know, sulphites make it

22 easier for the wine maker. So, other people
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1 that are listed on that presentation that Paul

2 gave you, they'll tell you, we work harder at

3 it. 

4 MR. FELDMAN: Thank you.

5 MR. GIACOMINI: Thank you. 

6 MR. LaROCCA: Thank you. 

7 MR. GIACOMINI: George Bass, Beth

8 Unger with the proxy and Dave Martinelli.

9 MR. BASS: Unfortunately, our

10 manager had a family death so we have another

11 proxy that's doing our time. 

12 So, to the committee and the staff

13 many thanks for all your time, all your hours

14 helping the NOP and NOSB, producers and

15 customers. Thank you especially for the

16 volunteers.

17 I want to talk to you about those

18 barns, the hens, the porches and then two

19 surveys.

20 Number one, we have about 6,600

21 layers in each barn. We have about 12 barns.

22 We have wonderful windows on each side of the
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1 barn. We have benches on both sides with feed

2 and also water. In the center are the nests.

3 There is a division in the middle so they're

4 for 3,200 or something and another 3,300. So,

5 that's really what goes. It's an old pipe,

6 but it's good. I think it's wonderful.

7 Also, I just want to explain a

8 little bit of hens. A lot of people don't see

9 a hen --

10 MR. GIACOMINI: George? You not

11 only need to be at the mic but you need to be

12 at the podium because on the record it's

13 collected through the other microphone. 

14 MR. BASS: Oh. 

15 MR. GIACOMINI: So, one is the amp

16 system, the other one is on the record. So,

17 yes. Just stay right there and--

18 MR. BASS: Right here?

19 MR. GIACOMINI: Yes. 

20 MR. BASS: Okay. All right.

21 Trying to explain -- I think

22 they're very happy. I think those hens are --
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1 I think they're very, very happy.

2 Early in the morning they start at

3 about 5:30 for breakfast. Take feed and water

4 on the benches. And then number two, the hens

5 jump down onto the floor and they jump up

6 again to the nest too. And they walk, they

7 run, they jump again. They jump up and down,

8 up and down. And they're having a wonderful

9 time. They have good exercise. 

10 Then afterward they have a little

11 bit of a burrow into the nest and so they have

12 a nap. And their eyes are shut, quite a few.

13 And then others stay in the burrows and then

14 they have a great dusk bath. I don't know if

15 you've ever seen them. Maybe a lot of people

16 here -- maybe they have some, they understand.

17 They really have a lot. 

18 But we think it's good and I think

19 they have -- I think those hens are much, much

20 better inside while they're outside. 

21 Not the moon space but anyway. And

22 then there is more exercise, more social
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1 interviews, Then the day is done at about

2 6:30 p.m. And the porches -- this is a

3 problem but I think it's not a problem at all.

4 I think it's at 2002, the porches were

5 certified. They are compliant and they are

6 legal. I think the porches have a lot of air,

7 a lot of sun, especially on the sides and good

8 health. And we don't have any diseases, no

9 worms, no migration of wild birds with Avian

10 Flu, no fox and coyotes, no manure, goes into

11 a huge reservoir. A lake very close to us for

12 the water of Boston of about 30 towns. So,

13 they need -- okay. 

14 I've got two surveys. One to talk

15 about 100,000. They finally got 80.5 positive

16 of about thee hens inside. And then two we

17 had another survey and then we had about 450

18 fertilized and this time the positive was

19 96.2. So, therefore, summary. 

20 I just want to talk about one

21 thing a 250 million dead of the poultry people

22 in China in that area. It's not here in the
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1 United States but actually there are 63

2 countries at least of this Avian Flu. It's

3 very hot and the porches -- summary. The

4 porches continue as a compost of the past and

5 all the future.

6 Thank you very much. 

7 MR. GIACOMINI: Okay. Thank you. 

8 Questions and comments? Okay.

9 Lisa, could you put the picture of

10 the porch back up? 

11 Could you tell us what the floor

12 and the roof on those are?

13 MR. BASS: Say that again, sir?

14 MR. GIACOMINI: Could you tell us

15 what the floor surface and the roof on those

16 porches are? 

17 MR. BASS: The floor. 

18 MR. GIACOMINI: At the mic please.

19 MR. BASS: Right here. 

20 MR. GIACOMINI: No, the floor in

21 the porch, what is the flooring and what is

22 the roof?
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1 MR. BASS: The boards outside. 

2 MR. GIACOMINI: Boards, okay. And

3 then what's the roof on that?

4 MR. BASS: This is plastic so the

5 sun comes through.

6 MR. GIACOMINI: Okay. 

7 MR. BASS: Yes.

8 MR. GIACOMINI: Okay. Thank you.

9 Okay. Beth Unger, Dave Martinelli

10 and Edward Gildea. 

11 Beth. You're the proxy.

12 MS. UNGER: Good morning. I'm

13 Beth Unger with Crop Cooperative and I'm going

14 to give you a little time back and keep this

15 very brief.

16 I was pretty impressed with

17 yesterday's discussion and I just want to

18 respond to that a little bit. But first I

19 want to thank Lisa McCrory for her comment on

20 the animal welfare document. I thought that

21 was very well thought out and very well

22 presented. 
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1 And second to finish up my comment

2 from Monday, I wanted to address the nutrient

3 vitamin and mineral and Sunset Review portions

4 of the agenda in tandem. 

5 But beginning with OTA's comment.

6 The Organic Trade Association comment on this

7 particular topic was pretty well done and they

8 did address the questions of the Handling

9 Committee and I thought that was way better

10 than my comments. 

11 But I want to go on and tie those

12 two together. Because unless I am not

13 understanding what is being said at the April

14 meeting and then again at this meeting, this

15 is my understanding.

16 I have the National Organic

17 Program twice now in reference to the nutrient

18 vitamin and minerals discussion, comment on

19 having the committee take a look at the 1995

20 recommendation. I think that is appropriate.

21 I think that is appropriate because the

22 recommendation really had a different
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1 intention in what the ultimate listings did.

2 Also, a completely different

3 Board, the 2000 Board in response to the

4 pending final rule, the proposed rule that

5 commented on the items in there and made it

6 perfectly clear in their comments that they

7 disagreed with the annotation that was put on

8 nutrient vitamin and mineral listing which was

9 at 21 CFR 104.20. I think that both of those

10 things are very relevant things to review and

11 to look at. 

12 And going back to, you know, those

13 two comments, and how it relates to Sunset

14 Review, the policy that you have before you

15 that took up a considerable amount of meeting

16 time last evening in discussion which was a

17 very healthy discussion, I'm going to go back

18 to being probably the only person in this room

19 or on record that stated I think that the NOSB

20 is limiting itself when they want the

21 annotations to only be more restrictive. That

22 was a comment that Jay had mentioned in his
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1 presentation about respect the work of other

2 Boards. There were two other Boards in

3 relation to this one specific listing that had

4 an issue with how everything played out.

5 If the Policy Committee's

6 recommendation goes through with that

7 restrictive part of annotations, the Handling

8 Committee's hands are tied. Why bother

9 reviewing the 1995 recommendation or the 2000

10 omnibus response to the proposed rule? 

11 Dan and Kevin, thank you very much

12 for your discussion during the 101B

13 discussion. I thought you two brought great

14 clarity to that whole recommendation. I would

15 hope the committee would go back and take a

16 look at the things Dan and Kevin had to say

17 about it because I believe in that

18 recommendation clarity is important and the

19 two things that they clarified were good audit

20 trails and ownership issues and I thought

21 those were quite relevant. 

22 I promised I would shorten my
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1 time. And so in closing, just to give you

2 about 45 seconds back, please when the next

3 Livestock Committee takes up the methionine

4 thing all over again, we need a new text

5 review. The first one was flawed and secondly

6 I'm totally looking forward to the USDA

7 supporting the research of methionine --

8 synthetic methionine in poultry diets. 

9 MR. GIACOMINI: Questions? 

10 Joe. 

11 MR. SMILLIE: You weren't the only

12 person. I was also thinking that but again

13 the idea as our charge is to restrict

14 synthetic use which I've always felt

15 uncomfortable with but I didn't say anything.

16 But you brought up an excellent point that

17 simply limiting it to restricting annotations

18 really does tie our hands. There are many

19 things beyond -- as well as restricting and

20 the example of the accessory nutrients is one

21 that I hadn't thought of. But that is a good

22 example where we would want to not expand but
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1 change, you know. I don't like necessary the

2 word "expand" and that is a good example that

3 serves the illustration that maybe we should

4 look at the simple phrase. 

5 Mostly that's what we will be

6 doing. My feeling is that -- that is the

7 general intent is to restrict. But we should

8 keep it open so that if necessary, if there's

9 a very good reason as you pointed out, we may

10 want to have the ability to expand an

11 annotation. And won't necessarily mean --

12 yes. 

13 Thank you.

14 MR. GIACOMINI: I think the

15 difference here -- I'll get to you next, Jay,

16 if you need to supplement my comment here.

17 The difference here is that the

18 framework of this recommendation is the

19 annotation change within the Sunset process.

20 There's no restriction on annotation changes

21 outside of the Sunset process within this

22 document. Okay. So, it's just within when
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1 it's done with in the Sunset.

2 Now, we have all that debate of

3 whether that's the appropriate time and how --

4 but this document as I understand it would

5 only be limiting the annotation change within

6 that document. 

7 MS. UNGER: Can I please respond

8 to that, Dan?

9 MR. GIACOMINI: Okay. 

10 MS. UNGER: This is a Sunset

11 Review item. It is very relevant to this

12 discussion. 

13 MR. GIACOMINI: Thanks. 

14 Jay. 

15 MR. FELDMAN: Thanks, Beth.

16 I would like to hear your response

17 to this line of thinking. And this goes to

18 your point, Joe.

19 Are we not constrained by the

20 statutory language that uses the term "Sunset"

21 which means remove? The process of sunsetting

22 is to re-evaluate the existing uses that are
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1 on that list, you know, in a technical sense

2 to remove those uses and all we're doing with

3 this proposal is we are restricting the

4 removal of those uses. I would argue that

5 given the construct of the statute that our

6 hands are tied on that point -- on your point

7 of expansion and that issue of expansion is

8 really left to the petition process which

9 offers anybody an opportunity to come in and

10 expand the uses of a particular material or

11 substance. 

12 Having said that, I think the

13 issues that we need to be able to deal with

14 perhaps during Sunset which may be viewed by

15 some as an expansion, are clarification

16 issues. So that like we were talking

17 yesterday about a clarification of a previous

18 understanding at the time of allowance or at

19 the time of a decision. So, I think we are

20 constrained by the law which requires us to

21 sunset or remove and that what we're doing

22 through this proposal is seeking to restrict
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1 the removal of that product in certain ways at

2 the same time that we allow it to remain for

3 the allowable uses.

4 MR. GIACOMINI: Well, I think

5 there's some debate over what OFPA is

6 requesting us to do there, but we won't get

7 into it here. 

8 Kevin. 

9 MR. ENGELBERT: Yes. I'd just

10 like to briefly reiterate basically what Jay

11 has said that the committee was firm in its

12 belief that any expansion of an annotation or

13 any additional annotation should be done

14 strictly through the petition process so that

15 in keeping with what's been done in the past.

16 MR. GIACOMINI: Joe.

17 MR. SMILLIE: In spite of the

18 Chairman's grimace, Beth's point though is

19 that the sunsetting of the 104.20 which was

20 not our recommendation, which was not the NOSB

21 recommendation, was the NOP's interpretation

22 of our recommendation. So, in a real sense by
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1 changing that annotation we would be expanding

2 it from their current interpretation of it

3 MR. GIACOMINI: Okay. 

4 I have a relevant question for

5 Beth.

6 Have you had a chance to review

7 the methionine White Paper that was submitted

8 by and posted -- I'm positive it was posted

9 from the Methionine Task Force? And if you

10 have, when we reviewed it, we felt that it

11 filled in fairly well, very well. Even though

12 some may consider aspects of it bias from the

13 source, we felt that it considered and filled

14 in very well any holes that may have been in

15 the methionine tap. Have you ever had a

16 chance to review that document?

17 MS. UNGER: Not thoroughly.

18 MR. GIACOMINI: Okay.

19 MS. UNGER: Yes. I have seen it

20 but --

21 MR. GIACOMINI: Okay. I agree,

22 it's getting -- you know, they're all getting
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1 old but at the time that was what we were able

2 to use that as a -- and I was wondering if you

3 had the same perspective. Okay.

4 Anymore questions?

5 Okay. Thank you.

6 Dave Martinelli, Ed and Aaron

7 Brin. 

8 MR. MARTINELLI: Dave Martinelli,

9 Common Natural Foods. 

10 My topic is Animal Welfare and I

11 had promised myself I was going to come up

12 here and not say the M Word but unfortunately

13 I'm going to talk primarily about methionine.

14 You know, first in acknowledgment,

15 I do want to thank strictly the program for

16 working so quickly from the time of the last

17 meeting to actually coming out with in turn

18 final rule. I know the time frame was short.

19 The pressure was severe, producers were very

20 concerned but we're very appreciative of the

21 fact that it was in final rule and we could at

22 least have some clarity for the next 24 months
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1 or 23 months soon.

2 I guess the frustrating part, I

3 expect it's frustrating for the Board. It's

4 certainly frustrating for producers is that I

5 really sense the Board wanted to kind of come

6 to a final resolution of methionine at the

7 last meeting but unfortunately the whole step8 down leg of the process has kind of left the

9 Board back facing the issue again and

10 producers are very concerned about what

11 happens in 2012. 

12 So, I think in the spirit of

13 trying to put this into a little bit of

14 context and not cover a whole lot of ancient

15 history, I do thin kit's important coming out

16 of the last meeting that we all focus on the

17 fact that there are a couple of key areas

18 within the methionine discussion that I think

19 the industry and the NOSB have agreement.

20 For one, I think this whole notion

21 of organic standards prescribing a vegetarian

22 diet for an animal that is essentially an
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1 omnivore is unnatural and I think the actual

2 commentary at the last meeting was that it's

3 an abnormal diet. And at least I think

4 there's a recognition that we're not asking

5 for methionine for any purpose other than to

6 correct a diet that is fundamentally

7 unbalanced not in nature but unbalanced in

8 organic statute. 

9 The second thing is that different

10 species of birds have different methionine

11 needs and even with any given species or given

12 type of birds such as layers and broilers,

13 there are different needs of different stages

14 of live. For example, young birds, whether

15 they're young broilers as chicks of young

16 pullets have higher -- generally higher

17 methionine needs than birds that are older.

18 And that was really the reason behind the task

19 force's suggestion that it be computed as an

20 average methionine usage over the life of the

21 bird as opposed to an absolute fact. 

22 So, I think the acknowledgement
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1 that we have of fundamental need for

2 methionine as well as different needs for

3 different species, I think the only

4 outstanding issue and it's not insignificant,

5 but the outstanding issue is, the

6 justification of the step-down.

7 Okay. The NOP is struggling with

8 economic and scientific support for the

9 stepdown levels. I can tell you from the

10 producer's side, nutritionists have struggled

11 with formulating for not even the stepdown

12 levels. They're struggling to formulate the

13 levels we're currently operating out of

14 effective October 1.

15 To achieve the step-down levels as

16 proposed my feedback from the nutritionists

17 that we've talked to, our own and others

18 within the industry is that they will have to

19 formulate using an excessive level of crude

20 protein. I mean, that's really the only way

21 to get methionine to the animals and obviously

22 that has significant economic, environmental
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1 and health issues for the birds. I mean,

2 you're going to have issues with them in the

3 house.

4 So, what I'd like to pose and in

5 the interest of kind of moving this forward is

6 that, you know, the task force has been

7 active. It continues to fund research. It

8 will continue to stay active obviously. But

9 we will focus our efforts in the very near

10 future on working with our resources, working

11 with our nutritionists on really trying to

12 come up with what is the scientific number?

13 What is the minimally acceptable level of

14 methionine that we can live with? 

15 And I'm not here today to tell you

16 what that number is, but we want to go out and

17 canvass our resources, come up with what we

18 propose the number to be, submit that in

19 petition form to the NOSB. We understand

20 that, you know, given kind of the process it

21 needs to go through for the time line for this

22 is really compressed, even though we're
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1 talking about 2012 deadline. I understand how

2 the years turn relatively slowly. So, we will

3 be focused on trying to get this done as

4 quickly as possible, get something to you all

5 prior to the next meeting, prior to the spring

6 meeting. Hopefully in time to be discussed at

7 the spring meeting or if not there certainly

8 in the meeting in the fall so we can hopefully

9 come to resolution on this and move forward

10 and move past it. 

11 And that's really my methionine

12 task force hat, not so much my Common Natural

13 Foods hat. We've got a whole Common Natural

14 Foods presentation but I'm going to allow Mark

15 McKay who is here from Common as well to

16 really get into that and talk about the animal

17 welfare -- our perspective on the animal

18 welfare recommendations. 

19 MR. GIACOMINI: Kevin.

20 MR. ENGELBERT: That minimal

21 number is something we have been after since

22 I've dealing with this on the Board and the
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1 sooner the better. Thank you. 

2 MR. GIACOMINI: Questions,

3 comments? 

4 Tracy. 

5 MS. MIEDEMA: Will the methionine

6 task force be able to help with this other

7 data point that the Livestock Committee has

8 been tasked with trying to figure out the

9 economic impact of the stepdown?

10 MR. MARTINELLI: I think we can

11 certainly help with that. I would ask for if

12 it's possible if we can get a little guidance

13 maybe from the program in terms of what --

14 what we need to provide in that regards. But

15 I'm happy to pitch in in any way possible. 

16 MR. GIACOMINI: Well, I think it

17 would be hard for you guys to pitch in because

18 overall from the task force you didn't fully

19 support the stepdown. 

20 MR. MARTINELLI: In terms of

21 getting the information though --

22 MR. GIACOMINI: Yes.
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1 MR. MARTINELLI: -- in terms of

2 assessing what the economic implications are.

3 MR. GIACOMINI: Yes.

4 MR. MARTINELLI: We can do that. 

5 MR. GIACOMINI: We will try.

6 Any other questions? Okay.

7 Thanks, Dave.

8 All right. Edward, Aaron and

9 Bill.

10 MR. GILDEA: Good morning. My

11 name is Edward Gildea. I'm the President of

12 Converted Organics. Converted Organics is a

13 publicly held company with its share of common

14 stock traded on NASDAQ under the trading

15 symbol COIN. 

16 Converted Organics manufacturers

17 organic fertilizers by recycling food waste.

18 The recycled food waste using a proprietary

19 microbial digestion process that we call high

20 temperature liquid composting.

21 One of the food wastes that we

22 recycle is corn steep liquor. Thank you for
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1 the opportunity to express my support, though

2 I'm in a minority position of the Crop

3 Committee that corn steep liquor is not

4 synthetic and should be allowed for continued

5 use in organic crop production.

6 Converted Organics operates its

7 high temperature liquor composting process at

8 a manufacturing facility in Gonzales,

9 California. No prohibited substances are used

10 in the process. 

11 Corn steep liquor is an ingredient

12 that is used in our products. It is always

13 digested or run through the microbial

14 digestion process before it is offered as a

15 product. We never use it directly as a

16 product without having gone through the

17 digestion process. To my knowledge no one in

18 the industry uses corn steep liquor as a

19 fertilizer without first processing it in some

20 fashion either by digestion or composting.

21 Food wastes are allowed as a feed

22 stock in compost operations regardless of the
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1 sources of the food waste. Corn steep liquor

2 is a food waste resulting from the

3 manufacturing of corn products such as organic

4 corn starch.

5 As a food waste if it is digested

6 or otherwise treated by a composting process,

7 it ought to remain allowable feedstock

8 acceptable for use in organic crop production.

9 Corn steep liquor is a food waste

10 resulting from corn wet milling processes. It

11 contains an insignificant amount of the

12 processing aid sulfur dioxide. Corn starch

13 which results from the exact same wet milling

14 process is included on the National List under

15 17 CFR Section 205.606 as an agricultural

16 product allowed in products labeled as organic

17 as a result of a determination made in 1995 by

18 this Board. 

19 The determination was correct in

20 1995 and it's still correct today. Sulphur

21 dioxide is the same. Corn starch is the same.

22 The waste called corn steep liquor is the
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1 same. 

2 Admittedly, we add to the process

3 by recycling the corn steep liquor and

4 reducing the amount of the So2 that's in the

5 corn steep liquor that we received through the

6 digestion process. 

7 It's important for manufacturers

8 and growers to have consistent decisions from

9 organizations such as this. When a small

10 manufacturers cannot rely on consistency in

11 decision making by the NOSB or other

12 committees, the inability to rely on it is

13 detrimental to our success as an organic

14 fertilizer manufacturer.

15 Moreover, consistent decisions

16 arrived at through a consistent process do not

17 contemplate behavior such as publishing and

18 untimely revised committee decision discussion

19 paper. Apparently, in support of a majority

20 opinion. This kind of casual disregard for

21 process doesn't fit within the definition of

22 consistent decisions arrived at through a
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1 consistent process.

2 As confused as it may be, the

3 decision of the minority position ought to

4 stand. There are other examples of food

5 wastes that result from food processing that

6 contain minimal amounts of processing aids

7 that are permitted to be used as an ingredient

8 in the manufacturing of products permitted for

9 use in organic crop production. 

10 For example, food wastes from

11 conventional tomato processing facilities that

12 use potassium hydroxide as a processing aid to

13 remove the skins as residues in insignificant

14 amounts and the food wastes from these

15 facilities may be used as a feed stock in

16 compost for organic production.

17 Notwithstanding the fact that potassium

18 hydroxide is not permitted for use in organic

19 crop production.

20 Corn steep liquor should be

21 allowed for use even if the So2 synthetic --

22 because the So2 synthetic levels are
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1 insignificant and virtually non-detectable in

2 our final fertilizer products. 

3 As an important part of any NOSB

4 decision, it is not necessarily whether the

5 product is synthetic or not but it is whether

6 or not the product is harmful or toxic to the

7 soil. The NOSB should focus on the fact that

8 corn steep liquor is not harmful to the soil.

9 In fact, if you focus on the presence of So2,

10 you should note that sulphur can be beneficial

11 to the soils. 

12 If the corn wet million process is

13 determined to create a synthetic due to the

14 use of So2, then all products in this process

15 -- is that my five minutes?

16 MR. GIACOMINI: That is five.

17 MR. GILDEA: Sorry. MR.

18 GIACOMINI: No, that's fine. 

19 Okay. Any -- Tracy. 

20 MS. MIEDEMA: I want to make sure

21 I understand your concern. For your business

22 you have that digestate that comes from your
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1 anaerobic facility and that digestate was

2 produced in part with corn steep liquor. 

3 MR. GILDEA: Well, no --

4 MS. MIEDEMA: -- is that today?

5 No. 

6 MR. GILDEA: We have a product

7 that we manufacture through aerobic digestion,

8 not anaerobic digestion. And we use corn

9 steep liquor as an ingredient in that product. 

10 MS. MIEDEMA: And is your concern that if

11 this was -- corn steep liquor was deemed

12 synthetic that your product would then not be

13 allowed in organic production or are you

14 simply arguing the case for corn steep liquor

15 in organic crop production?

16 MR. GILDEA: Well, the real reason

17 -- the real reason I'm here arguing is our

18 business is built around recycling food waste.

19 And if this committee can decide that this

20 particular food waste can't be used in

21 creating organic fertilizers then I have to

22 ask, what's next? What other food waste that
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1 we currently use in creating our products is

2 going to be banned because of a process

3 unrelated to us? 

4 We currently process all manner of

5 different kinds of food wastes from all

6 different kinds of waste sources. We don't

7 always know where it came from. It comes in

8 garbage trucks that are dumped in a tip floor

9 and we clean it up and we put it through the

10 digestion process and we create fertilizer. 

11 Could you decide that, I don't

12 know. Pick a crop. Lettuce with pesticides

13 can't be used as part of our process anymore,

14 we have to take out the lettuce. 

15 MS. MIEDEMA: I have a follow-up

16 question then for the program.

17 My understanding is that the rules

18 for compost and what can go into compost is

19 very different than what can be applied

20 directly to the field. And that a compost

21 could have a bunch of say Twinkies thrown in

22 it. That's not an issue. But something like
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1 corn steep liquor is what we're debating as

2 being potentially prohibited in organic crop

3 production. Is that a correct way to

4 characterize this? 

5 MR. McEVOY: The debate is about

6 corn steep liquor and whether or not it's a

7 synthetic or non-synthetic. In terms of crop

8 residues, food processing waste that consists

9 of residues of vegetables or fruits from food

10 processing, that's allowed as an input in

11 organic systems. In compost or directly

12 applied to soil, it's green waste. Food

13 processing waste, a natural substance. It's

14 allowed as a soil amendment to organic fields.

15 MR. GIACOMINI: I am not sure I

16 understood that answer either, Miles, but

17 maybe we'll take that up later.

18 Jeff. 

19 MR. MOYER: Just one quick

20 question. Maybe you can't answer or won't

21 answer it. 

22 In terms of CSL in your compost,
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1 what percentage of your business is --

2 MR. GILDEA: Thirty percent of

3 what we produce in California is the product

4 based solely on corn steep liquor and another

5 20 percent has corn steep liquor product

6 blended with other organic products. 

7 MR. MOYER: Point of

8 clarification. Are you saying 30 percent of

9 your compost is corn steep liquor or is there

10 corn steep liquor in 30 percent of your

11 product?

12 MR. GILDEA: What I am saying is

13 30 percent of the products that we sell in

14 California use corn steep liquor as the base

15 of the product. 

16 MR. MOYER: I see. 

17 MS. MIEDEMA: Miles, I want to ask

18 you a more specific question. Hopefully,

19 we'll be able to get to the bottom of this.

20 If Corn steep liquor is deemed

21 synthetic can this gentleman use corn steep

22 liquor to create his product and use it in
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1 organic --

2 MR. McEVOY: If corn steep liquor

3 is considered a synthetic, then no, he could

4 not use it as an input in a compost. 

5 MS. MIEDEMA: Would he be able to

6 use a Twinkie in that compost? 

7 MR. McEVOY: Yes, a Twinkie so far

8 is considered a food product of food, I guess

9 that could be put into organic compost. That

10 could be applied to an organic field. 

11 MR. GIACOMINI: Jay. 

12 MR. FELDMAN: Another question for

13 the program. 

14 MR. GIACOMINI: It's your guys'

15 dinner. 

16 MR. FELDMAN: Yes. Could this

17 company consider its end product a soil

18 amendment and if the Board were to choose to

19 allow a synthetic soil amendment in the form

20 of corn steep liquor could he -- could this

21 product be applied in organic production? 

22 MR. GIACOMINI: Jay, mic. 
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1 MR. McEVOY: Okay. So, if the

2 Board decides that corn steep liquor is a

3 synthetic, then it's not on the National List

4 as an approved synthetic then it's a

5 prohibited substance and could not be used for

6 either direct application or as an ingredient

7 in a compost. 

8 MR. GIACOMINI: Follow up. 

9 MR. FELDMAN: Quick follow up. 

10 Now, if the Board were to take the

11 next step to put it on the National Organic

12 Program could it be used under 601, whatever

13 that is? 

14 MR. GIACOMINI: 601 is fine. What

15 we --

16 MR. FELDMAN: 601(j), Section (j)

17 as a plant or soil amendment. 

18 MR. GIACOMINI: Kevin. 

19 MR. McEVOY: So, if the Board

20 consider it a synthetic and adds it to the

21 list, it would have to then be -- go through

22 a proposed rule and the final rule process
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1 before it would be allowed. So, during that

2 interim it couldn't be allowed and then the

3 question is, does it meet the OFPA criteria in

4 terms of an allowed synthetic? So, there's a

5 couple of questions there that would need to

6 be answered in order for corn steep liquor, if

7 it's deemed a synthetic to go onto the

8 National List as an approved input. 

9 MR. FELDMAN: I would just like to

10 say for the record here that and Kevin pointed

11 this out to me so I don't want -- if you'd

12 like to explain this I -- that the Board has

13 previously under 601(j)(7) allowed liquid fish

14 products with the annotation, can be Ph

15 adjusted with sulfuric, citrus or phosphoric

16 acid, the amount of acid you shall not exceed

17 the minimum needed to lower the Ph to 3.5. 

18 So, there is precedent here on the

19 Board to allow as a soil amendment a material

20 that has been manipulated with sulfuric acid.

21 MR. GIACOMINI: Tina. 

22 MS. ELLOR: So, here would be my
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1 question. And I don't know the full history

2 of why we were asked to look at corn steep

3 liquor and not other food processing wastes.

4 But in the future if somebody lodged a

5 complaint about tomato processing wastes being

6 processed with a synthetic and, therefore,

7 it's a synthetic. Would we be taking a look

8 at that too? 

9 MR. McEVOY: The reason why this

10 came up is because OMRI and WSDA had been

11 allowing corn steep liquor as a non-synthetic

12 input for many years and they made a

13 determination through their process that it

14 was not non-synthetic but that it was

15 synthetic. 

16 The process of how they did that

17 was inconsistently being -- was being applied

18 inconsistently because they have different

19 procedures. So, WSDA was starting to tell

20 growers that they couldn't use products with

21 corn steep liquor in it and OMRI was still

22 allowing products. Some products were not
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1 being allowed to be used because of the way

2 that their systems are set up. So, from a

3 fairness perspective, we thought that this

4 should be a determination not by OMRI and WSDA

5 but it's really a Board decision to determine

6 whether something is a synthetic or a non7 synthetic. And so for many years this was

8 accepted in the organic certification arena as

9 a non-synthetic. A change was being

10 contemplated. We feel that that's an NOSB

11 decision, not the decision by an individual

12 certifier. 

13 So, we brought the issue to the

14 Board for the Board to consider as one

15 specific subject or top, corn steep liquor.

16 Long term, I think what needs to happen is

17 that the NOP in consultation with the NOSB

18 needs to create a generic list of approved

19 substances. OMRI already has a generic list

20 of approved substances. Most certifiers and

21 producers rely on that list, but that need sot

22 be endorsed or accepted by the National
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1 Organic Program in collaboration with the

2 National Organic Standards Board so that it's

3 a comprehensive list of everything that is

4 allowed to be used. It includes non5 synthetics and synthetics and then we would

6 not have to answer these individual questions

7 through this process but through some other

8 process. 

9 MR. GIACOMINI: Do you have a

10 follow up?

11 MS. ELLOR: Yes. What I am trying

12 to wrap my mind around is this is a -- I think

13 this is a food processing waste and so any

14 waste of food processing then would need to be

15 on some sort of generic list to be used? I'm

16 just not, I mean, you know, I don't want to

17 beat this because I know we're going to beat

18 it again tomorrow. 

19 MR. GIACOMINI: Okay. We'll

20 continue this right now but does anyone have

21 direct questions for our speaker? Okay. 

22 We will let you sit down then.
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1 MR. GILDEA: Thank you.

2 MR. GIACOMINI: And then Jeff.

3 MR. MOYER: Unlike Tina I do want

4 to beat this one just a little bit more

5 anyway.

6 I mean from my perspective I see

7 that we're asking two totally separate --

8 well, maybe interconnected but two totally

9 separate questions. 

10 One is, is the product synthetic

11 of non-synthetic? The other is, can it be

12 used in a composting process to clearly --

13 many of us as farmers make compost that use

14 products that could conceivably have synthetic

15 ingredients in it, whether it's from food

16 waste, from manure products, from grass

17 clippings to tree leaves. There's lots of

18 materials that come into my site that could

19 conceivably and most like do have some

20 synthetic materials vested in that that as far

21 as I know that doesn't mean we can't use it to

22 make compost. 
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1 So, I don't understand. I mean,

2 if the question is, are those materials

3 synthetic? Yes, clearly they are. But that

4 doesn't stop us and never has stopped us as an

5 organic community from using those materials

6 in compost, not as -- we could not take those

7 and put them directly into our production

8 system but through the compost process we can.

9 And so I think we're looking at two questions

10 here and I need some clarification. 

11 MR. McEVOY: Yes, I think you're

12 looking at one question and that's whether or

13 not corn steep liquor is a synthetic or non14 synthetic. And then we've clarified this in

15 the guidance on green waste where the

16 distinction is if you're creating a compost

17 that any of the ingredients that go into that,

18 any of the feed stocks have to be non19 synthetic. Have to be natural feed stocks.

20 So, lawn clippings, food processing waste is

21 considered non-synthetic.

22 Now, those lawn clippings may
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1 contain some pesticide residues which are

2 synthetic but that doesn't make the lawn

3 clippings synthetic in terms of the green

4 waste guidance that is in the program

5 handbook. This came up with the bifenthrin

6 issue in California last year where the

7 question was, after the composting process

8 there were still bifenthrin residues in the

9 compost, did that make that compost ineligible

10 to be used as an organic input? We've

11 determined that the bifenthrin residues are

12 residues. They're not ingredients so

13 therefore that can be allowed as long as it

14 doesn't lead to contamination of the soil or

15 their crops. And with the bifenthrin in

16 particular there was no evidence that it did

17 lead to contamination of the soil or the

18 crops. 

19 If you want to eliminate non20 organic crop residues or food processing waste

21 as an organic input or non-organic manure and

22 that's a whole different question than what I
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1 think is on the table here today which is

2 whether corn steep liquor is a natural or

3 synthetic. 

4 MR. GIACOMINI: That is -- okay. 

5 MR. MOYER: I just wanted to say

6 that was very helpful in clarifying that in my

7 mind and I appreciate that. Thank you, Miles.

8 MR. GIACOMINI: However though,

9 Miles, if we're really going to look where

10 this goes, I would question the answer that

11 you gave to Tracy on the Twinkie. The Twinkie

12 contains synthetic substances, OFPA 605 and

13 not OFPA 601 and going into a compost for 601,

14 usage in crops, may contain things that are

15 not allowed.

16 So, Kevin, did you have a comment?

17 Okay. Any more comments on this one?

18 Joe. 

19 MR. SMILLIE: Yes, I'm less

20 enthused about your answer because if you were

21 following -- I may have this wrong, but my

22 thinking is if you were following this line of
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1 thinking on your green waste issue, then you

2 wouldn't have brought up the CSL issue as an

3 issue because it is compost. It's not applied

4 directly. It's compost so it should have been

5 part of the green waste guidance document and

6 not a special synthetic issue is the way I

7 look at it. 

8 MR. McEVOY: No, the difference is

9 that in a compost you can't use urea. You

10 can't add urea as a synthetic input. If corn

11 steep liquor is considered synthetic you

12 couldn't use corn steep liquor as a feed stock

13 in compost. That's why it's a very different

14 situation. 

15 MR. GIACOMINI: Okay. Can we get

16 back to public comment? I think this is a

17 huge debate, whether we continue it tomorrow

18 or later on today. We were an hour behind

19 when we started this session and like I said,

20 it's your dinner. 

21 So, Aaron, Bill and Ed. 

22 MR. BRIN: Hi. I'm Aaron Brin.
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1 I'm a beekeeper in southwest Wisconsin. I'm

2 also the Inspection Manager at MOSA and I've

3 been a member of the ACA working group on

4 apiculture guidance.

5 I'm here to support the

6 recommendation of the Livestock Committee and

7 also I support adding formic acid to the

8 National List for varroa mite control in honey

9 bees. 

10 Listening to some of your

11 questions, Monday I guess, it was -- I wanted

12 to -- I saw that you were concerned about the

13 land area, the forage area. 1.8 miles. It's

14 a large area to be either organic or wild

15 crop. I understand that. It's a very large

16 area. However, I want to say in a lot of ways

17 it's a compromise with the 2001 NOSB task

18 force standards which ask for a four-mile

19 forage area. So, it's a lot smaller than

20 that. 

21 It is an area which is consistent

22 with organic standards in Europe and in
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1 Canada. I think it's a reasonable area.

2 There were questions about how do

3 you inspect an area that is that large? And

4 that's also a good question.

5 I think one of the great tools we

6 have right now is Google Earth. When you get

7 a satellite view of an area around an apiary,

8 you can see pretty easily what areas are wild

9 areas and what area is a cultivated area.

10 That's going to help an inspector and the

11 certifier a lot. 

12 There's also hand-held GPS. 

13 People can actually walk through the area. 

14 I know there were comments by

15 Vermont Organic Farmers and NOFA Vermont which

16 were basically amendments to these

17 recommendations and they kind of questioned

18 the reasonableness of this 1.8 forage area.

19 They wanted to have two acre or less areas

20 within the forage areas which could be

21 considered non-organic production.

22 I'm not in favor of that.
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1 Interestingly enough, I think most of the

2 organic beekeepers in the United States are

3 from Hawaii. We haven't heard anything from

4 Hawaii or organic farmers that they're

5 complaining about the 1.8 forage area. They

6 can handle that in Hawaii. This seems to be

7 only something in Vermont that's a problem.

8 It's not a problem in northern Wisconsin. It's

9 a problem in northern Minnesota or upper

10 peninsula Michigan.

11 I would also say it's a larger

12 question than that because it's really a

13 question of international trade. We're going

14 to be getting most of our organic honey is

15 going to be coming in from Mexico, from

16 Central America, from Argentina, Brazil, other

17 areas in South America. And I really think we

18 need strict standards to uphold the quality of

19 organic honey coming into this country.

20 Okay. There were other questions

21 from Vermont organic farmers about transition

22 time. They only wanted a 60-day transition
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1 time. What they didn't look at was it's going

2 to take a full year for most beekeepers to

3 develop and draw out organic wax. And that

4 would be important. The wax tends to take in

5 chemicals and to have organic production I'd

6 like to see organic wax being used for the

7 development of bees and for holding honey.

8 They're also not wanting this

9 replacement bees to be limited to 25 percent

10 of all bees. The reason the replacement limit

11 is there is so that beekeepers can't just buy

12 bees, harvest the honey crop and then start

13 all over again with fresh bees again. We need

14 to -- organic people need to be developing

15 genetic stocks. 

16 MR. GIACOMINI: Thank you.

17 Questions/comments? 

18 Kevin. 

19 MR. ENGELBERT: What are your

20 thoughts on using wax-coated plastic as a

21 foundation?

22 MR. BRIN: Yes, good question.
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1 And, you know, as a beekeeper of course a

2 completely -- just a wax foundation, I think

3 is better in some ways. It's an incredibly

4 labor-intensive way to make frames. And I

5 don't -- for myself I don't even have time to

6 do that anymore. 

7 I think it's a reasonable

8 alternative to use wax -- organic wax-coated

9 plastic frames and it is kind of a standard in

10 the industry. 

11 MR. GIACOMINI: Question. Joe.

12 MR. DICKSON: Thank you, Aaron. 

13 A commenter earlier today asked

14 that the standard be modified to not allow

15 split operations where organic and

16 conventional hives are in the same bee yard.

17 What are your thoughts on that?

18 MR. BRIN: Yes. We had discussed

19 that and I would agree with that. There is

20 drift between bee hives. Bees don't always go

21 back to their own hive. They get mixed up and

22 we never anticipated that an organic and a
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1 conventional apiary could exist side by side.

2 If it's a split operation, I believe it should

3 be a separate aviary. Or they have to have

4 some kind of other plan which makes sense to

5 the certifier. 

6 MR. DICKSON: Could an organic and

7 a non-organic apiary share a forage zone or a

8 surveillance zone or should they be completely

9 separate operations?

10 MR. BRIN: Again, I guess it would

11 be up to a certifier but I believe they could.

12 If there were two apiaries on two sides of the

13 forage zone, I don't see a problem with them

14 sharing the forage zone. It's a question of

15 them drifting from one hive that's like five

16 feet away from another hive. MR. DICKSON: 

17 Do you have a relative distance on how far

18 apart you think they need to be?

19 MR. BRIN: That's a good question.

20 A lot of beekeepers try to hold drift down to

21 a minimum. You can paint hives different

22 colors. You can orient them in different
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1 directions. So, they get used to

2 understanding knowing where their hive is.

3 We'd like them to go back to their hive, not

4 -- they cause trouble when they go back to

5 somebody else's hive. 

6 So, if there's a plan, you know,

7 that makes sense to a certifier --

8 MR. GIACOMINI: Okay. That's

9 fine. 

10 Any other questions? 

11 All right. Thank you.

12 MR. BRIN: Thanks. 

13 MR. GIACOMINI: Bill. 

14 MR. ARDREY: Yes, sir. 

15 MR. GIACOMINI: Okay. Bill, Ed

16 and Bruce Drinkman. 

17 MR. ARDREY: And I do have a

18 PowerPoint presentation I'd like to go

19 through.

20 Thank you for allowing me to be

21 here today. I'm going to introduce you to

22 some new technology that should improve animal
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1 welfare and help reduce or help improve animal

2 herd health. 

3 Next slide please.

4 SmartStock developed an electronic

5 herd health monitoring device based on an

6 active RFID bolus for ruminant animals. If

7 you could pass that around this way. 

8 It's a true animal ID that unlike

9 the Iratek cannot be removed. The bolus is

10 adjusted by the ruminants early and remains

11 with them for their life.

12 Once ingested, the bolus will

13 transmit their core body temperatures up to

14 300 feet to a network of receivers placed

15 around the pens, paddocks and barns. There is

16 no need to parade the animals past a panel

17 reader which in itself adds additional stress

18 and gives false temperature readings when the

19 bolus itself will last for five years. 

20 Go ahead with the next one.

21 The temperatures are collected and

22 retransmitted by the receivers up to five
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1 miles to a bay station and computer where the

2 information is available via the Internet. The

3 herd manager will immediately be altered to

4 the majority of the dairy cow's disorders and

5 her physiological state including estrus and

6 parturition.

7 Oklahoma State University under

8 the direction of Dr. Robert Wittiman has

9 detected estrus in 100 percent of the test

10 cows with one false positive. There was an

11 average of eight to twelve hours notice to

12 allow for AI breeding. This is an example of

13 the estrus detection in the animals under test

14 at Oklahoma State University.

15 Go to the next one please.

16 This is an example of the data we

17 collected on parturition or calving of the

18 animals. There's approximately eight hours of

19 notice for the managers in case they need to

20 assist that cow during calving. 

21 Next slide please.

22 Blind studies at multiple
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1 universities have shown that there is a 24- to

2 72-hour advance notice before clinical signs

3 of an illness that cause a temperature spike

4 including most common curable disorders and

5 including epidemic outbreaks. This is an

6 animal -- one of the first trials we did. This

7 animal was in Omaha, Nebraska. I was in

8 Pawnee, Oklahoma, a couple hundred miles away.

9 I pulled this up on the Internet and I noticed

10 that this animal was about 105 degrees but you

11 can see the spikes where the animal is

12 drinking a lot of water and trying to cool

13 herself down. Eventually she gave up and

14 stopped drinking water and her temperature

15 went up to about 107. I called the manager

16 and asked him to take a look. He said there

17 were no clinical signs that that animal was

18 sick. He pulled her. Administered

19 antibiotics and within two days she was

20 healthy and back in the pens. 

21 Okay. Next slide please.

22 This is some of the equipment that
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1 we use. The bolus is in the center. It's

2 ingested into the animals. The animals then

3 transmit that information to a receiver that's

4 going out. The receivers are solar powered,

5 easy to install, and then they retransmit the

6 information up to five miles. 

7 Major universities in the U.S. and

8 Canada have validated the system in finding no

9 less than 28 university -- no less than 28

10 advanced university degrees including master's

11 and PhD's were achieved on studies based on

12 this SmartStock system. 

13 This graph that's up here now is

14 an indication of the potential cost savings.

15 Seven thousand head herd if we can reduce the

16 death loss by 50 percent we can potentially

17 save that herd manager $7.5 million in a five18 year period. 

19 Next slide please.

20 Something that's worth discussing.

21 We placed the system on a herd of 1,200 dairy

22 cows. The unexpected death loss due to
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1 infection was around six percent. We hope to

2 reduce that to three percent. After 15 months

3 and even to our amazement, the dairy had lost

4 a total of two cows. That's not two cows a

5 month. That's a total of two cows. They were

6 heat-stress related and a manager was away

7 from the herd but the conditions were flagged

8 by the computer. 

9 Medication costs were reduced by

10 50 percent and the hospital pens were

11 virtually empty. Mr. Jeff Beyers, the dairy

12 manager, said that we have saved him $500,000

13 in one year. 

14 With this system we have detected

15 mastitis, neuritis, other infections, estrus

16 calving and this product has been tested for

17 the last five years and studies continue, but

18 there is an opportunity for savings to the

19 organic dairy industry.

20 Okay. Thank you very much. 

21 MR. GIACOMINI: Thank you.

22 Comments and questions. 
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1 Okay. I have one. 

2 On one of the slides there do you

3 have an ear-tag version or just the bolus?

4 MR. ARDREY: We match it to an ear

5 tag.

6 MR. GIACOMINI: You match it to an

7 ear tag. Okay. 

8 MR. ARDREY: The ear tag gives you

9 the visual indication. If the ear tag falls

10 off, we can still identify that animal with

11 the bolus. You cannot get that bolus out

12 without surgery. 

13 MR. GIACOMINI: There's no ID with

14 the ear tag though other than visual?

15 MR. ARDREY: No ID other than

16 visual if the ear tag --

17 MR. GIACOMINI: No transmission? 

18 Okay. 

19 MR. ARDREY: No, sir.

20 MR. GIACOMINI: Okay. 

21 MR. ARDREY: Just the bolus. 

22 MR. GIACOMINI: Thank you. Any
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1 other questions/comments? 

2 Thank you. 

3 MR. ARDREY: Thank you very much.

4 MR. GIACOMINI: Ed. Am I in the

5 right spot here? Yes. Ed Schaller. Is he

6 here? 

7 Bruce Drinkman. Bruce. Ed.

8 MR. DRINKMAN: I'm Bruce.

9 MR. GIACOMINI: You're Bruce.

10 Okay. 

11 George Bass with a proxy. Kelly

12 Shea. 

13 Lisa, what is the note on John?

14 Can you explain that? Next one down after

15 Kelly. Or did I not get -- is he in that

16 slot? Okay. All right. Okay. Just trying

17 to keep it straight. No Ed. Okay.

18 Go ahead, Bruce.

19 MR. DRINKMAN: I was going to say

20 good morning, but I'll say good afternoon to

21 you folks.

22 My name is Bruce Drinkman. My
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1 wife, Mary, and I operate a 50 cow organic

2 dairy in north central Wisconsin. We raise

3 our own crops for the entire operation. 

4 I have three main areas of concern

5 that I want to address. 

6 The stock charts, I have come up

7 with some answers in regard to that while I've

8 been down here today. I do feel that it's

9 very important though that you keep the

10 farmers in touch with any adjustments that

11 will be made. It's not going to be an

12 overnight fix for anybody that gets this

13 thrown at them.

14 Sometimes the rules are rather

15 confusing for us on the farm end. And, you

16 know, we try to keep in touch with the

17 certifiers but it's not always easy. The 50

18 square feet recommendation that I saw come up

19 I wasn't sure if that was going to apply to

20 tie stalls but I've been advised that that's

21 going to be exempted is my take on that. 

22 And I think you need a little more guidance as
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1 far as how that will be calculated in the

2 event it comes into play. 

3 My second area of concern is the

4 origin of livestock. I believe that once an

5 operation has been certified the animals

6 should be brought in -- has been certified. No

7 outside animal should be brought onto the

8 operation unless they are certified

9 organically from another operation. And they

10 should be raised in the last stage of

11 gestation.

12 I also believe that transitioning

13 is a distinct one-time event. The conversion

14 provision should not be used to bring non15 organic animals into the operation on a

16 continuous rotation. 

17 The third issue that comes to mind

18 for me and was brought to my attention is the

19 products listed for Sunset Review on the

20 205.603, synthetic substances. I hope that

21 those substances will be renewed as I use

22 several of them on the farm. And the one that
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1 kind of tripped my trigger was sodium

2 hypochlorite. That's the chlorine I use to

3 sanitize my milking equipment which I need to

4 keep in compliance with Uncle Sam. So, you

5 know, we have to be very aware of issues on

6 that end of it. 

7 And I know phosphoric acid was

8 another one that was thrown out and I've tried

9 other alternatives. I haven't come up with

10 any that works as well as these. I've looked

11 at other options in the past.

12 And the other thing as far as

13 chlorine in general goes, my wife is a

14 registered nurse for over 20 years. It's kind

15 of the standard in the health industry too to

16 use that. I mean, it's not like it's just

17 strictly for dairy farm use. 

18 The other products on that list I

19 also see a similar situation. Aspirin is as

20 old as we are and then some so that shouldn't

21 be an issue. I strongly encourage you also to

22 do what you can to keep in touch with farmers
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1 in general. I being a dairy farmer if you

2 have questions, feel free to contact us and

3 talk to us. Ask us what our thoughts are.

4 We're an honest lot. We'll try to tell you

5 where we're at with this stuff. 

6 Thank you for your time. 

7 MR. GIACOMINI: Questions,

8 comments? 

9 Okay. Thank you.

10 MR. DRINKMAN: I have one thing.

11 Kevin, I've never met you, but I do thank you

12 for your time and input over the years. 

13 MR. ENGELBERT: Thank you. 

14 MR. GIACOMINI: Okay. Is Ed here? 

15 Okay. 

16 One second please. Ed's not here.

17 Is Richard next up? Okay. 

18 Richard. 

19 MR. MATTHEWS: Richard Matthews,

20 President of NLP Solutions, Incorporated

21 speaking on behalf of the Country Hen. 

22 This week we have heard a lot
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1 about access to the outdoors for poultry

2 including the call for enforcement by NLP. 

3 For poultry, Miles and his team already have

4 reviews and investigations underway. I have

5 every confidence that he will vigorously

6 prosecute violations by producers and their

7 certifying agents. 

8 I also have every confidence that

9 he will note any regulatory provisions needing

10 enhancement to facilitate enforcement. Should

11 he identify such needs, he will surely bring

12 the issues to the Board for its

13 recommendations.

14 Some speakers have called for the

15 NOP to enforce pasturing of poultry. NOP

16 can't do that. Why? Because no such

17 regulation exists. In fact, Section

18 205.239(a)(1) merely requires that animals

19 have access to the outdoors. It doesn't

20 define access to the outdoors. It doesn't

21 mention pasture, grass or for that matter

22 dirt.
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1 This lack of detail is what led

2 the NOSB's May 2002 recommendation on access

3 to the outdoors and the NOP's acceptance of

4 that recommendation.

5 One of the things that I like and

6 admire about Katrina is her focus on reviewing

7 the history of past Board activities. And for

8 access to the outdoors, the record is rich in

9 history. 

10 George Sieman was chair of the

11 Livestock Committee that crafted the NOSB's

12 May 2002 access to the outdoors

13 recommendation. Compare the final

14 recommendation to the original recommendation.

15 Read the May 2002 transcripts and you work

16 your way back through the record including the

17 comments. You will read discussion on AI and

18 other health, safety and well-being risks as

19 well as risk to water and the related

20 challenges imposed by state environmental

21 agencies. 

22 You will see an evolution of the
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1 recommendation based in compromise. You will

2 discover the origin of the NOSB's approval of

3 outdoor access areas consisting of concrete or

4 wood provided they are covered with scratch

5 materials. It's this record and the NOSB

6 recommendation that led to the NOP policy on

7 the acceptability of porches. 

8 Porches are a compromise. Porches

9 address the risk to water quality issues faced

10 by some producers. Porches address the

11 health, safety and well-being issues raised by

12 producers. Porches take away the excuses for

13 not providing access to the outdoors. Porches

14 are an animal plant health inspection service

15 approved bio-security practice. Porches have

16 been an approved practice for eight years. 

17 Producers who don't provide access

18 to the outdoors are in noncompliance.

19 Certifying agents that don't require access to

20 the outdoors are in noncompliance. Certifying

21 agents that prohibit porches are in

22 noncompliance.
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1 The Country Hen uses porches to

2 comply with Massachusetts environmental

3 regulations. The Country Hen is and I

4 emphasize is in compliance with the NOP. 

5 Dan, you raised the question to

6 George and I'd like to follow up on that. 

7 You asked him what the floor of

8 the porch was made of. And he responded wood.

9 What didn't happen was the follow up question.

10 What's on that wood besides the hens and the

11 hen-processed food. The answer is shavings

12 for scratch material. 

13 MR. GIACOMINI: Questions/

14 comments for Richard? 

15 Kevin.

16 Richard, don't go away. 

17 MR. ENGELBERT: Thank you. Does

18 the Country Hen or any other labeled egg

19 producer tout the benefits of their porches on

20 their advertising material or their cartons or

21 their websites? 

22 MR. MATTHEWS: I can't speak for
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1 all of the producers who use porches. But

2 George is very open on it. In fact, one of

3 his surveys asks the questions, how do you

4 feel about the use of porches? 

5 MR. GIACOMINI: Further questions,

6 comments? 

7 I'll tread into this a little bit

8 with you, Richard.

9 Would it be and I understand your

10 disposition on a number of these issues, so

11 I'm going to try to be selective on what I

12 ask. 

13 Would it be appropriate for this

14 Board to look at the amount of access into the

15 porch and the size of the porch as an

16 appropriate consideration to animal welfare

17 under your understanding and interpretation of

18 what the regulations are? Would those be

19 appropriate?

20 MR. MATTHEWS: Most definitely.

21 MR. GIACOMINI: Okay. 

22 MR. MATTHEWS: I think that you
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1 would find that George Bass is more than

2 willing to do anything that you find necessary

3 with regard to the porches. If you wanted him

4 to expand the porches he would. If you said

5 that the opening wasn't big enough, he'd make

6 the opening big enough. And I think that it's

7 really vital that the openings be big enough

8 and that there be reasonable space. Not

9 everyone has enough space, even though those

10 that do use porches. 

11 MR. GIACOMINI: Right. 

12 MR. MATTHEWS: So, there's work to

13 be done in the area of porches as well, but my

14 emphasis is that it's a compromise position.

15 It's something -- we saw it in the dairy

16 pasture rule. Where in California there's

17 areas where the animals can't be on pasture

18 during certain times of the year because of

19 the environmental regulations. And that's the

20 same thing that some of these producers are

21 facing is environmental regulations. As

22 George mentioned, he's in a watershed for the
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1 water supply for the City of Boston. And

2 there's restrictions on him as to allow those

3 birds out onto the ground. 

4 So, instead of just keeping them

5 in the hen house, he went the extra mile to

6 find the compromise position and I think

7 that's what all producers should be doing

8 where they have concerns. Go the extra mile.

9 MR. GIACOMINI: I think though it

10 does need to be recognized that as you use the

11 example of dairy. You could use the analogy

12 that that porch is, except for the chicken

13 wire on the side, that porch could be viewed

14 as very similar to a pole barn. A pole barn

15 whether it's open housing, whether it's free

16 stall barns, whatever, on a dairy. I don't

17 know of anybody that would find that pole barn

18 as acceptable to access to the outdoors.

19 MR. MATTHEWS: I'll put it this

20 way. When there is a thunderstorm outside and

21 I want to get outside to enjoy the light show,

22 and enjoy the sounds of nature, I'm outside
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1 when I go out on my porch. The only

2 difference is I'm not getting wet. But I am

3 outside. 

4 MR. GIACOMINI: Kevin. 

5 MR. ENGELBERT: Richard, how do

6 you respond? I mean, you've been here since

7 Monday morning and we've heard poultry farmers

8 come up here and say that they provide what I

9 would consider to be true access to the

10 outdoors with pasture and scratching dirt and,

11 you know, no wire, no boards under their feet.

12 And they say it can be done. They're doing it

13 and there's -- anybody who doesn't do it is

14 simply making excuses. How do we respond to

15 those farmers that have come up here and given

16 testimony to that effect?

17 MR. MATTHEWS: The thing that you

18 have to consider is the regional differences.

19 This whole rule is based on consideration of

20 regional differences. I mean, the pasture

21 rule was a great example of what we went

22 through with regard to that. There are areas
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1 where the risk of bio-security through AI are

2 higher than other places. So, there's some

3 legitimate concerns by the producers.

4 There are areas where the hen

5 houses were located long before the NOP went

6 into place. And there's environmental issues

7 in those areas. And so the Board in past

8 history has taken all of that into

9 consideration and they have worked diligently

10 to find the compromises.

11 Now, I'll grant you, the testimony

12 from 2002 didn't mention porches, but it is a

13 natural extension once you've got the approval

14 to have wood surfaces and you've got the

15 approval for concrete surfaces. And there's

16 a whole history as to why they went to that as

17 an approved practice.

18 And so, yes, Kevin, in an ideal

19 world where everyone is the same and all areas

20 are the same, maybe you could have a

21 requirement that every bird be out on pasture.

22 But we don't have the ideal situation. We
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1 don't have the perfect world. We have

2 regional differences. We have environmental

3 differences, but we have one worldwide

4 standard. 

5 MR. GIACOMINI: But the new

6 pasture rule specifically states if an area

7 can't meet the 3120, it's likely just an area

8 that you can't be an organic dairy.

9 MR. MATTHEWS: That's true, but

10 there's all kinds of provisions in there that

11 enable somebody to meet it.

12 MR. GIACOMINI: Okay. 

13 MR. MATTHEWS: I mean, there's

14 intensive grazing, there's irrigation of the

15 fields, there's additional pasture land. I

16 mean, there's all kinds of examples within

17 those regulations where you can get up to the

18 30 percent.

19 And the 120, that's the minimum

20 and there's no place in the geographical

21 United States or very few places in the

22 geographical United States, contiguous states,
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1 where you would see where you couldn't get 120

2 days. I mean, it was selected because of the

3 average is like 120 days. That's why it was

4 the minimal number. 

5 MR. GIACOMINI: Okay. Anything

6 else for Richard? 

7 Kelly, you are just so ready, I

8 think we'll let you go ahead but we'll break

9 for lunch after this.

10 MS. SHEA: It's up to you, Mr.

11 Chair, whichever one you want. It's up to the

12 Board. 

13 MR. GIACOMINI: Let's go ahead. 

14 Hopefully, we won't drag out questions too

15 badly. I know you won't go over. But we are

16 an hour and a half behind.

17 MS. SHEA: Well, with that in

18 mind, I'll speak swiftly.

19 So, good morning to everyone. I

20 really want to thank everybody on the Board

21 for all the efforts the last couple days. You

22 are stuck to your chair. We can wander out in
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1 the hallways so when my butt gets sore and I

2 want to complain I think of you. 

3 And a lot of mud leading up to the

4 meeting, so I've heard a number of comments

5 from you guys about workload and challenges

6 with gathering information. And so I would

7 really urge the Board Members to reach out to

8 individual members of the community and to

9 organizations like the OTA, NODPA and its

10 sister organizations, OMRI, the National

11 Organic Coalition just to name a few. We'd be

12 more than pleased to be arms and legs for the

13 Board. 

14 We can mobilize our colleagues

15 together. Data for the Board. I do know of

16 two Board Members that reached out to OTA. The

17 Trade Association organized conference calls

18 so the Board Members could present their draft

19 recommendations and gather feedback. It was

20 an excellent process. And it serves the dual

21 purpose of both strengthening the

22 recommendation for the Board Member and
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1 informing the public.

2 You know, there were only 16

3 business days for people to absorb over 180

4 pages of very important information that could

5 lead to regulatory changes. The Board's own

6 policy manual says although not required by

7 FACA, the Board strives to post a provisional

8 agenda, et cetera, et cetera, and they talk

9 about no later than 90 days before the meeting

10 is scheduled to begin and then a final agenda

11 no later than 45 days and Federal Register no

12 later than 45 days. 

13 So, I don't want to be critical.

14 I'm just pointing out that because public

15 input is so crucial and because it's really

16 difficult to get all the documents out to the

17 public, you know, 45 or 90 days ahead of time,

18 that it's even more important that the Board

19 begin to engage their colleagues in the

20 organic community as the work is being done.

21 So, if this happens, I think the Board

22 deliberations will be much more informed.
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1 As to the Made With

2 recommendation. Since this was a request from

3 NOP staff that are no longer at the program,

4 and since the current NOP staff are already

5 working on this project, I would just suggest

6 that the committee volunteer to withdraw its

7 document.

8 Yesterday I was pretty concerned

9 to hear a Board Member say that we should get

10 rid of the 100 percent category. That would

11 not be good. Hundred percent ingredients are

12 really critical in ingredient percentage

13 calculations. What we need is clarification,

14 not elimination.

15 A great area of clarification

16 needed is in washing or cleaning of surfaces

17 where agricultural products are handled. I

18 mean is raw milk from a farm not 100 percent

19 organic because the farmer needed to wash his

20 milk equipment? 

21 The 238 recommendation that you

22 worked on. It's really a good start and I
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1 have no problems with you guys passing that

2 but I think it needs to go a little further.

3 See, the National List for

4 livestock is broken into categories ostensibly

5 by use. But use crosses categories. For

6 example, minerals and vitamins are used for

7 health care, not only as feed additives. So,

8 as the NOP very appropriately pressures

9 certifiers for consistency, certifiers are now

10 reading the regulations and the National List

11 with a more restrictive eye which is great.

12 So, this will lead to some decisions that

13 maybe have been made in the past using common

14 sense, being made using a black and white

15 lens. And that's not bad. But I think it can

16 have unintended consequences in areas where

17 the regulations were, you know, were imperfect

18 when they were written.

19 So, give a little though to that

20 and Dr. Pierman is going to be speaking as

21 well and maybe he can elaborate on that a

22 little bit more. 
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1 Silicon dioxide, so I just learned

2 at this meeting about the petition to de-list

3 silicon dioxide. And this is a really

4 important material for use in anti-foam. So,

5 silicon dioxide is actually an ingredient in

6 the certified anti-foams that are in use

7 today.

8 So, I just don't know if kind of

9 just a whiff of an alternative, you know,

10 should cause the Board not to relist the

11 material currently in use. So, I think the

12 community really hasn't had time to adequately

13 comment on alternatives or research

14 alternatives.

15 Cleansers and sanitizers,

16 chlorine, phosphoric acid, others. Farmers

17 and processors already have so few options for

18 sanitization and food safety. I really liked

19 Jay's comments on the issue. And so I would

20 suggest that, you know, some more work can be

21 done to make sure we have the right materials

22 on the list but I don't think we can do that
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1 work before the Board's vote tomorrow. So, we

2 would like to see those relisted.

3 And in closing, just really a

4 heart-felt thanks to Kevin and the Board and

5 as he always says his two sons. To Dan

6 Giacomini, Jennifer Hall, Jeff Moyer, Joe

7 Smillie. Thank you for five years of service

8 to the community. It's really appreciated. 

9 MR. GIACOMINI: Joe.

10 MR. SMILLIE: Well, yes, that was

11 enough. 

12 One issue that I want to get

13 clarification on. One I don't think a lot of

14 people understand. They could be wrong, is

15 the 100 percent.

16 There's two different things we're

17 talking about, Kelly, and I think you know but

18 just to be sure. There's 100 percent claim.

19 That's a claim that you can make that your

20 product is 100 percent. That claim also

21 includes the fact that you cannot use any non22 organic processing aids.
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1 For example, nitrogen-flushed

2 coffee cannot currently make the claim 100

3 percent coffee on a package that says it was

4 flushed with nitrogen. However when that

5 coffee goes into a coffee cake, you can use

6 the 100 percent as the calculation formula. It

7 is 100 percent. Whether they'd be allowed to

8 put 100 percent organic ingredients on the

9 package without making the 100 percent claim,

10 I don't know. I'll leave that to the wisdom

11 of the program.

12 But in our talking about trying to

13 allow nitrogen-flushing back to the old

14 inerts, you know, fiasco, that was the point

15 we were trying to make is to get across is

16 that we believe that, you know, processing

17 aids like nitrogen that shouldn't prevent the

18 100 percent claim. But, again, it doesn't

19 prevent counting it as a calculation on the

20 100 percent. 

21 MS. SHEA: I do understand that.

22 It's not well understood --
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1 MR. SMILLIE: Right. 

2 MS. SHEA: -- policy. 

3 MR. SMILLIE: Agreed. I certainly

4 agree. We meet it every day as a

5 certification agent. 

6 MR. GIACOMINI: Kevin.

7 MR. ENGELBERT: Very briefly. 

8 Thank you very much for the warm

9 wishes. But it's three sons, not two. And I

10 don't know if I would be here if it was only

11 two sons. 

12 MS. SHEA: Don't tell any of them

13 that I left them out. Okay? I'll get your

14 wife on that as well. 

15 MR. GIACOMINI: Further comments

16 or questions? 

17 Okay. Steve. 

18 MR. DeMURI: Just thought of one.

19 You had an opinion on the silicon

20 dioxide. What about the glycerides for

21 sunset?

22 MS. SHEA: I have no relationship
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1 with glycerides. 

2 MR. GIACOMINI: That's on the

3 record. 

4 MS. SHEA: Seems I brought some

5 mirth to the room today. 

6 MR. GIACOMINI: Okay. Thank you.

7 Any announcements before we break

8 for lunch? 

9 I have just before 45. One hour,

10 we'll start at 1:45 again. 

11 Please be prompt. 

12 Thank you. 

13 (Whereupon, the above-entitled

14 matter went off the record at 12:44 p.m. and

15 resumed at 1:45 p.m.)

16

17

18

19

20

21

22
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 1:52 p.m.

3 MR. GIACOMINI: The Board please

4 find their seats, we're getting ready to

5 start. Any conversations, please move them to

6 the hallway. Please. We're going to be going

7 with Jon, Susan and Steven Frenkel.

8 Any announcements or anything we

9 need to do, Lisa, before we proceed?

10 MS. BRINES: No.

11 MR. GIACOMINI: Okay. Programming

12 thing, are we on with sound? Okay, thumbs up

13 from sound. Okay.

14 Jon? Okay, go ahead.

15 MR. CADOUX: Thanks for your time,

16 guys. I will be very direct and quick.

17 I'm Jon, the founder and president

18 of Peak Organic Brewing Company. We're one of

19 very, very few brewing companies in the world

20 that strictly do organic beer. So organic is

21 not a line extension for us, it's not ten

22 percent of our volume, it's not twenty
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1 percent, it's 100 percent. Every single ounce

2 of beer we've ever brewed is certified

3 organic.

4 We support the Handling

5 Committee's recommendations to take hops off

6 the list in January 2013, and we think it's a

7 real win/win for organic beer, organic

8 brewers, like us, organic growers and also the

9 consumer. We also think, especially me, I

10 think it's a big win for 606, to be honest,

11 too. Over the next few years, just our

12 company, Peak, will support and purchase, you

13 know, untold thousands of pounds of organic

14 hops, quite literally millions of pounds of

15 organic grains, malted barley. And were it

16 not for 606, I frankly don't know if we'd be

17 around to purchase a single pound. And so I

18 think that's a lot, and we're really looking

19 forward to January of 2013.

20 MR. GIACOMINI: Questions and

21 comments?

22 Kevin?
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1 MR. ENGELBERT: So do you mean to

2 say that you think that hops had never been

3 put on 606 and always been required to be

4 organic, that there would be no such thing as

5 organic beer right now?

6 MR. FOSTER: It's hard to say for

7 sure, but if I had to bet, I would bet against

8 it. I don't think I'd be around. I don't

9 think we would have survived.

10 MR. GIACOMINI: Other questions,

11 comments?

12 Joe?

13 MR. SMILLIE: Just a comment,

14 because we were challenged by the program to

15 prove, in dollars and cents and actual facts

16 and terms and pounds and acres, that 606 spurs

17 organic growth. So as Miles now knows, it's

18 in the testimony, we have some figures to

19 start with, and I'm convinced there will be

20 more.

21 MR. GIACOMINI: Love that sample

22 size, but that's okay. I'm a scientist.
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1 Jon, I just have a question for

2 you. I'm ideal with, you know, harvest

3 seasons and crop years, with the crop years

4 the time you need to go between harvests. And

5 this seems right in the middle of your crop

6 year. Granted you have big times of brewing

7 and lax times of brewing, you know, you're

8 getting through all the holiday season. Is

9 this the right date?

10 MR. CADOUX: It's the right date

11 because this is based on the 2012 harvest,

12 which will be in roughly the September,

13 October time frame. However, hops go through

14 a multi-month processing phase that brings us

15 to January. So by January, we believe that

16 the 2012 hop harvest will be fully processed

17 and ready for purchasing.

18 MR. GIACOMINI: So even though you

19 have the September, October is the harvest, it

20 doesn't really come into the market -- it's

21 not in the pipeline until January?

22 MR. CADOUX: That's exactly right.
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1 MR. GIACOMINI: All right, that

2 makes sense, thank you. I'm fine now.

3 Any more questions? Comments? 

4 Okay, thank you.

5 Okay, Susan Cheney, Steven Frenkel

6 and Dragan. 

7 MS. CHENEY: Hello, Susan Cheney

8 with Martek Biosciences.

9 I would like to thank the Board

10 for the opportunity to voice our support for

11 the Handling Committee's efforts to fully

12 review the historical, scientific and legal

13 requirements regarding the supplementation of

14 Organic Certified Products. The 1995 proposed

15 annotation regarding vitamins and minerals

16 remains a valid and integral part of the

17 authorization for responsible supplementation

18 of organic products and should be revalidated

19 and incorporated into the National List as

20 originally recommended by the 1995 NOSB.

21 Organic food products should have

22 access to the same science-based nutritional
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1 ingredients that may appear in conventional

2 products, subject to standard National List

3 procedures. Consumers of organic products

4 should be allowed to choose appropriately

5 enriched organic products and not be forced to

6 purchase conventional foods due to the lack of

7 availability of enriched products in organic

8 form. The clearest path to this outcome would

9 be to revisit the existing annotations for

10 vitamins and minerals and correct it to

11 reflect the original NOSB recommendation.

12 Lastly, in response to the

13 unfounded allegations made against my company

14 this morning, I would like to say that Martek

15 and its customers stand by the strong safety

16 record of our ingredients and the health

17 benefits that they provide.

18 Thank you.

19 MR. GIACOMINI: Questions and

20 comments?

21 Joe?

22 MR. SMILLIE: Same question I
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1 asked last time. Do you absolutely need

2 hexane in order to extract DHA and AHA from

3 ALGO sources?

4 MS. CHENEY: From one of the ALGO

5 sources right now, the answer is yes. From

6 one of the ALGO sources we currently have, we

7 do not use it. The ARA is a fungal source,

8 just to correct that --

9 MR. SMILLIE: Oh, I'm sorry.

10 MS. CHENEY: -- and that also

11 requires hexane at this point in time.

12 MR. SMILLIE: Do you believe it's

13 possible in the future to have AHA and DHA

14 available --

15 MS. CHENEY: I do believe --

16 MR. SMILLIE: -- without hexane in

17 this fashion?

18 MS. CHENEY: I do believe the

19 science will catch up eventually. The science

20 isn't there now, or the technology isn't there

21 now. It's not something that's not being

22 looked at, I can assure you of that. The
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1 technology's just not there.

2 MR. GIACOMINI: Question --

3 further questions or comments?

4 MR. DeMURI: Although the

5 technology isn't there at this date, is this

6 something that you folks or suppliers are

7 working on currently?

8 MS. CHENEY: I can say we are

9 working on it, and I am bribing my team on a

10 regular basis.

11 (Laughter.)

12 MR. GIACOMINI: Okay. All right,

13 I think that's it. Thank you.

14 Where's my screen -- Steven

15 Frenkel, Dragan -- 

16 MS. BRINES: Jim Goodman. 

17 MR. GIACOMINI: Jim Goodman, I

18 don't have that one. Okay. What else is --

19 okay, he just slipped in and moved down. 

20 Okay. Jim Goodman.

21 MR. GOODMAN: Yes, thank you for

22 allowing me to slip in. My cows need me so I
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1 have to get home to milk, too. Thirty years

2 I've been trying to make them get along

3 without me but they haven't got to that yet.

4 I'm an organic dairy farmer. I

5 don't -- and we also do direct marketing here

6 at the Farmer's Market in Madison, we sell

7 beef and cheese. I'm not specifically a

8 poultry grower but I have some comments

9 related to that. We've been through a few

10 years struggling over a pasture rule, what

11 defines access to pasture, dry matter cause

12 need, and I think this relates pretty well to

13 some of the discussions you've been having on

14 poultry.

15 Selling at the Farmer's Market,

16 you deal directly with customers and they have

17 certain expectations and assumptions about

18 what organic means. And I think if we could

19 sell eggs, if we raised chickens, if we sold

20 eggs, we could get rich because people want to

21 buy organic eggs. They want to know how

22 they're raised. 
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1 And we've heard a lot of comments

2 about how these chickens in these large

3 thousand and multi-thousand bird houses are

4 happy. And I guess I've always wondered if

5 they're so happy, why don't we see pictures of

6 thousands of chickens in the barn on the egg

7 cartons instead of the chicken laying in the

8 grass? It seems to me that people want to buy

9 eggs from poultry that has access to pasture

10 where they can do their natural activity and

11 be the omnivores that they're designed to be. 

12 And that's what the industry sells eggs as. 

13 You never see a large multi14 thousand chicken poultry farm on an egg crate. 

15 You never see a confined dairy on a milk

16 carton. It's always a happy cow next to a

17 little red barn or a chicken laying in the

18 grass. As was mentioned, poultry are

19 omnivores. If they have access to the

20 outdoors, to pasture, to grass, to bugs, they

21 can supply their dietary needs. 

22 It seems that many of the
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1 solutions people have proposed to getting by

2 the rules and fitting them into their large3 scale productions are just that, a way to fit

4 rules into a production model that they know

5 is very profitable. And I don't necessarily

6 think that's the mission of the organic

7 program or the NOSB. If you want to make

8 profit in a conventional system, sell

9 conventional poultry, sell conventional eggs.

10 Another thing I wanted to briefly

11 address was nanotechnology, which I assume has

12 been discussed in the last couple days but I

13 haven't heard much mention today. I think

14 nanotechnology is one of those things that

15 needs to be included with the big forbidden

16 parts of organic; GMOs, sewage sludge. I just

17 really don't see any need, I don't see any

18 benefit to farmers, I don't see much benefit

19 to consumers. I looked up a few things on

20 nanotechnology, some of the products that

21 they're making. One is a nutritional drink

22 with nano particles of iron. Safety testing
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1 on nanotechnology is not really done, it's not

2 required. The theory with the small particles

3 of iron that are passed through cell

4 membranes, they're more bio-available, how do

5 we know that children drinking maybe more of

6 this chocolate drink than they should aren't

7 getting too much iron in a day? Iron can be

8 toxic. 

9 Adhesive for McDonald's hamburger

10 containers, I guess, well, that's really nice. 

11 But I don't think we need to worry that much

12 about McDonald's in organic at this point. 

13 Nano-silver particles as disinfectants in

14 cutting boards and tools, that's another thing

15 that fits into large-scale production, you

16 know, we've gotten by fine with soap and water

17 for many years to keep things clean.

18 One needs to look at the list of

19 companies that already have nano products and

20 production. Altria, which is Kraft, BASF,

21 Bayer, Cadbury, Cargill, DuPont. These are

22 not organic companies. This is a technology
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1 that's being developed for the conventional

2 industry and I really don't think it has any

3 place in organic. I would again urge you to

4 put that on the top of the list with GMOs and

5 sewage sludge as things strictly denied to

6 organic.

7 Joan Gussow who was a member of

8 this board quite a few years ago, and this is

9 just a short quote from her. She observed

10 that, while sustainable agriculture cannot be

11 defined, organic agriculture is being defined. 

12 And it's definition is being rendered

13 serviceable to an existing agri-food industry. 

14 And I think nanotechnology is a great example

15 of that; large-scale confinement, livestock

16 operations are a great example. People have,

17 for years, wanted to create a parallel

18 industry and create the organic Twinkie, which

19 maybe is already out there. I don't know.

20 But I don't think that we need to

21 be going that way. I don't think that's what

22 people who buy organic food expect, I don't
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1 think that's what they'd want. I don't think

2 we should allow huge corporate interests to

3 bend the rules to fit their standards of

4 production when these rules should be in place

5 to keep farmers in business and keep consumers

6 with a safe product.

7 Thank you.

8 MR. GIACOMINI: Questions and

9 comments?

10 (No response.)

11 MR. GIACOMINI: Okay, you're done. 

12 Thank you. If you can figure out that once-a13 day cow and weekends off, let us know.

14 Steven and Dragan -- I hope I'm

15 getting that right -- and Christopher Ely in

16 the hall. Go ahead.

17 MR. FRENKEL: Hello, I'm Steve

18 Frenkel. 

19 As the owner of Organic Vintages,

20 a licensed distributor of organic wines, and

21 wines made with organically-grown grapes in

22 the states of New York, New Jersey and
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1 Connecticut, I would like to offer my comments

2 regarding the recent petition for a change in

3 the NOP regulations to permit wines made with

4 100 percent organically-grown grapes with

5 sulfites added to be labeled as organic wine. 

6 I am emphatically opposed to such a change.

7 I have been supplying wines to

8 stores and restaurants in the New York

9 Metropolitan area and the Tri-State region for

10 22 years. And by the way, one of the first to

11 win at the organic wine distribution business

12 way back. Currently representing more than 35

13 wineries, some producing USDA organic wines

14 and others producing wines made from

15 organically-grown grapes. 

16 I feel exceptionally fortunate to

17 be able to provide the fine wines from these

18 producers in the marketplace, and am grateful

19 to all the purveyors we work with. I, our

20 sales team and our office staff have developed

21 good relationships with our customers and have

22 also been in direct contact with consumers on
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1 a regular basis. Invariably, we find that all

2 concerned, consumers and retailers, prefer

3 clear, honest, forthright labeling. 

4 In response to the issues raised

5 in the petition and based on my many years of

6 personal experience, I believe that the

7 majority of our retailers and their customers

8 desire that only a wine made with 100 percent

9 organically-grown grapes, with no added

10 sulfites, should be labeled as organic wine. 

11 I am also of the opinion that wine made with

12 100 percent organically-grown grapes, with

13 added sulfites, should continue to be labeled,

14 made with organically-grown grapes, contains

15 sulfites, or better yet, should be allowed to

16 state, if made this way, made with 100 percent

17 organically-grown grapes, contains sulfites,

18 but not carry the organic wine description. 

19 Wine made with 70 percent organically-grown

20 grapes should be labeled, "Made with 70

21 percent organically-grown grapes", or

22 "Contains 70 percent organically-grown
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1 grapes". 

2 Sulfites in the high

3 concentrations of around 100 parts per million

4 act as an allergen to many people, and

5 therefore would be a significant disservice to

6 provide the USDA logo and organic wine

7 statement that could mislead the consumer into

8 assuming they are purchasing a pure, non9 allergenic beverage. Many of our retailers

10 carry only wines that state organic wine and

11 have the USDA organic logo since they have

12 found that their customers, in most cases, are

13 more inclined to want a wine that is made with

14 organically-grown grapes and also without

15 sulfites. Other retailers carry both and find

16 that since they can be distinguished easily,

17 their customers are able to choose according

18 to individual preferences.

19 However, if a rule changed that

20 allowed wines made with organically-grown

21 grapes and added sulfites to be labeled

22 "organic wine" is implemented, retailers and
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1 their customers would be more easily confused,

2 even fooled into thinking an organic wine they

3 have purchased doesn't contain sulfites. I

4 also don't think it is in the best interest of

5 the consuming public to be potentially misled,

6 even if it is beneficial to the growth of the

7 organic wine industry.

8 My business has grown

9 exponentially over many years, and only has

10 leveled out recently due to the current

11 economic climate. I do think that our

12 industry will continue to have steady,

13 continued growth and interest in all things

14 organic will remain strong, especially if we

15 adhere to careful, truthful labeling and

16 maintain the integrity of the organic

17 standards as already established. To now clog

18 the labeling standards with potentially vague

19 or unclear messages could endanger the

20 longstanding trust of the organic consumer.

21 MR. GIACOMINI: Questions and

22 comments?
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1 (No response.)

2 MR. GIACOMINI: Thank you.

3 Dragan, Christopher Ely and Mark

4 McKay. Go ahead.

5 MR. MARCURA: My name is Dragan

6 Marcura, I am the founder and the chief

7 science officer of AgroThrive, Incorporated. 

8 And like Tina yesterday, I accept all

9 responsibilities for all things associated

10 with CSL because it was my application that

11 initiated the discussions and I'm still living

12 the consequences. 

13 So first of all, thank you for all

14 the hard work that you've done on that, and

15 I'd like to get into some of the -- my -- we

16 handed out two handouts. One of them is the

17 detailed summary of why we don't think it

18 should be synthetic and the other one is --

19 and you can read this at your leisure -- the

20 other one is excerpts from the only research

21 study that has been published on this

22 particular topic, the question of whether
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1 sulfur dioxide breaks disulfide bonds in

2 steeped corn. And so I will be referring to

3 some of these details in the second handout,

4 the one that has the graph in front of it. 

5 The second page of that handout has the

6 process.

7 This is the steeping process of

8 the counter current steeping kind, which is

9 the only process that is being used for steep

10 liquor that my company and Converter Organics

11 uses. There is -- this was -- this graph was

12 made up from the visit that I personally did

13 to Corn Products International in Stockton and

14 you have detailed description -- the page

15 following, detailed description, step by step. 

16 Let me just go through a couple of very

17 important aspects of this process, which seems

18 to be lost in this whole discussion.

19 As you can see there, we have 12

20 different circles that represent large

21 stainless-steel tanks, each one of them called

22 steeps. And you see, we have steeps going
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1 from number one through number twelve, and

2 it's a continuous process. The reason it's

3 called counter-current is that the corn goes

4 into the number one, for the process to start

5 it goes into the number one tank and the

6 sulfur dioxide, the sulfurous acid goes into

7 the last steep, number twelve, when it's added

8 in fresh form. 

9 What happens during the process,

10 the corn is -- each tank is filled with 37,500

11 pounds of corn, and it's also steeped in the

12 oldest steep liquor. The oldest steep liquor

13 meaning that it has the lowest amount of

14 sulfur dioxide and the highest amount of --

15 the highest amount of lactic acid. At the

16 same time as the -- where's the button, oh,

17 here's the button. Okay. At the same time as

18 the corn is being added to the -- to steep

19 number one, the oldest steep liquor is added

20 on top of it and at that point, we have a

21 very, very active lactic acid fermentation

22 going on. Lactobacilii -- it's dominated by
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1 lactobacilii and lactobacilii are known to

2 convert sugars starches to lactic acid and

3 also they are known to hydrolyze proteins. 

4 They're normally used in culture dairy

5 products such as yogurt, such as cheeses, that

6 ripen cheeses because of their percolative

7 ability. They also digest milk, for example,

8 in culture dairy products.

9 So the process, the steep liquor

10 is moved down the process and the oldest corn

11 receives the -- receives the new sulfur

12 dioxide and is then immediately taken to

13 grinding. So that by the time the steep

14 liquor reaches steeps one and two or three,

15 the sulphur dioxide is very low and it's the

16 lactic acid fermentation and the hydrolytic

17 power of the microbes that breaks the proteins

18 or releases of the starch.

19 That is in opposition -- if I can

20 just -- 

21 MR. GIACOMINI: How much longer do

22 you think you have?
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1 MR. MARCURA: Just a minute.

2 MR. GIACOMINI: Okay. Let's be

3 quick, this is my understanding this would

4 help.

5 MR. MARCURA: Okay, yes. Next

6 slide, please. 

7 Okay, this slide here shows what

8 happens in the methodology, which is what a

9 lot of the people have been discussing. This

10 is a lab -- bring it up, please, so you can

11 see the caption underneath. This is the

12 laboratory setup situation, the model system

13 where the -- where there is no lactic acid

14 fermentation and where sulfur dioxide is added

15 every five hours to keep the concentration of

16 sulfur dioxide in the process -- can you

17 please bring it down -- keep the concentration

18 in the process at its maximum level.

19 So this is where the big

20 difference is. In order for the sulfur

21 dioxide to get into the corn and actually do

22 any -- cause any chemical change, it has to be
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1 in a very, very high concentration at the

2 beginning, at the -- which is not the case in

3 the steeping process, counter-current steeping

4 process.

5 I'll leave it at that for some

6 questions if --

7 MR. GIACOMINI: Okay. Questions,

8 comments? Joe?

9 MR. SMILLIE: Yes, I need you to

10 walk us through a little bit more.

11 MR. MARCURA: Yes.

12 MR. SMILLIE: What is the active

13 form of the sulfurous acid that's capable of

14 breaking the disulfide bonds?

15 MR. MARCURA: Okay. The -- we

16 have a slide, I think it's number five,

17 please.

18 This slide here shows the

19 association chemistry of sulfurous acid. And

20 it's all -- whether there's a possibility of

21 the disulfide bond breakage or not depends on

22 this association chemistry. The only moiety
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1 that is capable of breaking disulfide bonds is

2 the SO3 minus 2 moiety. The -- all the other

3 versions of the SO2, which is sulfurous acid,

4 are incapable of breaking disulfide bonds. So

5 this is only available at the pH of about 7. 

6 At the pH of about 7, pK 2 of 6.99 means that

7 at that pH, those two versions are at

8 equilibrium. 

9 And as we go in this direction,

10 we're losing the concentration of the active

11 form of sulfur dioxide that is available at

12 the active site in the solution.

13 MR. SMILLIE: So it's the new

14 sulfur goes into the old corn?

15 MR. MARCURA: Yes.

16 MR. SMILLIE: And what's the pH

17 when the --

18 MR. MARCURA: The pH --

19 MR. SMILLIE: -- sulfurous acid is

20 at?

21 MR. MARCURA: Yes. The pH of the

22 corn, by the time the corn reaches the last
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1 steep or the last -- by the time it will enter

2 the last steep is about four. So the -- in

3 order for any activity, any disulfide bonds to

4 be broken, we have to have this moiety. And

5 at pH four, you can see that from seven to

6 four, there is a large difference in pH. And

7 when you look at the concentrations of these

8 two moieties, you will -- some of the chemists

9 in the room will probably agree that, at the

10 pH of four, which is where the corn is when

11 sulfur dioxide is added, the concentration of

12 this moiety is -- compared to this moiety, is

13 about one in 1,000 versus 999 in 1,000.

14 So at this level, at this level,

15 we have very little chance of the active form

16 of sulfur dioxide being present in the system. 

17 MR. SMILLIE: Yes, well, learning

18 my chemistry year by year.

19 In your opinion then, just to sum

20 it up, is it a chemical change? Is it

21 splitting a covalent bond?

22 MR. MARCURA: For this process, in
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1 addition to the concentration of the active

2 moiety being very low at the active site, we

3 also have the lowest concentration of sulfur

4 dioxide inside the liquid. So if we do the

5 proportionate analysis of how much of SO3

6 minus two is present at the active site, when

7 sulfur dioxide is added, we find that, even

8 though those sulfur dioxide is approximately

9 100 parts per million, we are one-tenth of

10 that -- of a percent possibility of SO2 minus

11 three being present at that point, which ends

12 up being one-tenth of a parts per million --

13 one-tenth of a parts per million versus 99.9

14 parts per million of the inactive form.

15 So you know, anybody that's a

16 betting person or an individual of proportions

17 or at least -- would realize that the, not

18 only is the chemistry inside the steeping

19 process against this -- the possibility of

20 this reaction taking place for this particular

21 process, but the particular concentration of

22 the active moiety is miniscule at best. 
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1 So in my opinion, no possibility

2 of the disulfide bonds being broken by sulfur

3 dioxide in this particular process.

4 MR. GIACOMINI: Joe?

5 MR. SMILLIE: Is this process a

6 standard corn wet milling process?

7 MR. MARCURA: This is what's been

8 practiced by, as far as I know, all of the

9 steep -- at least the corn refineries and the

10 producers of corn steep liquor that's being

11 used in fermentation in liquid fertilizers.

12 MR. SMILLIE: So if all this data

13 is correct, the lactic acid fermentation

14 process --

15 MR. DARCURA: No, no. Not

16 necessarily the lactic acid but the digestive

17 capability of lactic microbes, lactobacilii,

18 same as they ripen cheese, same as they

19 hydrolyze dairy protein, for example, the milk

20 proteins. They are most likely digesting the

21 protein that's encapsulating the starch in

22 this particular process.
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1 And further evidence to that is

2 that there are free amino acids in the

3 analysis of steep liquor, there is the

4 vitamins, B vitamins are produced in fair

5 amount, fair quantities, none of which are

6 components of corn but it's actually the

7 microbes that are producing.

8 MR. GIACOMINI: Anything further? 

9 Kevin?

10 MR. ENGELBERT: Why do you add the

11 sulfur dioxide to that?

12 MR. MARCURA: In my opinion,

13 sulfur dioxide is being added to keep down the

14 putrifactive organisms, to select for lactics. 

15 And at the end of the process, at the end of

16 the process, to kill the lactics so that the

17 digestion of the proteins doesn't continue. 

18 That's consistent with the use of sulfur

19 dioxide in wine, it's consistent with the use

20 of sulfur dioxide in a few other processes.

21 MR. GIACOMINI: Any other

22 comments, questions? Jay? 
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1 MR. FELDMAN: Thank you.

2 So it's -- you guys buy corn steep

3 liquor for your product, right?

4 MR. MARCURA: Yes.

5 MR. FELDMAN: You're not the

6 manufacturer?

7 MR. MARCURA: We don't

8 manufacture.

9 MR. FELDMAN: You don't

10 manufacture.

11 MR. MARCURA: Yes.

12 MR. FELDMAN: And you mentioned

13 that there were free amino acids in the end

14 product?

15 MR. MARCURA: Yes.

16 MR. FELDMAN: Okay. So there's

17 cysteine in the end product?

18 MR. MARCURA: Probably yes.

19 MR. FELDMAN: Okay.

20 MR. MARCURA: But there would the

21 twenty-whatever, four or five --

22 MR. FELDMAN: Where does the
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1 cysteine come from?

2 MR. MARCURA: Probably from the

3 corn protein.

4 MR. FELDMAN: Okay. How did it

5 get into the steep water?

6 MR. MARCURA: By digestion,

7 microbial digestion.

8 MR. FELDMAN: Okay.

9 MR. MARCURA: The sulfur dioxide

10 breaks only the disulfide bonds, according to

11 the -- to some research -- only the disulfide

12 bonds, but not the primary bonds of the

13 protein backbone. It only breaks disulfide

14 bonds. It has no activity against primary

15 bonds, carbon-to-carbon or carbon-to-nitrogen

16 bonds. So the fact that there are free amino

17 acids only proves that the lactic acid

18 bacteria or lactics are doing digestion as

19 I've outlined.

20 MR. FELDMAN: Okay. So to answer

21 Kevin's question, though, if -- I mean, you're

22 bringing interpretation to Bis and Cogen --
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1 MR. MARCURA: Yes.

2 MR. FELDMAN: -- which I'm not

3 sure there's agreement on, given --

4 MR. MARCURA: There is --

5 MR. FELDMAN: -- where their

6 conclusion is, I'll read you --

7 MR. MARCURA: There is full

8 agreement.

9 MR. FELDMAN: -- what they're

10 saying the major role of sulfur dioxide in

11 steeping is to cleave disulfide linkages,

12 thereby loosening the protein matrix that

13 encapsulates the starch granules.

14 MR. MARCURA: Can you also read

15 the second to the last -- could we have slide

16 number six, please, and I'll show you what

17 they say about this particular process.

18 The reason they're making -- the

19 last slide, number six, please.

20 Contrary to the above, contrary to

21 the process which you're talking about, and

22 they've decided -- they've done the study
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1 where they've shown that sulfur dioxide does

2 break disulfide bonds. But in order to do

3 that, there has to be a high concentration of

4 sulfur dioxide, which they do in their

5 laboratory setting, they replenish sulfur

6 dioxide every five hours to 2,200 parts per

7 million, every five hours, throughout their

8 steeping process. In addition, they have no

9 lactic fermentation in their artificial

10 steeping process.

11 So under those circumstances, yes,

12 disulfide bonds are broken by sulfur dioxide. 

13 But in order to do that, there has to be three

14 conditions that have to be met, and I've

15 outlined them in my submission. The first one

16 is that sulfur dioxide has to be in its active

17 form. SO3 minus two. The second one is that

18 the corn has to be at a high pH, they say 5.8. 

19 And third one is that there has to be a

20 driving force, the concentration gradient

21 between sulfur dioxide in the liquid and the

22 sulfur dioxide at the active site, which is
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1 the interior corn. Those three conditions are

2 present under lab conditions, which is what

3 most of their paper is about.

4 However, they are not present

5 under the commercially-produced steep liquor,

6 counter-current steeping process which is

7 practiced by 100 percent, as far as I know, of

8 North American steep liquor production, which

9 is being used in fertilizer production. Those

10 conditions are absolutely not met. The reason

11 they are not met is -- that's why it's called

12 counter-current. New corn is added to oldest

13 steep liquor, high concentration sulfur

14 dioxide, high concentration of lactic acid,

15 very active fermentation going on. Microbes

16 are dividing and growing very rapidly. 

17 If we could have slide two,

18 please? I'm sorry, slide one, and I'll show

19 you the graph. Slide one, please. Oh, slide

20 two then. I need the graph that shows --

21 right here. 

22 Right here, we have -- this is the
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1 zero time edition, zero time before the

2 process starts. The process starts with old

3 steep liquor -- with old steep liquor, right. 

4 At this point, the acidity is at its maximum. 

5 Sulfur dioxide concentration is at its very

6 minimum. There is a very, very vigorous

7 lactic fermentation going on at this point. 

8 The corn itself gets steeped and soaked within

9 15 hours. Can you please take a look at the -

10 -

11 MR. FELDMAN: I have it in front

12 of me.

13 MR. MARCURA: Yes, okay, good. 

14 Within 15 hours. 

15 So within this 15 hours, the corn

16 goes from about 6.8 to pH 4 because that's

17 where this process is buffered out. When the

18 corn is down at pH 4, it is not able to -- the

19 sulfur dioxide is not able to break disulfide

20 bonds because it is in its inactive HSO3 minus

21 four. Even if it gets in there, it can't do

22 it. The only reason that Bis and Cogen are
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1 achieving the breakage of bonds is because

2 they are replenishing sulfur dioxide every

3 five hours in order to keep that driving force

4 behind it, in order to be driving the sulfur

5 dioxide into the corn. And it only happens

6 while the corn is at a higher pH than 4.

7 And if you read their conclusion

8 on the last paragraph there, contrary to this

9 process that we have set up in the lab, if you

10 see every one of these, every one of these

11 says, okay, this is the convert -- this is the

12 counter-current process. But if we go to

13 figure -- to slide three, please. To slide 3,

14 please bring it up so you have the caption. 

15 This is the model solution system. This is

16 the laboratory setup system. They say, look

17 at that, solution contains 2,200 parts per

18 million, et cetera, but it is replenished with

19 sulfur dioxide every five hours. Please read

20 the caption and you will see. That's where

21 the misinterpretation on this whole discussion

22 has been all along. 
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1 And I, for the life of me, can't

2 understand why people -- unfortunately, this

3 is sort of the devil is in the details. As a

4 scientist, I go into the experimental design

5 when I don't understand what's happening and

6 when I want to evaluate what the actual

7 results mean. The experimental design here is

8 that they used 2,200 parts per million every

9 five hours for the duration of the process. 

10 And the counter-current process in industry

11 uses about 2,000 parts a million two hours

12 before the corn is ground. In other words, at

13 the very end of the process.

14 If they wanted sulfur dioxide to

15 break disulfide bonds, they would have added

16 that at the beginning, not at the end. They

17 leave it after the fermentation process to

18 break disulfide bonds and to free the starch. 

19 And they use sulfur dioxide at the end of the

20 process to kill the fermentation so that it

21 doesn't continue hydrolyzing proteins when

22 they need the proteins as whole. Because when
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1 they harvest proteins, they don't harvest

2 polypeptides. They harvest whole proteins.

3 MR. FELDMAN: Okay. So basically

4 your bottom line is that, the methodology the

5 researchers used is different than the

6 methodology used in industry?

7 MR. MARCURA: Totally different.

8 MR. FELDMAN: Totally different?

9 MR. MARCURA: Totally different. 

10 And unfortunately it uses the same agents, it

11 uses similar terminology, but unfortunately a

12 lot of people misunderstand those two and

13 think they are the same. They're absolutely

14 not the same.

15 MR. FELDMAN: How do you -- how

16 would you suggest that the Board, the NOSB --

17 because it seems to me that you're saying, if,

18 in fact, the breaking of the disulfide bonds

19 occurred and the -- you know, the reactions

20 occurred in terms of breaking of covalent

21 bonds associated with the manufacturing

22 process, that that indeed would yield a
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1 process that could be characterized as

2 chemical change. It seems like you're

3 implying that, I don't want to put words in

4 your mouth.

5 MR. MARCURA: No, I'm not.

6 MR. FELDMAN: You're not implying

7 that?

8 MR. MARCURA: No, I'm sorry, I'm

9 not implying that.

10 MR. FELDMAN: You're not implying

11 that Bis and Cogen created chemical change in

12 their laboratory study?

13 MR. MARCURA: No, that's

14 absolutely what they did. 

15 MR. FELDMAN: They did do that?

16 MR. MARCURA: Yes, they did.

17 MR. FELDMAN: So I guess what I'm

18 asking you is --

19 MR. MARCURA: That has nothing to

20 do with the process that's used for making --

21 MR. FELDMAN: I understand that.

22 MR. MARCURA: Yes.
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1 MR. FELDMAN: But if the process

2 were to be similar to that described by Bis

3 and Cogen, you would consider that a chemical

4 change?

5 MR. MARCURA: I still wouldn't

6 because disulfide bonds do not determine

7 primary structure of proteins. Disulfide

8 bonds determine tertiary and quaternary

9 structure of proteins, not the primary. A

10 common understanding among chemists, among

11 protein chemists is that primary structure is

12 chemical structure of the proteins. Secondary

13 as well. Tertiary and quaternary are only the

14 functional properties of proteins that

15 determine orientation in space or biological

16 activity. So enzymes, for example, will have

17 quaternary structure where not only are the

18 chains of proteins bound by disulfide bonds

19 but larger proteins are bound in a particular

20 configuration that gives it biological

21 activity. So disulfide bonds do not qualify

22 as the chemical structure bonds of proteins. 
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1 MR. FELDMAN: Okay. So this is

2 where -- I hate to drag this on, but I just

3 want to say that this is where we're having a

4 problem in terms of applying Appendix C of the

5 basic chemistry in the NOSB Policy and

6 Procedures Manual because there we're talking

7 about a process of denaturation which causes

8 physical change. The most observable result

9 is a loss of biologic activity --

10 MR. MARCURA: Exactly.

11 MR. FELDMAN: -- except for

12 cleavage of disulfide bonds, denaturization

13 stems from changes in secondary, tertiary and

14 quaternary structures through disruption of

15 non-covalent interactions.

16 MR. MARCURA: But not --

17 MR. FELDMAN: But what we're

18 seeing in the Bis and Cogen piece is a two19 step process. And that's why -- I mean, you

20 don't seem to be acknowledging that they've --

21 they've created a process which, I believe,

22 according to our definition, a two-step
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1 process which includes the first part being

2 denaturization -- would it be denaturization

3 and naturation and the displacement reaction.

4 MR. GIACOMINI: Excuse me, Jay, I

5 understand --

6 MR. FELDMAN: All I'm saying is --

7 MR. GIACOMINI: I know, but just

8 your time here has gone through as much as he

9 would have been speaking. So we need to move

10 on.

11 MR. FELDMAN: I just want to --

12 what I'm worried about is that there's a

13 process here that scientists have identified. 

14 It seems to conform to the basic chemistry in

15 our guidelines. You are dismissing that. 

16 You're saying two things to us. One, we're

17 not using the process that Bis and Cogen adopt

18 in the laboratory. I understand that. But

19 then you're also dismissing their findings as

20 well as not replicating -- as not establishing

21 chemical change. And that's where I have a

22 problem because I want to get to the point
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1 where we can identify the process you're

2 using, if in fact it doesn't cause that

3 reaction.

4 MR. GIACOMINI: Okay. We've got

5 to move on, please.

6 MR. FELDMAN: So I think we have a

7 problem --

8 MR. GIACOMINI: Jay, Mike, please. 

9 And Katrina?

10 MS. HEINZE: I appreciate your

11 insight today.

12 What I was going to say is, I know

13 we have a lot of public commenters today and

14 I want to make sure they have their time. I

15 was wondering if you would be here tomorrow,

16 I expect we'll have more questions.

17 MR. MARCURA: Yes.

18 MS. HEINZE: Okay.

19 MR. GIACOMINI: Tracy?

20 MS. MIEDEMA: Super quick

21 question. Is it possible to buy Bis and Cogen

22 style corn steep liquor?
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1 MR. MARCURA: No.

2 MS. MIEDEMA: Okay.

3 MR. MARCURA: Nobody makes it. 

4 That's only a laboratory creation.

5 MR. GIACOMINI: Okay. Further

6 questions?

7 (No response.)

8 MR. GIACOMINI: Okay. Thank you

9 very much.

10 MR. MARCURA: Thank you.

11 MR. GIACOMINI: Okay, Christopher

12 Ely, Mark McKay and Doug Swantner.

13 MR. ELY: I'm Chris Ely, co14 founder of Applegate Farms. 

15 Applegate welcomes the idea of a

16 single national organic animal welfare

17 standard and we applaud the NOSB for defining

18 these standards with input from stakeholders. 

19 Applegate has been working with livestock

20 farmers who have closely modeled what is now

21 the organic production industry since 1986. 

22 As such, these producers have shown us a full
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1 range of animal welfare practices and we have

2 learned what is critical for animal welfare.

3 We have discovered that there are

4 often two categories of standards. Those

5 which are science-based and those which are

6 based on perception. We believe the NOP

7 standards must be based on a scientific

8 criteria that enhances the lives of organic

9 livestock while maintaining the consumers'

10 positive perception of our industry. 

11 With 24 years of experience

12 working with farms that raise animals without

13 the use of antibiotics, growth promotants or

14 other drugs that enhance or insist with CAFO15 style livestock practices, we have learned

16 that the two critical criteria in this model

17 are stocking densities and management. 

18 We would suggest the following

19 recommendations to the proposed stocking

20 densities. The statement at the beginning of

21 the stocking density charts reads, young must

22 be kept indoors when there is a danger of
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1 frostbite. We would recommend changing the

2 statement to young may be kept indoors during

3 extreme weather conditions and/or the threat

4 from predators. Due to mortality, we believe

5 that stocking densities need to be defined as

6 forecasted numbers and weight at the time of

7 slaughter, not at the time of placement in the

8 barns.

9 The stocking density for bovines

10 seem to be similar to those found in CAFOs. 

11 According to the standard of 40 feet -- 40

12 square feet for a 770 to 1,100 pound cow or

13 steer, an acre of ground could contain over

14 1,000 cattle. I put it that way because I

15 have my own farm and it's easy for me to look

16 at what an acre of land can hold. This is an

17 unhealthy and unsustainable practice, even for

18 a sacrificial paddock.

19 Applegate would suggest that input

20 from organic beef producers be gathered as a

21 way of defining a realistic standard. The

22 proposed stocking density of seven pounds per
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1 square foot for turkey is more than half the

2 recommended stocking density of the

3 conventional turkey industry as seen through

4 the National Turkey Federation Animal Handling

5 Guidelines, which is 15 pounds per square feet

6 -- 15 pounds, yes, I said it right.

7 Although we are not proposing that

8 15 pounds per square feet is appropriate, our

9 experience with both organic and antibiotic10 free turkey grow out is that 12 square feet is

11 more than sufficient to maintain a healthy

12 environment and allow birds to roam freely,

13 open their wings, have ample feed, water and

14 scratching space and to practice natural

15 behaviors. This standard also allows for

16 lower than 25 ppms of ammonia levels

17 recommended by the NOSB.

18 Applegate believes that 25 ppms of

19 ammonia standards allows for a substandard

20 growing practice in poultry barn and therefore

21 we recommend a standard of 20. When density

22 is reduced, also is ammonia reduced. Twenty-
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1 five ppm is a commercial industry standard but

2 20 ppm is achievable for the organic industry. 

3 Although at certain times of the year under

4 certain weather conditions, ammonia can spike

5 over the standard of 20 ppm. Most times this

6 is a temporary situation and can be quickly

7 resolved by a well-managed poultry farm.

8 There seems to be a perception

9 among the general public, and even within the

10 industry, that organic handling of slaughter

11 standards address animal welfare at a higher

12 level than commercial operations that follow

13 the AMI guidelines written by Dr. Temple

14 Grandin. This is not true. Applegate

15 believes, and has experienced the standards

16 written by Dr. Grandin and adopted by much of

17 the conventional industry during the last

18 decade are science-based and ensure the

19 highest level of welfare currently available

20 to livestock slaughter operations. The

21 criteria focus on the measurable outcomes that

22 are clearly defined and quantifiably measured. 
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1 These present AMI animal welfare handling of

2 slaughter standards are reviewed annually and

3 updated accordingly as seen through the recent

4 release of the transportation standards.

5 Applegate recommends that the NOP

6 adopt the AMI recommended animal handling

7 guidelines and audit guide for slaughter. If

8 NOP adopts the AMI standards, it would save

9 having to train organic auditors on slaughter

10 standards as many plants have already been

11 audited by CAFO-trained third-party auditors

12 on the same standard. The adoption of these

13 slaughter standards could save plants which

14 currently slaughter organic livestock an

15 additional third-party audit specific to

16 organic.

17 MR. GIACOMINI: One more thought. 

18 Oh, you're done. Okay.

19 MR. ELY: Done.

20 MR. GIACOMINI: Questions,

21 comments?

22 (No response.)
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1 MR. GIACOMINI: So you're done. 

2 Thank you very much.

3 Mark? Okay, Mark, Doug and

4 Gwendolyn.

5 MR. McKAY: Mark McKay. I'm with

6 Coleman Natural Foods. I appreciate the

7 opportunity to address the Board and the NOP.

8 My comments today are going to be

9 specific to, actually the same as the previous

10 speaker, addressing the stocking density,

11 outdoor access and animal welfare guidelines. 

12 Coleman Natural Foods has been in

13 the national organic broiler production

14 business for over 25 years. We have

15 operations in both California and

16 Pennsylvania, and hopefully within a couple

17 weeks we will be in organic production in the

18 state of Washington as well. Within the last

19 two or three years, we were actually the pilot

20 company for the Global Animal Partnership and

21 their U.S. rollout and pilot program for the

22 STEP program for animal welfare. When we
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1 started that in Pennsylvania three years ago,

2 we have 70 family farmer operators who all

3 have achieved either the step 2 level grade or

4 higher within both our organic and our

5 antibiotic-free raising operations.

6 As a broiler producer, we're very

7 supportive of the discussion documents. 

8 However, we would encourage, actually, that

9 the Livestock Committee in particular take

10 into consideration some additional standards

11 that we think should be added to the

12 discussion. We do believe -- and I heard one

13 of the speakers earlier mention this as well,

14 that precise standards create a very level

15 playing field among the producers, and I

16 think, in turn, that will generate higher

17 level of confidence among the consumers which

18 I think, in turn, will benefit the entire

19 organic industry.

20 We at times resist the urge to

21 turn our packages, our consumer packages, into

22 a NASCAR car with the proliferation of label
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1 claims and attributes about the products. But

2 one thing that does come up, and I think

3 probably because people see it within the

4 places where they buy these products is that

5 animal welfare and animal welfare

6 certification is an amendment that typically

7 gets added before all others and is added in

8 addition to the organic certification for

9 certified organic poultry products. And in my

10 opinion, I think that organic and the organic

11 certification for these products should say it

12 all, that you don't have to add an incremental

13 statement about certification for animal

14 welfare, that it should be included with what

15 comes along with all the rest of the things

16 that we do from an organic standpoint.

17 I would also comment that, in

18 general, I'm not as familiar with the AMI

19 guidelines, but the National Chicken Council

20 has a broad range of what they consider to be

21 animal welfare guidelines for conventional

22 producers. I would actually say that they're
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1 fine and the -- in general, the conventional

2 industry adheres to them fairly rigorously. 

3 I actually see those as a foundation, as a

4 starting point, and that there are additional

5 things that our industry should do incremental

6 to that to encourage natural behavior and

7 promote the additional welfare of the animals

8 in our care.

9 I'll skip through to this. I'll

10 speak specifically to stocking density and

11 outdoor access. We actually have some farms

12 where we've been frustrated in the past, and

13 I'll speak first about access. That the birds

14 don't -- at least have not gone outdoors, have

15 not gone and enjoyed the access to the

16 outdoors as much as we would like. And so

17 we've actually taken a lot of effort recently

18 to modify the things that we do from a

19 husbandry practices standpoint in order to

20 encourage that behavior. So we've started to

21 work on the things structurally that we have

22 to do in order to promote and encourage birds
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1 to go outside.

2 And a lot of the things that are

3 actually in the discussion document from the

4 Livestock Committee are very similar to some

5 of the things that we've found. That it's not

6 just enough to have a door. You have to have

7 a wide opening that gives a large amount of

8 access across the entire length of the barn. 

9 It helps to have that at ground level rather

10 than high -- rather than have a ramp up and a

11 ramp back down. When the birds first start to

12 go outside, it is very helpful to have some

13 kind of protective covering, either a shade

14 cloth or a little overhang or something else

15 like that. In fact, we found that the most

16 amount of birds that were able to go outside

17 to go out on their own, is where we give them

18 a significant amount of protection over the

19 top of their barns or over the top of their

20 forage areas.

21 I will also comment on this. On

22 both transport, handling and stunning
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1 procedures, there are a significant amount of

2 incremental items that can be measured that

3 the industry is currently doing that are far

4 in addition to the industry standards relative

5 to catching, handling, transportation and

6 holding of the animals. And even that part,

7 just prior to the primary process within the

8 slaughter plants as well, that can be very

9 clearly defined, that the industry can very

10 confidently and comfortably live up to at

11 standards that are greater than the quote,

12 unquote, industry standards.

13 We look forward to the continued

14 efforts and we're here to help in order to

15 continue to build the confidence in the

16 consumers in our organic products. Thank you.

17 MR. GIACOMINI: Questions,

18 comments?

19 (No response.)

20 MR. GIACOMINI: Thank you.

21 MR. McKAY: Sure.

22 MR. GIACOMINI: Okay, Doug? Okay,
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1 Doug, Gwendolyn, Peggy Miars, just letting the

2 Board and everyone know we are moving quickly

3 past over two hours behind schedule. So we'll

4 see how things go.

5 Go ahead.

6 MR. SWANTNER: Good afternoon. My

7 name is Doug Swantner and I'm a retired

8 government worker. I spent 30 years working

9 with the Department of Interior and Department

10 of Agriculture and Fire and Aviation,

11 specifically with Forest Service and Bureau of

12 Land Management. I'm speaking as a concerned

13 consumer concerning the sulfides in organic

14 wine issue.

15 Let me start by saying that I have

16 a sensitive constitution and have learned what

17 I can comfortably eat and drink and what

18 things adversely affect me. I'm allergic to

19 bee stings and scallops and seem to have a

20 sulfide intolerance also. I carry an Ana-kit

21 with me at all times in case of allergic

22 reaction and have experienced going into
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1 anaphylactic shock twice.

2 I never was much of a wine drinker

3 in my earlier days, a glass or two always made

4 me feel bad and I would get headaches and

5 intestinal discomfort for at least a day

6 afterward. I pretty much quit drinking wine

7 after that, just feeling that something in it

8 inherently didn't agree with me. Like I

9 mentioned, I've always been conscious of my

10 food and beverage intake and, as the organic

11 movement gained momentum, I got into it more

12 and more as it made sense to me not to be

13 consuming harmful chemicals and pesticides

14 when there was a more healthy alternative

15 available. Plus I felt a whole lot better

16 eating organically. And with things like

17 wine, which I thought I could never drink, I

18 found that organically that could be a whole

19 different thing for me.

20 I knew Phil LaRocca from earlier

21 days in Quincey, California, where I still

22 live, before he started his wine-making
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1 business in the Sierra foothills a few hours

2 from where I live. He had been a early

3 pioneer of the organic movement and was also

4 teaching natural food classes at Chico State

5 University. I knew he was growing grapes

6 organically and taking it to a step further by

7 not adding any sulfides in the process of

8 cleaning containers or as a preservative. And

9 when he started making his wines, I mentioned

10 that I was not really into wine as I seemed to

11 get sick and -- whenever I drank it. He

12 commented that I probably had an allergy to

13 sulfides and that many people had this and

14 weren't even aware of it, and that I should

15 try his wines and see how they treated me.

16 To my amazement, I found that I

17 could drink his wines and feel good while

18 drinking and then not have the headaches and

19 intestinal discomfort I had experienced in the

20 past. It was then I decided that I definitely

21 had an allergy to sulfides. When I drink a

22 wine that contains added sulfides, I'm like a
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1 barometer. I immediately get stuffed up and

2 congested. The more sulfides, the more

3 immediate and intense the reaction. And this

4 was my first indicator that my body has

5 ingested something that it is rejecting. I

6 have tried to stay away from anything with

7 added sulfides and the fact that wine grapes

8 have some naturally occurring sulfide content

9 seems to be okay with my body.

10 With a heavily-sulfide wine, I can

11 actually smell and even taste the sulfides. 

12 So now I have been drinking the LaRocca wine

13 for about 20 years, along with a few other

14 truly organic wines that I have learned to

15 trust. When I buy wines, I stay away from the

16 bottles that say, made with organically-grown

17 grapes, because I know that they have added

18 sulfides. And looking at the back of the

19 bottle, on the label, you can confirm this. 

20 When I see a bottle that is labeled organic

21 wine, then I am comfortable know that the

22 whole process, from the growing to the
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1 bottling, has been accomplished without any

2 added chemicals compromising the organic

3 quality. I don't have to look on the back

4 label to see if it contains the clause,

5 contains sulfides. When I see the organic

6 wine label, that is what I have grown

7 accustomed to expect, is just that, a

8 completely organic wine.

9 I don't want to be misled into

10 drinking something that is labeled organic but

11 is allowed to have a certain percentage of

12 added sulfides. It's misleading and could be

13 dangerous for me and potentially many other

14 consumers who might not even know they are

15 sulfide sensitive. I understand now that a

16 proposed amendment is before the USDA and NOSB

17 that wants to allow 100 percent -- or 100

18 parts per million into wine of sulfides and

19 still have it retain the organic wine label. 

20 I don't understand what the rationale is

21 behind this. When I buy organically-produced

22 products, why should I have to second-guess
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1 that? I don't want to buy an organically2 labeled wine, or yogurt for that matter, and

3 essentially not really know what I'm getting. 

4 What's the point if, by some law, that these

5 products can actually contain a certain amount

6 of additives or chemicals? It makes a mockery

7 out of the organic philosophy and the people

8 who are trying to eat and drink as naturally

9 as possible.

10 I say let organic be just that,

11 totally organic, otherwise you will never know

12 truly what you are buying as a consumer. And

13 to me, that is a breach of the freedom of

14 information that we hold so dearly in this

15 country. This compromise in the case of

16 organic wines is a bad idea and can only lead

17 to more of the same in other products.

18 MR. GIACOMINI: Thank you. Any

19 final -- do you have any final word, or --

20 MR. SWANTNER: I just wanted to

21 say that I trust that people like the Freys

22 and the LaRoccas will continue to make truly
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1 organic wines, whatever happens with the

2 labeling issue. But I just -- what bothers me

3 is that their efforts would be invaded if

4 their wines get grouped in with other products

5 that are added to allow the 100 percent or 100

6 parts per million sulfide and still use the

7 same label.

8 MR. GIACOMINI: Okay. Questions,

9 comments?

10 (No response.)

11 MR. GIACOMINI: Thank you.

12 MR. SWANTNER: Thank you.

13 MR. GIACOMINI: Gwendolyn, Peggy

14 and Lindsay.

15 MS. WYARD: Good afternoon. My

16 name is Gwendolyn Wyard and I'm commenting

17 today on behalf of Oregon Tilth, a non-profit

18 organization supporting biologically sound and

19 socially equitable agriculture. My position

20 there is the technical specialist for the

21 processing program. I'm going to highlight a

22 few selected topics. You have all our
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1 comments in writing where you can refer to the

2 detail.

3 First on the USDA regulations with

4 respect to the made with label, we don't

5 believe that when consumers look at a label,

6 if that label had statements certified to be

7 USDA regulations, we truly don't believe that

8 they'll immediately understand that the

9 product or handler has gone through the same

10 certification process as an organic product. 

11 Probably instead they would wonder what are

12 those USDA regulations and certified to what? 

13 For the record, we wholeheartedly

14 support the made with labeling category and we

15 would like to see consumers understand the

16 rigorous certification process that is applied

17 to this label. However, we feel that this

18 should be done through educational efforts

19 emphasizing any agricultural product making an

20 organic claim on the principle display panel

21 must be certified to the USDA NOP regulations,

22 exemptions, exclusions and non-scope products
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1 noted. So it's a young regulation and time,

2 education and awareness is the answer, not

3 another labeling claim that leads to confusion

4 and label reading fatigue.

5 Yeast. This is my thirteenth

6 consecutive Board meeting. In October of 2004

7 Oregon Tilth came to the Board and asked that

8 you help to clarify the definition of non9 agricultural. So for 13 meetings I've been

10 listening to this discussion, following

11 closely and helping out, and I've seen yeast

12 be the holdup in many respects, trying to

13 classify yeast, when really the issue here was

14 giving yeast a chance, allowing it to have

15 organic preference assigned to it. So I'm

16 here today to say, let's give yeast a chance. 

17 I think it's a great compromise, it will

18 promote the production of organic yeast

19 resulting in increased organic acreage. It

20 recognizes that yeast can meet the '95 five

21 composition standards for a processed

22 agricultural product without categorically
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1 classifying all microorganisms as

2 agricultural. It recognizes the difference in

3 composition requirements for products intended

4 for human consumption versus livestock

5 consumption, and most importantly it's

6 consistent with NOP's guidance and

7 certification of organic yeast and processed

8 agricultural products, NOP 5014, effective

9 March 2nd, 2010.

10 Nanotechnology, we're in favor of

11 the locked door, a.k.a., they are synthetic,

12 therefore they're prohibited now today. And

13 we support that the NOP take action now by

14 adopting the recommended guidelines.

15 We also would like to publicly

16 recognize that there is widespread public

17 concern over the use of nanotechnology and

18 emphasize that, in any possible future

19 consideration of nanotechnology, the burden of

20 proof must weigh strongly against the

21 proponents to prove that the material is safe. 

22 At this point in time, too little is known
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1 about the impact of nano particles on human

2 health and the environment, therefore we do

3 support the precautionary principle as we move

4 ahead in our efforts to learn more about its

5 applications. But we do not support a general

6 prohibition of nanotechnology. It's

7 synthetic, it's prohibited.

8 Limitations of 205.101(b), we

9 request that the CACC make it very clear that

10 the intent of this recommendation is to

11 require traders, brokers and distributors to

12 become certified when the conditions of

13 205.101(b) are not met, and ownership is

14 transferred from the certified operator to the

15 uncertified broker, trader and distributor. 

16 Please clarify that this does not include the

17 third-party contracted transportation of

18 certified product from one certified operator

19 to the next.

20 And finally, I'd like to draw your

21 attention to a comparison chart that we've

22 included in our comments. This is with
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1 respect to nutrient vitamins and minerals. 

2 Our concern is that somewhere between the

3 intent of the Board and the recommended

4 annotation that wasn't accepted, the program's

5 decision to reference 21 CFR 104.20 containing

6 the nutrient listing that hasn't been amended

7 since January of 1993, and then the FDA

8 clarification of the interpretation on 104.2,

9 we have or will lose the ability to use

10 nutrients that may be essential or at very

11 least reasonably desirable in the diet. So

12 what I have done is I have put a side-by-side

13 comparison of the vitamins and minerals listed

14 in 104.20. The vitamins and minerals that are

15 listed in 101.9(c)(8), and this is -- 101.9

16 establishes the declaration of nutrition

17 information, and specifically that portion

18 sets the RDIs and nomenclatures established

19 for vitamins and minerals which are essential

20 in human nutrition. So I'll just point out

21 quickly to wrap up here that the highlighted

22 ones, selenium, manganese, chromium, these
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1 here that are listed in 101.9, these are

2 commonly used. We, as an organization, have

3 been allowing those vitamins and minerals

4 because 104.20 specifically references 101.9

5 in the beginning, and it states that, from

6 time to time, they recognize that the

7 nutrients listed in 101.9 may be updated. And

8 that has been more recently updated than

9 104.20. So this is a real problem for several

10 products that are out there.

11 Thank you very much.

12 MR. GIACOMINI: Thank you. 

13 Questions and comments? John?

14 MR. FOSTER: Thank you Gwendolyn,

15 that's really helpful. I love a good

16 analysis, you know?

17 MS. WYARD: Thank you, John.

18 MR. FOSTER: So on the 101(b) --

19 on the 101(b) deal, there's -- my question is

20 about transfer of ownership being a lynchpin. 

21 In the case of a broker, it's often not a

22 transfer of ownership but a transfer of
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1 possession, not necessarily of title. Would

2 it be fair to say that if an uncertified

3 operator storing, accumulating, parceling out

4 over time, is title absolutely necessary as a

5 lynchpin for you or for Oregon Tilth?

6 MS. WYARD: I think it is. I

7 think it's important.

8 MR. FOSTER: Title is important?

9 MS. WYARD: Title is important.

10 MR. FOSTER: Okay, thank you.

11 MR. GIACOMINI: Tracy?

12 MS. MIEDEMA: Does the program

13 have any position on compliance of products

14 that contain vitamin K currently?

15 MR. McEVOY: Yes, the position is

16 that there was a broad interpretation of

17 nutrient vitamins and minerals in reference to

18 104.20, and that's where we're issuing draft

19 guidance to clarify what -- the FDA's

20 interpretation of what is allowed under 21 CFR

21 104.20. So vitamin K would be currently

22 allowed under the previous allowance by NOP
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1 and by certifiers.

2 MR. GIACOMINI: Okay. Jay?

3 MR. FELDMAN: Cut me off after

4 three minutes, okay?

5 MR. GIACOMINI: Okay.

6 MR. FELDMAN: Thank you. You

7 know, maybe you can help me with this,

8 Gwendolyn, I'd appreciate it. We -- the Board

9 received a technical review from the USDA's

10 science and tech, and the world seemed simple

11 back then because we received a document that

12 says the sulfur dioxide added to the fermented

13 material that -- I'm talking about CSL - the

14 sulfur dioxide added to --

15 MR. GIACOMINI: Wait, wait, Jay. 

16 She didn't.

17 MS. WYARD: Oregon Tilth did not

18 submit comments on corn steep liquor, and so

19 I'm not prepared to make any comments.

20 MR. FELDMAN: Is that right?

21 MS. WYARD: It's true.

22 MR. GIACOMINI: I don't know, it's
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1 listed here on the list, but I -- she

2 certainly didn't mention.

3 MR. FELDMAN: We know she didn't,

4 but it's in her -- 

5 MS. WYARD: We -- I certainly --

6 it's true, it is. But if I did answer any

7 questions it would be by Gwendolyn Wyard and

8 not Oregon Tilth.

9 MR. FELDMAN: Okeydoke.

10 MR. GIACOMINI: Lisa, can you take

11 us up to the top of that chart, please? And

12 the first column is the one that we're

13 supposed to be working with, right, Gwendolyn? 

14 Okay.

15 MS. WYARD: That is the -- yes,

16 the -

17 MR. GIACOMINI: Have you ever had

18 to deal with an issue of added protein under

19 this listing?

20 MS. WYARD: We have had operators

21 submit a request for a formulation that

22 contained various proteins, yes, where they
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1 were classifying them as a protein and

2 pointing to 104.20. Now the problem as you

3 see up there is that the annotation

4 specifically references vitamins and minerals. 

5 So that was the other part of the

6 clarification, that just because it's under

7 104-point -- well, (d)(3), the annotation

8 doesn't include protein.

9 MR. GIACOMINI: Okay. Any other

10 questions for Gwendolyn?

11 (No response.)

12 MS. WYARD: Thank you so much, and

13 especially thank you to the outgoing Board

14 members for your steady and absolutely

15 fantastic service and, at times,

16 entertainment.

17 MR. GIACOMINI: Okay. Peggy,

18 Lindsay and Kyla.

19 MS. MIARS: Good afternoon, my

20 name is Peggy Miars and as of about five weeks

21 ago I am the executive director of OMRI. 

22 Thank you to the Board members for your
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1 service in the organic industry -- service to

2 the organic industry, and thank you for this

3 opportunity to speak.

4 First of all, we're announcing

5 today that OMRI's products list has exceeded

6 2,000 products approved for use in organic

7 production and processing. And I've heard

8 OMRI's name mentioned several times over the

9 last couple of days, and I know that OMRI's in

10 a unique position as the global leader in

11 materials review. And along with that

12 position comes healthy debate and

13 disagreement. So I'm here today to affirm for

14 the analysts and the organic community that we

15 at OMRI strive for consistency and high

16 integrity in materials review. We are

17 supported by crops, livestock and processing

18 review panels comprised of individuals with

19 decades of experience in organic and many with

20 advanced degrees in sciences.

21 Our staff evaluates materials

22 based on chemistry, functionality and the
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1 residue of synthetics. I personally look

2 forward to enhancing OMRI's relationship with

3 ACA's, the NOSB, NOP staff, EPA staff and

4 other agencies and organizations. And our new

5 management team is poised to take OMRI to the

6 next step in our history, and I invite any

7 NOSB members or organic stakeholders to

8 contact me with questions, comments or

9 concerns, just as some of you have been doing

10 since before I even started my new job. 

11 However, I will defer any technical questions

12 to our review program manager, Lindsay

13 Fernandez-Salvador, who is our next speaker. 

14 In other words, don't ask me about corn steep

15 liquor. I don't know.

16 MR. GIACOMINI: Is that -- oh --

17 MS. MIARS: That's it. I'm done. 

18 Short and to the point.

19 MR. GIACOMINI: Questions and

20 comments? I'm so not used to having someone

21 not go past the buzzer that I'm just not ready

22 at all. Okay. Thank you very much.
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1 MS. MIARS: Thank you.

2 MR. GIACOMINI: Okay. Lindsay, is

3 it Kayla or Kyla? Kayla?

4 MS. SMITH: Kyla.

5 MR. GIACOMINI: I had it right the

6 first time -- and Tiffanie.

7 Lindsay, go ahead.

8 MS. FERNANDEZ-SALVADOR: Okay,

9 thank you. I'm Lindsay Fernandez-Salvador. 

10 I'm a program manager at OMRI. I was going to

11 spend most of my time talking about excipients

12 and 205.238(c)(2), but the NOSB answered my

13 questions and I sincerely appreciate your

14 response. That was a very sweet victory for

15 me, so I'm going to take it home and do

16 something with it.

17 Unfortunately, though, that leaves

18 me over four minutes to talk about my favorite

19 topic, corn steep liquor. I oversaw the

20 second of two votes that our advisory council

21 hops committee made on CSL. I probably have

22 the most intimate knowledge of how we arrived
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1 at our synthetic classification than anybody

2 in this room. So I encourage anybody that

3 wants to know the truth about our decision

4 making to ask me. I've distributed a copy of

5 the decision tree that's in our policy manual,

6 it looks like that this, that OMRI used to

7 make our classification. This decision tree

8 was proposed by the NOP in March 2006 based on

9 NOSB recommendations. We use this decision

10 tree when evaluating materials that need

11 further clarification.

12 I'd like to start especially by

13 supporting Jay's statement that the NOSB

14 should base their vote on the process by which

15 corn steep liquor is manufactured and not the

16 compatibility to organics, because that is the

17 question that we're charged with by the NOP,

18 and that is what the public was asked to

19 comment on. 

20 OMRI looks to the NOSB for

21 deliberations to inform our interpretations. 

22 On Monday morning, I have to go back to work
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1 and I have to help my staff understand how to

2 make classification decisions. Our decision

3 making process does not include compatibility

4 to organics. I strongly encourage members to

5 return to the facts of the manufacturing

6 process to inform your vote on the

7 classification of this material.

8 I'd also like to take a moment to

9 correct some misconceptions on part of the

10 committee -- one some of the part of the

11 committee members about classification

12 materials, and we did touch on this a little

13 bit during today's comment, but I just want to

14 reiterate that. The simple contact with the

15 synthetic not on the National List does not

16 automatically make an input synthetic. It is

17 the action of the synthetic during the

18 manufacturing process that leads to a chemical

19 change, and this is what renders the input

20 synthetic. Using this logic, that simple

21 contact causes an input to be synthetic, would

22 cause a sizeable portion of the 2,000 OMRI
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1 list of products to come off our list.

2 Further, the statement that

3 because CSL is used in compost, it should be

4 allowed is not accurate. Once a compost feed

5 stock is classified as synthetic by virtue of

6 the chemical change brought on by the

7 manufacturing process, it is then prohibited

8 as a compost feed stock. To give you a very

9 obvious example, plastic will break down if

10 put in a compost pile, if you give it enough

11 time. But clearly we would not allow it as a

12 feed stock because it is synthetic. The same

13 is true about CSL, if it is first classified

14 as synthetic. 

15 So in conclusion, I am confident

16 in OMRI's process by which we arrived at the

17 synthetic classification for CSL. Given the

18 debate I saw yesterday, I am not confident

19 that the NOSB members are on the same page on

20 how to make the classification, which is

21 essential to consistent decisions for the

22 greater good of the organic industry. I urge
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1 you to consider the impact of your decision on

2 those of us that must make consistent material

3 classifications every day. Before taking your

4 vote tomorrow, please ensure that everybody

5 has used the same method to evaluate the

6 material, and only focus on the manufacturing

7 process and chemical change to determine the

8 classification.

9 Thank you.

10 MR. GIACOMINI: Questions -- Joe?

11 MR. SMILLIE: Were you in the room

12 for the previous testimony from -- 

13 MS. FERNANDEZ-SALVADOR: Yes.

14 MR. SMILLIE: -- the gentleman? 

15 He went through the process and explained the

16 actual process.

17 MS. FERNANDEZ-SALVADOR: Yes.

18 MR. SMILLIE: What disagreements

19 with his -- would you have any disagreements

20 with his explanation of the wet milling

21 process?

22 MS. FERNANDEZ-SALVADOR: Dragan's
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1 explanation was excellent. Thank you, Dragan,

2 for bringing that to light. I wish that he'd

3 have gone first because it was so thorough and

4 really explained the intricacies of the

5 process. And OMRI did take into consideration

6 his main points. And the main disagreement

7 was two-fold: One could argue that lactic

8 acid and lactobacilii is the only factor

9 causing the cleavage of disulfide bonds. And

10 that would then fall under naturally occurring

11 biological processes and we would remove this

12 from the classification of synthetic.

13 OMRI was not -- our advisory

14 council members on the crops committee was not

15 convinced that it was only lactobacilii that

16 was causing this cleavage. While that

17 argument is certainly true, that it probably

18 is causing some of the breakdown, it's

19 certainly not causing all of the breakdown and

20 that SO2 is probably also cleaving disulfide

21 bonds.

22 MR. SMILLIE: Well, that's not
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1 what he said. He said, if I can summarize it

2 in my layman terms, that basically that the

3 SO3 has the ability to do that, and that's

4 what the -- whatever their names are -- the

5 scientists did. But that in the commercial

6 wet milling process, because of the pH, it

7 wasn't doing it. And that it was there to

8 prevent putrefaction. So that the enzymes,

9 the lactobacilis enzymes could do that work,

10 and that the bulk of the work was being done

11 by them, and in fact, the chances of the

12 sulfurous acid doing the work was almost nil

13 because it wasn't -- the pH for it to operate

14 wasn't there at the time when that

15 concentration was there -- if I got it right.

16 MS. FERNANDEZ-SALVADOR: I think

17 you did, yes. And I would say that, without

18 putting words in any council member, I would

19 say that they were not convinced that it was

20 only happening via lactobacilii. That sulfur

21 dioxide or the active SO3 could and would also

22 create the same effect. And that if it was
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1 created by SO3, HSO3, then it was synthetic in

2 that instance and would render the entire

3 product synthetic.

4 MR. SMILLIE: Thank you.

5 MR. FELDMAN: Joe, I wish -- I

6 really wish it was as simple as that. I mean,

7 we started this whole odyssey with a technical

8 review, which we try to do, you know, when we

9 review this stuff. And the first thing that

10 catches everybody's eye is the statement that

11 it's a complicated process of chemical --

12 MR. GIACOMINI: Jay, can we stick

13 to -- can we stick to questions for Lindsay,

14 please?

15 MR. FELDMAN: Yes. I want to -- 

16 MR. GIACOMINI: We're trying to

17 stay on the schedule.

18 MR. FELDMAN: Okay.

19 MR. GIACOMINI: We're getting back

20 to somewhere even close.

21 MR. FELDMAN: -- that are not

22 fully understood. So I guess what I'm asking
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1 is, given that we received a technical report

2 which explicitly says it's a complicated

3 process not fully understood, and that the

4 sulfur dioxide added to the fermented material

5 to cleave disulfide linkages, which again was

6 the only finding we found in here as to why

7 sulfur dioxide was included, it's surprising

8 to learn at the eleventh hour now that there

9 is, in fact, a different process that does not

10 cleave the disulfide bonds. Is that a

11 surprise to you? Is this some new information

12 to you, having gone through this review

13 before?

14 MS. FERNANDEZ-SALVADOR: No, it's

15 not. We had the information that Dragan

16 presented just a few minutes, and that's just

17 a function of the person that you hire to do

18 your TR.

19 MR. FELDMAN: Yes, that's what we

20 did. Okay. What about the different levels

21 of sulfur in the end product? Why are we --

22 why do you believe we're seeing the different
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1 levels of sulfur in the end product?

2 MS. FERNANDEZ-SALVADOR: We didn't

3 take that into account. We were convinced by

4 a lab result that there was a non-detect of

5 sulfites as a proxy for sulfurous acid. That

6 was not an issue in our synthetic, non7 synthetic determination.

8 MR. FELDMAN: Okay. Just to

9 summarize then. You've looked at the same

10 information that we heard previously, but your

11 position is that the reason for the

12 introduction of the sulfur dioxide is to do,

13 what?

14 MS. FERNANDEZ-SALVADOR: Our

15 position is that, while lactic acid or

16 lactobacilii is likely causing some or maybe

17 even the bulk of the disulfide cleavages, SO2

18 cannot be ruled out that it is not cleaving

19 disulfides. 

20 MR. FELDMAN: Thank you.

21 MR. GIACOMINI: Okay, question. 

22 But your knowledge base -- I'm confused where
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1 the knowledge base came from in the processes

2 that are used commercially to make corn steep

3 liquor. I'm confused where your knowledge

4 base came from to make that assumption, other

5 than it's just an assumption made to people,

6 for lack of a better term, without being --

7 without wanting to be intensive at all, but

8 these are things that made them comfortable?

9 MS. FERNANDEZ-SALVADOR: Well, the

10 knowledge base came from literature and the

11 same information that was presented just a few

12 minutes ago. And while some people are

13 convinced that it only happens by

14 lactobacilii, the evidence presented in these

15 papers did not convince our crops committee

16 that it was --

17 MR. GIACOMINI: They were corn

18 steep process or were they chemistry table

19 process?

20 MS. FERNANDEZ-SALVADOR: I don't

21 understand your question.

22 MR. GIACOMINI: They -- were they
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1 the type -- were they corn stepped liquor

2 commercial processing processes or were they

3 studies looking at the -- like the other study

4 that he talked about?

5 MS. FERNANDEZ-SALVADOR: Corn

6 steep liquor manufacturing processes and also

7 the chemical explanation that was laid out by

8 Dragan. 

9 MR. GIACOMINI: Okay. Joe?

10 MR. SMILLIE: Chopped liver.

11 MR. GIACOMINI: No, I'm just

12 standing there, I'm looking that way.

13 Katrina?

14 MS. HEINZE: I'll ask you the same

15 question I asked before, because I want to

16 make sure that folks on other topics get a

17 chance with us today before we completely burn

18 out. Are you here tomorrow?

19 MS. FERNANDEZ-SALVADOR: I am here

20 tomorrow until one-ish.

21 MS. HEINZE: That's good to know. 

22 Thank you.
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1 MS. FERNANDEZ-SALVADOR: I

2 appreciate the time. Thank you.

3 MR. GIACOMINI: A question from

4 the Board. Dragan has requested time at the

5 microphone to respond to this. What is the

6 opinion of the Board? 

7 (Off mic comments.)

8 MR. GIACOMINI: Wait, Dragan, we

9 seem to be up for debate here. Are we going

10 to need to be very brief on this or -- I mean,

11 we're way behind schedule, folks.

12 MS. FERNANDEZ-SALVADOR: Might I

13 say that I don't want to get into a big debate

14 with anybody else. I'm relaying information

15 from other people. So I prefer that we do not

16 do that. At least I prefer not to be a part

17 of it.

18 MR. GIACOMINI: I think the

19 majority of the Board is to not right now. If

20 you're here tomorrow, we may do that and we're

21 just trying to get -- we think we understand

22 both sides, and it's going to come down to
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1 just people's impressions of where the -- what

2 the facts are and where the information comes

3 from, and all of that, to make a decision for

4 any individuals who want to make a decision,

5 and people will disagree. So anything further

6 here?

7 (No response.)

8 MR. GIACOMINI: Thank you very

9 much, Lindsay. Next is Kyla.

10 MS. SMITH: Kyla.

11 MR. GIACOMINI: Kyla, Tiffanie and

12 Mr. Wolf.

13 MS. SMITH: Good afternoon. My

14 name is Kyla Smith, I am a certification

15 specialist and an inspector for Pennsylvania

16 Certified Organics. I am here to give some

17 insight into the need for clarification around

18 101(b) with a specific example on how this is

19 affecting our certified farmers in regards to

20 the brokering of hay and impact this has on

21 organic integrity.

22 This has really come to a head
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1 over the past year and a half. This issue has

2 reared its ugly head at many inspections

3 during this time where the farmer who

4 purchased hay from a broker had a certificate

5 from the certified producer of the hay, and an

6 invoice from the broker whom is not certified. 

7 There is obviously a missing link in this

8 audit trail which doesn't link the hay back to

9 the original grower. It would be way too easy

10 for a broker to acquire a certificate and pass

11 any hay off as certified.

12 In my mind, the issue at hand is

13 not whether the hay is considered a packaged

14 product or not, rendering a possibly

15 exclusion, the issue is whether the broker is

16 taking ownership of the hay, which is clearly

17 a function of handling as defined by the Rule. 

18 For example, if a producer is

19 using a custom operator to haul hay, this

20 transport is put into their organic system

21 plan and covered during the producer's

22 inspection, including the audit trail. This
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1 is clearly an instance where the trucker would

2 not need to be certified. On the other hand,

3 we are seeing these brokers take ownership of

4 the hay they are transporting as they are

5 reselling this hay and are providing a new

6 invoice. In some cases, they are breaking up

7 loads or combining loads from various farms. 

8 In most cases, they are providing the

9 purchaser of the hay with a certificate but

10 without an invoice to link it back to the

11 original grower. Without that, the

12 certificate doesn't really mean anything.

13 As it currently stands, these

14 brokers are not seeking certification as they

15 believe they are excluded, therefore they are

16 not inspected, which greatly affects the

17 organic integrity of the cows which are being

18 fed this hay.

19 Sorry -- ultimately this falls on

20 the shoulders of the farmer that purchased the

21 hay. If they don't acquire the proper

22 documentation, their certification is the one
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1 that is in jeopardy. In some cases, buying

2 from a broker is a new process for them, and

3 they are unsure of what documentation they are

4 required to have. In many cases, they are

5 probably being told by these brokers that, as

6 long as they have a certificate, that is all

7 they need. Farmers are literally about to

8 lose their certification because they are not

9 able to provide the documentation required to

10 prove that they -- that the feed they

11 purchased is, indeed, organic because these

12 brokers are not forthcoming with the original

13 invoice or transaction certificate or weight

14 slip, or whatever you want to -- whatever they

15 need.

16 As far as the costs are concerned,

17 not all brokers would need to be certified. 

18 If these folks are clearly just hauling hay or

19 working on commission and not reselling by

20 taking ownership of this hay, they would not

21 need to be certified. However, I know that

22 it's my goal, as I believe it is many people
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1 here, to grow the organic industry while

2 upholding organic integrity through the

3 enforcement of the regulations. Requiring

4 certification of brokers that are clearly

5 handling would result in a nominal fee for a

6 few while growing the industry. I also don't

7 believe the cost should be a basis on whether

8 or not an operation is required to be

9 certified.

10 While I can't predict if this will

11 increase costs to the farmer, it would

12 certainly be very minor in comparison to

13 losing their certification or inadvertently

14 buying from a broker who does not have

15 verifiable documentation.

16 I know this issue goes beyond hay

17 brokering in Pennsylvania, but I thought a

18 specific example would help to clarify the

19 need for guidance from NOP on this issue.

20 Thank you for your time and

21 diligence in this matter.

22 MR. GIACOMINI: Questions,
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1 comments?

2 (No response.)

3 MR. GIACOMINI: Thank you.

4 MS. SMITH: Thank you.

5 MR. GIACOMINI: Tiffanie?

6 MS. HUSTON-LABBE: Yes.

7 MR. GIACOMINI: Bill Wolf and

8 Katherine -- Katherine.

9 MS. HUSTON-LABBE: Good afternoon. 

10 I am Tiffanie Huston-Labbe, and I don't know

11 if it matters, last name, H-u-s-t-o-n, L-a-b12 b-e.

13 I'm the farm program manager at

14 Oregon Tilth, so I'll spare you the details

15 about Oregon Tilth, as you've already heard

16 from Gwendolyn. But we do want to thank the

17 members of the Committee and the NOP for their

18 notable efforts and progress, and we really

19 appreciate the opportunity to be present and

20 comment and be a part of the process.

21 We have a few comments that echo

22 many that were presented on Monday as well as
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1 today. EPA List 4, quickly, not that our bid

2 for urgency will impact the speed of the

3 government, but we do hope that the workable

4 solutions for this issue will be pursued with

5 gusto, as it is very apparent it is needed to

6 help us move forward efficiently and with

7 clarity.

8 Agriculture, we want to thank ACA

9 and industry members for their work. We

10 strongly support the recommendation of the

11 livestock committee and join them in calling

12 on the NOP to implement these standards as

13 soon as possible. Doing so will provide the

14 opportunity and market to the many, many

15 producers seeking to have their products and

16 practices serve as a -- recognized as organic.

17 Animal welfare, with 238 we don't

18 foresee any enforcement changes as mainly due

19 to the fact that we were practicing under what

20 the Chairman referred to as the status quo. 

21 However, since the language addition is

22 focused on technical interpretation, it is
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1 suggested to include a definition of

2 preventatives along with the rule change.

3 Animal welfare discussion. The

4 inclusion of modern animal husbandry

5 principles and techniques is commendable. We

6 believe it is every livestock producer's

7 desire and best interest to handle animals in

8 a low-stress manner, and that animals' welfare

9 and condition is and should be at the

10 forefront.

11 A few comments with regard to the

12 discussion documents. Will there be an

13 economic assessment analysis conducted

14 regarding the implementation of these

15 proposals as there was with the pasture rule? 

16 We believe there needs to be some

17 consideration on the rotation of outdoor

18 access areas with respect to the stocking

19 density, management and requirements. Clarity

20 is requested regarding the acceptable levels

21 of poor body condition, lameness and lesions. 

22 It is our opinion that if requirements are
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1 proposed for ruminants on physical welfare

2 assessments, similar requirements should be

3 set for all livestock except for bees because

4 I have no idea how body condition score a bee.

5 Speaking of body condition score,

6 if body condition scoring is not required, how

7 can an inspector accurately assess and report

8 on specific number of animals? Specifically,

9 how can an inspector judge less than two or

10 five percent if they are not required to

11 assess a specific number of the whole herd or

12 flock?

13 The science behind the suggestion

14 of maintaining ammonia levels is also

15 understood and appreciated. This is something

16 that our staff and inspectors have already

17 been auditing, assessing and taking

18 enforcement action upon without the specific

19 parameters, however the question with this

20 proposal comes back to audit ability and

21 economic impact. So certifiers would need

22 clear understanding of testing requirements,
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1 including documentation required and the

2 responsibility of payment for those tests.

3 The science behind the suggestions

4 that animals in contemporary have a herd/flock

5 mate within visual contact is, again,

6 understood and appreciated. It is common

7 knowledge that herd animals are less stressed

8 and easier to handle quietly and safely in the

9 company of a herd mate. However certifiers

10 will, again, need clear guidance on the

11 documentation required and the audit ability

12 of this requirement.

13 That's all I have. Thank you.

14 MR. GIACOMINI: Question or

15 comments?

16 (No response.)

17 MR. GIACOMINI: Yes, I -- just for

18 clarification, when we came forth with our

19 document from the livestock a couple of years

20 ago on body condition and lesions, Oregon

21 Tilth was one of the most vocally opposed to

22 that action. Has that changed? Does that
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1 opinion -- did I understand that you've

2 changed that feeling within your organization?

3 MS. HUSTON-LABBE: Our feeling on

4 animal welfare has not changed. We've always

5 felt that was very important and people should

6 be conducting those. What Oregon Tilth

7 historically has tried to get away from is

8 very specific requirements on practices on the

9 farm level. So the audit ability of counting

10 lesions is not a problem. When it gets down

11 to numbers and estimates and having to assess

12 a whole herd, that just comes down to being

13 prescriptive on management practices as well

14 as the inspection, you know, timeliness and

15 accuracy and those things. So that's been our

16 perspective on those comments. And that has

17 not changed.

18 MR. GIACOMINI: That wasn't quite

19 the way it was expressed in some emails I

20 received from -- so well, maybe it's evolved

21 a little bit.

22 Okay. We appreciate that, though. 
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1 Okay. We're past where we should -- we're

2 scheduled to take a break. Let's take one

3 now. It is 3:30, 3:45 back in session. 

4 Please be prompt.

5 (Whereupon, the above-entitled

6 matter went off the record at 3:31 p.m. and

7 resumed at 3:50 p.m.)

8 MR. GIACOMINI: If the Board

9 members can find their seats, audience,

10 gallery finds their seats, take any -- oh,

11 there's no conversations. You guys are

12 getting so good at this. 

13 Joe, we're ready -- the rest of us

14 are ready to start. Bill, you can go ahead,

15 it's only Joe.

16 MR. WOLF: Well, my opening --

17 does this slide? Okay.

18 My opening comment is to say I

19 want to thank the five retiring Board members

20 an the ten that remain. Extraordinary,

21 extraordinary work this last six months.

22 I'm going to address a number of
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1 broad issues, and I will point out that there

2 were two public comments that we submitted in

3 great detail to the Board and I hope -- did

4 all of you read those comments? Thank you.

5 I want to cover -- I've got to

6 find out how to run this -- there we go. 

7 First of all, just to introduce myself, Wolf,

8 DiMatteo and Associates are strategic

9 consultants in the organic industry. I've

10 been involved with organics since 1971, a

11 broad range of experiences from farming to

12 just about every aspect of organic, including

13 being a pesticide manufacturer at one point. 

14 I want to talk about basically

15 some underlying principles that I believe are

16 critical in the decision making here. And the

17 roots of organics in soil, and in soil health,

18 and the principles behind how the world's

19 evolved. This guy, our little earthworm, is

20 really one of the originators of the decision21 making process. And I'd like to just bring

22 our earthworm to the table in the process of
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1 thinking about some of the decisions we make. 

2 We're trying to encourage earthworms and

3 ladybugs and evaluate products in that

4 context. And the criteria for materials

5 decisions, to a great extent, are easy to

6 understand when you think about what's good

7 for them.

8 There's another aspect to the rule

9 that's different from almost any other

10 regulation, and that is that it's not static. 

11 It is built around continuous improvement. 

12 There are numerous sections of the rags that

13 get involved in continuous improvement. 

14 Organic is more than just a no-chemical

15 pesticides or fertilizers, and I think it's

16 really important to think in terms of that --

17 the core underlying principles and not, per

18 se, what we've marketed to the consumer and

19 then respond to that consumer's

20 misunderstanding of the depth of organic in

21 making our decisions.

22 Okay, now my clicker's not
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1 working. Next slide, that one. Okay.

2 About continuous improvement, one

3 of the most dramatic factors that's occurring

4 is that we really have not solved problems

5 with how to evaluate and manage commercial

6 availability. And I'd to address three

7 general recommendations that are going to help

8 in decision making about materials. One is,

9 I think it's critical that the public know and

10 the growers and the processors know what

11 commercial availability decisions are being

12 made by ACAs. That process alone will

13 increase the availability and solve the

14 problems as it has, for example, with hops. 

15 

16 We therefore just simply create a

17 list, have a mechanism where ACAs must report

18 what decisions they make, both around seed and

19 around 606 items. The second, apply organic

20 preference to all non-organic ingredients and

21 merge 605 and 606 as originally envisioned in

22 OFPA.
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1 The last point I'd like to make is

2 that we have fewer acres entering organic and

3 that growers and processors are confused

4 because we have a unstable regulatory

5 environment. Four examples at this meeting

6 that would be helpful that we should talk

7 about is uniform certification and

8 enforcement, which the Department is really

9 moving forward with. Renew list for inerts

10 for five years while this new program is being

11 developed and allow a reasonable period for

12 transition to the new program. Allow re13 reviewed list for inerts to be used rather

14 than creating a vacuum where nothing can be

15 changed and vote CSL non-synthetic.

16 I appreciate OMRI's comments. I

17 think there's been a lot of new information

18 brought forward and I think that the

19 processing committee of OMRI should have been

20 involved in that original decision.

21 I do want to respect Oliver the

22 earthworm, the USDA's earthworm at the -- at
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1 the USDA peoples' garden, and I want to keep

2 him -- keep Oliver happy. So on that note,

3 I'm open to questions.

4 MR. GIACOMINI: Questions? Joe?

5 MR. SMILLIE: Bill, you said

6 something that caught my interest. You said

7 that you thought that OMRI's processing

8 committee should have been involved in that

9 decision, or was that an intended comment?

10 MR. WOLF: Yes, the advisory

11 council was originally structured to have a

12 expertise from throughout all aspects of the

13 community. I was the founding president of

14 the Board of OMRI and was -- served in that

15 role for seven years. And the advisory

16 council was intended to generically look at

17 many of these issues and function to really

18 bring together all kinds of experts from

19 industry, from all across -- across all

20 communities. And the crops committee made the

21 decision to send it to the crop advisory

22 component of the advisory board.
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1 None of the members of the

2 advisory board, as I understand it, that were

3 on the -- it's been segregated rather than

4 holistically looked at. And so corn steep

5 liquor is a byproduct of food processing, so

6 the decision about whether it was a synthetic

7 process needed to include food processing

8 experts. So that was the point I was making. 

9 And so I -- you know, I respect OMRI's process

10 but I think that there's a lot of new

11 information that's come to light since that

12 decision was made. 

13 I think it's also important to

14 understand that some of that is the base. 

15 We're triggered by competitive complaints and

16 that we are now embroiled in a debate that

17 doesn't really move us forward as a community.

18 MR. GIACOMINI: Questions,

19 comments? Katrina, did you have something? 

20 (No response.)

21 MR. GIACOMINI: Okay, thank you,

22 Bill.
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1 Katherine. Kim Keitz, Gwendolyn

2 Wyard next.

3 MS. DiMATTEO: Katherine DiMatteo

4 and I'm the other part of Wolf, DiMatteo and

5 Associates, but we have a third partner also,

6 Sandy Mayes, so we are -- and we have

7 associates also throughout the U.S. that work

8 with us.

9 I want to make very clear that the

10 comments that we did submit that Bill referred

11 to reflect Wolf, DiMatteo and Associates, not

12 as paid consultants for particular clients,

13 but as individuals who work together who have

14 experience, long experience in organic. And

15 it does reflect our own opinions and our

16 perceptions and our wishes for the organic

17 community. And so I just want to credential

18 myself a little bit for those of you who don't

19 know me, and to remind those of you who do,

20 where this comes from in terms of my -- how I

21 look at the things that come before you and

22 come before all of us in the organic
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1 community.

2 I started out as a -- in consumer

3 co-ops, I worked 20 years in consumer co-ops. 

4 I worked for a Peace and Social Justice

5 organization. I worked for a sustainable

6 energy organization. For 16 years I was the

7 executive director of the Organic Trade

8 Association, I'm currently the president of

9 the International Federation of Organic

10 Agriculture Movements. So there's a deep and

11 broad and diverse background that I bring to

12 thinking about. And my opinions, and our

13 opinions at Wolf DiMatteo and Associates, I

14 also want to say, clarify again, we're not

15 influenced by clients. Rather we sometimes

16 turn down prospective clients because they

17 don't match what we would like to see come out

18 in terms of either inputs or certified organic

19 products or farms or participants in the

20 organic community.

21 So I won't spend much time on corn

22 steep liquor or try to repeat too much of what
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1 we wrote in our comments. I do want to just

2 point out that, unlike fish emulsion, corn

3 steep liquor is not developed to be a soil

4 amendment. It is a byproduct of food

5 processing. And I think that must be decided

6 to be a synthetic because it is a byproduct of

7 food processing. It doesn't differ from other

8 byproducts of food processing and the decision

9 for it to be a synthetic would have great and

10 long impact on many, many of the materials

11 that are used in composting in our community

12 today.

13 I also urge you not to put this

14 decision off. I think you've spent a lot of

15 time and with the changing of the guard and

16 thanks to the five retiring members, I think

17 the decision should be taken at this meeting.

18 Tina, thank you for clarifying the

19 posting of the document, I appreciate that. 

20 I know we made comment about our concerns, but

21 thank you for taking responsibility for that

22 and explaining it to us.
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1 The sunset review recommendations. 

2 We're really pleased to hear that the NOP has

3 been in discussion with the EPA and we're

4 really hopeful that the outcome of those

5 discussions provides a practical solution that

6 doesn't overburden the National Organic

7 Standards Board or discourage suppliers from

8 providing organic compliant inputs. I think

9 it's very important that we have a process

10 that moves forward in an orderly way and

11 doesn't disrupt or discourage the development

12 of organic compliance and less toxic products

13 that we can all use in many different ways

14 outside of organic production.

15 In terms of the policy committee,

16 sunset review process and their

17 recommendation, thank you very much to all of

18 the board members for the discussion that you

19 had yesterday. I thought you made great

20 progress and it was a great interchange and --

21 on the optic. And I appreciate the

22 recognition by the policy committee members,
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1 that they'll take that back and make some

2 adjustments to ensure -- to make the changes

3 needed to ensure, to allow for public comment

4 on annotations prior to a full NOSB vote. 

5 So I just want to read one part

6 from our comment because it's important to me. 

7 We realize that a limited list of allowed

8 synthetics is viewed by some as the correct

9 approach to ensure integrity of organic. We

10 disagree and believe it is not the number of

11 items that matters but the compatibility with

12 an organic system that is most important. It

13 is important to keep in mind that there will

14 always both new and experienced farmers and

15 handlers and the use and need for materials as

16 well as the effectiveness of alternatives is

17 dependent on the maturity of the farm or

18 handling operation.

19 Also the fact that an input is

20 synthetic or natural should not be the

21 paramount concern but rather it is the impact

22 on soil, crops, livestock, the environment and
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1 human health as well a judicious use that

2 ensures integrity and sustainability of

3 organic systems.

4 Thank you.

5 MR. GIACOMINI: Thank you. Any

6 comments or questions? Katrina?

7 MS. HEINZE: When you were talking

8 about CSL, I thought I heard you say

9 classified as synthetic. And I'm wondering if

10 that was what you meant?

11 MS. DiMATTEO: It was not. 

12 Classified as a non-synthetic.

13 MS. HEINZE: Thank you for

14 clearing that up.

15 MS. DiMATTEO: Because it is a

16 food processing waste material.

17 MS. HEINZE: I just wanted to give

18 you the chance.

19 MR. GIACOMINI: Okay. Any other

20 questions, comments?

21 (No response.)

22 MR. GIACOMINI: Okay. Thank you. 
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1 Tag team champions Kim Keitz, Gwendolyn Wyard,

2 Cameron Wilson and Jim Pierce.

3 MS. KEITZ: We have come out of

4 dormancy. The Material Working Group was

5 founded about three years ago, somewhere

6 around there, really to be an unaffiliated

7 collection of individuals with technical and

8 regulatory background.

9 Participation in the Group was

10 open and available to any interested party. 

11 In other words, it was not a function or

12 Organic Trade Association or any other group. 

13 It was Gwendolyn and I's mission to make sure

14 that anybody and everybody who wanted to

15 participate could so that we got a very well16 rounded group of individuals to -- with their

17 opinions.

18 So again our goal was to offer

19 working papers to the NOSB on the materials

20 issues and the list of individuals that

21 participated or somewhat -- some participated

22 more than others. But that was the group that
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1 was on the entire email list there, so to

2 speak. And what we're going to present to you

3 today is really just a summary over the last

4 several years of flow charts on material

5 review. Our charge is just to make sure that

6 we keep in front of you the history of

7 materials and how those things are reviewed.

8 MS. WYARD: Okay, not much time

9 here. Really what I'm about to deliver is a

10 motivational speech, to get the horse in front

11 of the cart and follow a process that involves

12 a decision tree and a narrative that supports

13 that decision tree and a worksheet that can be

14 filled out. And I know that since you're

15 getting beyond all the sunset materials, and

16 you mentioned, Katrina, that this is now going

17 to be a focus, that's really the intent of

18 what I have to say here today. 

19 So going back in time, this is the

20 NOSB recommendation of 2005. And in this

21 recommendation, some of the working concepts

22 that were being applied here, this is where
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1 the concept -- are you doing that, too, Lisa?

2 MS. BRINES: That doesn't work.

3 MS. WYARD: Okay, I appreciate

4 your support. I wasn't sure who was moving

5 what.

6 So at this point in time, this is

7 where this concept started. I don't think it

8 started here but it certainly was captured

9 here in this recommendation, that as long as

10 the extraction process does not chemically

11 change a substance that's being extracted, as

12 long as a chemical reaction does not occur. 

13 This is the idea that contact with a synthetic

14 substance, a processing aid, would not render

15 it synthetic unless a chemical change occurs.

16 The NOSB at this point spent a lot

17 of time, they put together a chemistry 101

18 paper and they really delved into what would

19 constitute a chemical change and exactly what

20 they meant by chemical change. So coming down

21 here, this -- that recommendation went on to

22 the NOP, and then the NOP, I believed they
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1 hired another organization to put together a

2 document which is referred to as the NOP

3 framework. And this is the decision tree of

4 '06. And basically they took the --

5 everything that the NOSB had in their

6 recommendation and they cleaned it up and they

7 made suggestions to make -- to help it make

8 more sense. And they put this decision tree

9 together.

10 And the Material Working Group

11 then came along and we looked at this decision

12 tree and we spent a time, quite a bit of time,

13 the group that you saw up there, improving

14 this decision tree. So yet another decision

15 tree was created. And the decision tree is

16 what was presented to the NOSB. Our document

17 was dated 4/20 of '09. And it basically took

18 a lot of very, very good information that was

19 put together in the NOP framework. We adopted

20 almost everything in that document related to

21 synthetic/non-synthetic and put it into our

22 document.
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1 I'm going to interject just a --

2 this next slide just to demonstrate. I'm

3 taking the liberty of bringing in something

4 that Oregon Tilth created. Simply as a

5 demonstration, what this is responding to is

6 the NOP response to the Board. What a

7 decision tree might look like if you were to

8 separate out agricultural and non-agricultural

9 from synthetic and non-synthetic. So as you

10 move ahead and you put your decision tree

11 together, we very much recommend, you know,

12 that the response from the NOP can be set up

13 this way where, right from the very beginning,

14 you ask, what are we dealing with? A crop

15 input, a livestock input, processing input. 

16 So that's just sort of the starting map.

17 Now the first decision tree that

18 we presented to you, we did not include a

19 question about significant levels, because we

20 couldn't come up with very good, clear

21 criteria of what a significant level would be. 

22 So we left that out. That has become very
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1 much a part of the discussion and we think

2 rightly so, and that was definitely very much

3 a part of the 2005 NOSB recommendation as well

4 as the NOP framework. 

5 So when you're looking at the

6 decision tree that the Material Working Group

7 submitted, here's -- we're going into examples

8 -- I'll just quickly wrap up -- these are

9 worksheets that you have to use, tools that

10 you can use. And make sure when you put these

11 worksheets together that you include -- and

12 this is information from the Material Working

13 Group document -- an explanation that goes

14 behind the definitions. These explanations

15 here didn't make it into your April

16 recommendation. You brought forward the

17 definitions, such as chemical change, but

18 there's very clear criteria that, you know,

19 gets into the explanation of what that means. 

20 And that's very helpful. And you can read

21 through this document here and see how

22 incredibly helpful these types of
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1 considerations would be to a determination of

2 corn steep liquor, for example.

3 Thank you very much.

4 MR. GIACOMINI: Question, Katrina.

5 MS. HEINZE: I wanted to thank you

6 for that summary and for the reminder. The

7 Fall 2009 document did adopt most of what the

8 Material Working Group recommended, and it

9 does have a sentence in there that, for a full

10 explanation of the thought process on how to

11 include -- apply the definitions, you do need

12 to look at the Material Working Group

13 document. So I do appreciate that reminder,

14 Gwendolyn.

15 MR. GIACOMINI: Further questions,

16 comments?

17 (No response.)

18 MR. GIACOMINI: Kim, you -- I'd

19 like to ask you a question. You were Material

20 chair for a number of years, you co-chaired

21 the working group. You showed the different

22 trees, the framework tree which is almost
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1 exactly the same as the OMRI tree that we gave

2 us, you showed us the other tree of

3 alternatives. Without getting into the

4 specific -- I'm not asking you whether you

5 think corn steep liquor is synthetic or non6 synthetic, and I'm hoping you won't have to

7 answer it from that perspective. Can you give

8 any of the Board members who are -- have for

9 whatever reason -- who are still looking -- as

10 we are still looking at this, so I'm going to

11 say everybody -- no one has fully decided, can

12 you give us any insight, recommendations, very

13 briefly on dealing with this issue? It's

14 complicated, it's that .1, .3 percent whatever

15 that's a problem.

16 MS. KEITZ: You know, it's painful

17 sitting out in the audience watching you guys

18 go through this because I know it's very tough

19 decisions that you have to make. I suppose my

20 advice would be that, you know, again, use the

21 tools that you've got in front of you. It's

22 your charge as a Board to make the best choice
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1 that you can at the end of the day. It's --

2 you know, I see two sides. You've got

3 scientists saying this and scientists saying

4 that. Again, at the end of the day, you've

5 got to make the best balanced choice with

6 that.

7 You know, I do -- I disagree with

8 the statement made earlier that you have to

9 just make a synthetic or non-synthetic

10 decision. I think you do have to look at

11 evaluation criteria. You know, you have to

12 take -- you have to look at this material as

13 a whole, you know, and if you're on the fence

14 on something, I think you need to defer to,

15 you know, what you think is best for the

16 industry and for the material. I guess that

17 would be my advice to you.

18 MR. GIACOMINI: Katrina?

19 MS. HEINZE: I should have asked

20 earlier, are you guys around tomorrow?

21 MS. WYARD: Yes.

22 MS. KEITZ: Yes.
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1 MS. HEINZE: Okay, thank you.

2 MR. GIACOMINI: Further questions?

3 (No reponse.)

4 MR. GIACOMINI: Okay.

5 MS. WYARD: Thank you.

6 MR. GIACOMINI: Thank you. 

7 Cameron Wilson? 

8 MR. WILSON: Yes.

9 MR. GIACOMINI: And Jim Pierce and

10 Cameron Wilson.

11 MR. WILSON: Me again. So I'm not

12 sure if I shift over there later, but --

13 MR. GIACOMINI: No, actually you

14 stay at the podium.

15 MR. WILSON: Okay, all right.

16 I'm going to talk about EDDS which

17 is a urgent matter we petitioned to the NOSB. 

18 I work for a company called Neudorff. 

19 Neudorff, German-based, family-owned company,

20 specializes in the development of natural

21 pesticides. Many of the products that we have

22 are NOP and OMRI compliant. We've petitioned
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1 the NOSB to add the biodegradable chelater at

2 EDDS to be allowed as an inert and pesticide

3 used in organic production. EDDS represents

4 the next generation of chelaters and was

5 developed to replace synthetic chelaters which

6 are currently on the August 2004 list of

7 inerts of minimal concern. EDDS, if improved,

8 would result in less synthetic chelaters being

9 put into the environment and our food system.

10 Many industries in Europe have

11 already embraced the use of EDDS to replace

12 synthetic chelaters due to the concerns

13 surrounding the synethetics. EDDS is used in

14 organic agriculture in Europe today. In

15 Switzerland, the FiBL organization has

16 approved EDDS for use in organic production

17 and most recently received verbal approval

18 from ECOCERT for the use of EDDS. We kindly

19 ask the NOSB to do the same.

20 NOSB recommended not to allow EDDS

21 to be added to the National List based on the

22 perceived lack of need to do available
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1 alternatives, the organic compatibility to

2 agriculture and the lack of detailed

3 information regarding the potential

4 environmental health and impacts to the

5 manufacturing process. When we first received

6 the TAP review, our first reaction was, it

7 looks like this was reviewed as an active

8 ingredient. That was our first impression. 

9 And still we went through the process of

10 responding, however we believe that it was put

11 into a process that looked at it as an active

12 ingredient, and we believe that the process is

13 flawed and it has to be looked at in a

14 different way because it is an inert.

15 I'm going to go on and state a

16 couple of reasons why I feel EDDS is

17 important, but I will -- I want to say my

18 summary first in case I get cut off. It's

19 that we ask the NOSB to defer the vote on EDDS

20 until the NOP, USDA and EPA collaborate on the

21 review process for inerts. 

22 So let me go through now and
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1 explain why we believe EDDS is important. 

2 There is a need for chelaters and pesticide

3 formulations used in organic production. 

4 Chelaters are commonly used inert ingredients

5 and are essential to the shelf stability of

6 pesticide formulations. Without their use,

7 less inputs would be available to organic

8 farmers. This would result in higher food

9 cost to the end user.

10 Metal ions introduced during the

11 manufacturing and packaging process will

12 oxidize both active and inert ingredients in

13 pesticide formulations rendering them less

14 stable and less efficacious. As mentioned,

15 less biodegradable synthetic chelaters are

16 currently on EPA's list 4(b) and allowed in

17 pesticides for organic production. These

18 chelaters are considered old chemistry and

19 have been replaced in many industries in

20 Europe with biodegradable chelaters such as

21 EDDS.

22 We have requests from U.S.
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1 customers to formulate with biodegradable

2 inerts such as EDDS and to stop using

3 synthetics. In Europe, EDDS is widely used in

4 a variety of high-volume industries because of

5 its excellent environmental profile. Some of

6 the diverse applications that EDDS has

7 replaced less biodegradable chelaters are

8 laundry detergents, surface cleaners, personal

9 care products, bleaching, photographic

10 development and agriculture, pest control

11 products and foliar fertilizers.

12 EDDS is compatible with organic

13 agriculture. EDDS is naturally occurring and

14 produced by soil microorganisms. EDDS is

15 already present in the ecosystem and the

16 mechanism for its utilization and degradation

17 by soil microbes are also present. EDDS is

18 completely and quickly mineralized by microbes

19 into carbon dioxide, water and ammonia. The

20 biodegradable nature of this compound led to

21 the Manufacturer Award and The Green Chemistry

22 Award in the U.K. and allowed for EDDS to
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1 obtain several European eco-label approvals.

2 EDDS has no adverse effects on

3 human, animals or the environment. EDDS is

4 considered of low toxicity to human by the EPA

5 and approved for use in food-contacting paper

6 products by the FDA. There will be no adverse

7 effects to people or animals when used as an

8 inert ingredient in pesticide formulations. 

9 The toxicity to EDDS has been tested on a

10 variety of non-target organisms such as

11 earthworms, dafnia, algea and fish and found

12 to be nontoxic at the concentrations well

13 above what would reasonably we would expect to

14 be using it at in inerts and pesticides.

15 As EDDS is naturally occurring and

16 rapidly and completely biodegradable, there

17 will be no adverse environmental impact. The

18 manufacture of EDDS does not pose a risk. One

19 of the things identified in the TAP was the

20 manufacturing process -- I'll finish up. The

21 process uses a compound dibromide ethane. 

22 It's carefully controlled in the production
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1 method and contained and the product EDDS does

2 not contain any dibromide ethane.

3 So --

4 MR. GIACOMINI: Thank you. Any --

5 MR. WILSON: -- I'll summarize and

6 say --

7 MR. GIACOMINI: Okay.

8 MR. WILSON: -- it's already being

9 used in Europe in organic products. And

10 again, just to reiterate, we ask the NOSB to

11 defer the vote until the process is

12 collaborated. 

13 Thank you.

14 MR. GIACOMINI: Joe?

15 MR. SMILLIE: I've got a lot

16 respect for FiBL. They are a very well-known

17 organization and do a good job. That's a very

18 good sign. I think that a request for

19 deferral until we've got the proper process

20 for judging these is an appropriate request.

21 MR. GIACOMINI: Crops Committee,

22 does that satisfy the request that you made
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1 regarding these -- the substances?

2 MS. ELLOR: It absolutely does. 

3 In fact, we got together this morning as a

4 Crops Committee and certainly we're willing to

5 defer it until the next meeting. And we're

6 certainly willing to defer it until the

7 process is-- the complete collaborative

8 process is up and running. So thank you so

9 much for coming.

10 MR. WILSON: Thank you.

11 MR. GIACOMINI: Thank you very

12 much.

13 MR. PIERCE: Mr. Wilson, would it

14 be easier for you to do your other

15 presentation now and --

16 MR. GIACOMINI: No, we're not

17 doing that.

18 MR. PIERCE: And Mr. Chairman and

19 Ms. Secretary --

20 MR. GIACOMINI: Jim Pierce,

21 Cameron again and then Lisa.

22 MR. PIERCE: A slight request. I
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1 should be able to finish my comments in about

2 four minutes, at which point I'll take

3 questions and then, if possible, I'd like to

4 use my last minute to make you smile.

5 MR. GIACOMINI: You're not going

6 to let us smile for four minutes?

7 MR. PIERCE: Not like that. So if

8 you'll just start the clock please and then

9 give me one more minute. All right.

10 I'm Jim Pierce from Oregon Tilth,

11 the best certifier. For the record, these

12 comments are on behalf of Oregon Tilth and/or

13 myself and are not intended to advocate for

14 any of our fine clients.

15 Most of you know from previous

16 testimonials that my particular brand of

17 organic zeal is as a lumper not a splitter and

18 as a staunch standards conservative but an

19 out-of-the closet materials liberal. You are

20 about to draw a line somewhere between hair

21 and fish. 

22 OFPA 65.17 addressing the National
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1 List is simultaneously verbose and vague on

2 organic -- on synthetic materials, but it is

3 clear that there is to be a list of allowed

4 synthetic materials. And by my read, the crux

5 of the assessment would be (c)(1)(A)(iii) that

6 the use of materials is consistent with

7 organic farming and handling.

8 As you debate and complete the

9 criteria information forms, please do so in

10 the spirit of previous Boards by weighing the

11 impacts against outcome benefits. In the

12 spirit of my NOSB mentor, George Siemon, also

13 ask who dies? Nothing, including organic

14 farming and convening an NOSB meeting is zero

15 impact. As Jeff Moore astutely noted

16 yesterday, Monday, if the weather turns icy

17 cold tomorrow, the environmental impact of

18 your decision to ban propylene glycol from

19 arguably compatible organic input would be

20 eclipsed manyfold as your plane is deiced. 

21 Irony? Yes, you bet ya, as they say here in

22 God's country.
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1 You need to draw a clear bright

2 line between synthetic and non-synthetic but

3 not here. If you decide that corn meal, corn

4 starch and corn oil, and as a byproduct corn

5 steep liquor are synthetic because of the

6 process, and regardless of the outcome, you

7 will certainly have set a precedent for a high

8 bar for organic integrity but you will have

9 done a disservice to the future of the

10 entrepreneurial spirit as well as future NOSB

11 Boards which will have to struggle with the

12 impact of your decision.

13 Now, before I lunge headlong into

14 the next lane of traffic, let me repeat that

15 I'm not advocating on behalf of any of our

16 fine clients, which include both the Montague

17 Hop Growers and the Capulet Breweries. 

18 Maybe you realize it, but if not

19 here's the verbal two-by-four. Hops, like

20 flavors, colors and soon hopefully yeast is

21 not about listing or delisting, it's about

22 commercial availability. Monday we learned
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1 that 99 percent of hops are contracted, and

2 although the Montagues are sitting on 80,000-

3 plus pounds of inventory, the Capulets seem to

4 be not only avoiding forward contracting for

5 those hops but by specing their way around

6 losing what's available. Shame on them and

7 shame on us, the certifiers, for not settling

8 this feud. Mr. Murray, dude, we blew it. Not

9 so good. That is all.

10 Or is it? Transcripts will show

11 that somewhere in these rants I address the

12 NOP, and that would be now. Please prioritize

13 commercial availability guidance based on the

14 2007 and 2008 NOSB recommendations, including

15 language on proactive measures which would

16 include forward contracting. Doing so will

17 allow your agents, us the certifiers, to

18 universally apply considerably more pressure

19 on farmers and handlers to increase the use of

20 organic seeds and ingredients. Without such

21 guidance, we will continue to struggle with

22 hop-like commercial availability abuse with
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1 other ingredients such as flavors, colors,

2 corn starch and very soon, hopefully yes,

3 yeast.

4 In closing for the record, I love

5 babies. And I love beer -- and I love beer. 

6 This is critically important. You're on the

7 right track, good work and Godspeed.

8 MR. GIACOMINI: Okay. Now --

9 MR. PIERCE: Questions?

10 MR. GIACOMINI: Questions. 

11 Questions. I think you've just eliminated the

12 possibility of any questions.

13 MR. PIERCE: Well, we'll see if

14 this is in tune, but I'm not really thinking

15 it's important. My G-string seems a little

16 tight, but I'll get over it.

17 MR. PIERCE: (Sings a song.)

18 MR. GIACOMINI: Don't know why you

19 didn't include that in the regular part of

20 your comments. That's absolutely precious.

21 Kevin, you have a question about -

22 -
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1 MR. ENGELBERT: I'm just so

2 pleased that I'll have a memory for my last

3 memory from my last meeting that I'll never

4 forget.

5 MR. GIACOMINI: Okay. You offered

6 Cameron to go ahead of you, and now I

7 understand why.

8 MR. PIERCE: That's a tough act to

9 follow. I should have brought the bagpipes.

10 MR. GIACOMINI: Cameron, Lisa and

11 Michael Brandt.

12 MR. WILSON: So I'm going to talk

13 a little bit about the EPA list for inerts. 

14 Recommendation by the NOSB was to extend the

15 list for five more years. Neudorff supports

16 the relisting of EPA's list 4(a) and (b)

17 inerts for five more years. We disagree that

18 -- with the minority opinion that three years

19 is sufficient time period for review of the

20 list four inerts.

21 Neudorff is a 156-year-old

22 company. Despite our small size, Neudorff is
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1 recognized worldwide as a leader in developing

2 pesticides for organic production. We rely on

3 our decades of experience and knowledge rather

4 than large research budgets that would enable

5 faster formulation and reformulation work. 

6 Removal of the some of the current inerts

7 allowed in organic inputs in five years would

8 put smaller companies, such as ourselves, at

9 a disadvantage. Our research group is less

10 than ten people. 

11 We have spent a considerable

12 amount of time and money developing,

13 patenting, registering and marketing our

14 intellectual property based on the current

15 allowable inerts. Losing these inerts without

16 enough lead time would jeopardize the future

17 of our business in the U.S. It would also

18 result in less inputs for organic growers

19 resulting in potentially less yields,

20 resulting in higher prices to the end user. 

21 This seems to contradict the spirit of the

22 organic movement.
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1 We understand the need for the

2 NOSB to continue to revise and improve the

3 list of materials allowed for use in organic

4 agriculture. We support the continued use of

5 the EPA's list 4(a) -- 4(a) and 4)b) inerts to

6 allow a thorough review of chemistry and

7 toxicology in these inerts. Developing stable

8 efficacious products specifically for the

9 organic sector and formulation changes

10 resulting in regulatory changes takes years to

11 effect. We urge the NOSB to provide enough

12 lead time when the inerts list does change.

13 One of the features of natural

14 active ingredients is that they typically

15 break down readily. With organic pesticide

16 formulations, the inert ingredients are

17 especially important. They need to stabilize

18 the active ingredients effectively in the end19 use product. For this reason, formulation and

20 reformulation of pesticides that continue to

21 have natural ingredients is difficult and time

22 consuming. Once a formula is determined to be
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1 efficacious, stability must be confirmed.

2 The EPA, for example, requires one

3 year storage stability studies. The EPA and

4 Cal EPA must review and approve new formulas. 

5 OMRI must approve new formulas. For this

6 entire process, R&D companies such as

7 Neudorff, require a minimum of four to five

8 years notice of any changes to the list of

9 allowed inerts to prevent this disruption to

10 growers.

11 Neudorff supports the NOSB's

12 recommendation of relisting the current EPA's

13 list 4(a) and (b) inerts for five more years. 

14 Anything else will result in fewer inputs

15 available to the organic farmers, putting

16 their business at a disadvantage. 

17 And I just wanted to ask one

18 question. Does the NOSB recommendation

19 include list four inerts that were added after

20 August 2004? Because there were -- there were

21 inerts that were petitioned, that were added

22 to list 4 and then they were actually
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1 disallowed.

2 MR. McEVOY: Well, I can't speak

3 for the NOSB recommendation, but I can speak

4 for the list 4 materials that were added after

5 September of -- what was that -- '04 -- August

6 2004 that are not included in the list of

7 approved substances.

8 MR. WILSON: Okay. Just maybe

9 this is a silly question, but what was the

10 logic? Is that they picked the August 2004

11 list, they took some ingredients off, they put

12 the -- other ones were petitioned after that

13 to go on, and then those were disallowed. I'm

14 just trying to understand the logic behind

15 that. We got caught up in it a little bit,

16 and we were able to clean it up. But it was

17 a bit of a tricky situation.

18 MS. BROWN-ROSEN: Emily Brown19 Rosen.

20 It had to do with EPA's

21 procedures. They -- and they were reassessing

22 the tolerance for all those inerts. And
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1 initially they started handing out letters and

2 claiming they were going to update list 4, so

3 various certifiers and OMRI accepted them. 

4 But then they finalized their process and

5 announced they were not going to update list

6 4, and it kind of left those inerts in limbo. 

7 So NOP issued a new policy clarifying how

8 we're going to use the obsolete list and we're

9 really going to have to rely on the old -- you

10 know, the actual published list. So it's a

11 problem. That's why we need to go forward and

12 deal with this further.

13 MR. WILSON: Okay, thank you.

14 MR. GIACOMINI: Is that --

15 MR. WILSON: Well, that was my

16 question.

17 MR. GIACOMINI: Do you have any

18 more -- anything else?

19 MR. WILSON: I was going to ask

20 you that.

21 MR. GIACOMINI: Okay. Any

22 questions or comments?
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1 (No response.)

2 MR. GIACOMINI: Okay, thank you.

3 MR. WILSON: Thank you very much.

4 MR. GIACOMINI: Lisa, Michael

5 Brandt and Karreman. Go ahead.

6 MS. BUNIN: Good afternoon. My

7 name is Lisa Bunin and I'm the organic policy

8 coordinator at the Center for Food Safety. 

9 CFS is a non-profit member organization that

10 works to protect human health and the

11 environment by curbing the proliferation of

12 harmful food production technologies and by

13 promoting organic and other forms of

14 sustainable agriculture.

15 Today I'm also representing CFS's

16 sister organization, the International Center

17 for Technology Assessment, a non-profit

18 organization dedicated to providing the public

19 with full assessments and analysis of the

20 impacts of food-related technologies on

21 society. 

22 My remarks today will focus on
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1 nanotechnology, but first I want to briefly

2 comment on corn steep liquor in light of the

3 Board's discussion yesterday. Although we

4 believe that corn steep liquor meets the

5 definition of synthetic because it is

6 manufactured by a chemical process, we

7 strongly urge the Board to postpone your

8 decision. We urge more investigation and

9 research due to the confusion surrounding the

10 fundamental chemistry. What's at stake is far

11 reaching and therefore the decision should not

12 be made without clear Board agreement and

13 consensus on such a core definition.

14 Okay. On to nano. CFS and ICTA

15 are pleased to see the recognition by the

16 materials committee that there is overwhelming

17 agreement within the organic industry to

18 prohibit nano technology in organic production

19 and processing at this time. We

20 wholeheartedly support the prohibition of nano

21 technology and nano materials in organic, and

22 so do 8,320 of our individual supporters who
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1 wrote to this NOSB urging it to take immediate

2 action to protect the integrity of organic by

3 keeping nano out. 

4 CFS and ICTA support the materials

5 committee's proposed definition of engineered

6 materials and its' acknowledgment that the

7 unique functions and properties of materials

8 at the nano scale could harm animals, humans

9 and the environment. We also support

10 excluding traditional food processing

11 technologies and naturally-occurring nano

12 particles which clearly differ from those that

13 are deliberately manufactured. We agree with

14 the committee's conclusion that deliberately

15 engineered materials are synthetic. It does

16 not matter whether the bulk -- original bulk

17 material comes from a natural source because

18 once materials are manipulated at the

19 nanoscale, the chemical and physical changes

20 that result render it a non-agricultural

21 synthetic material.

22 We do not support allowing
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1 individual nano materials to be petitioned for

2 placement on the National List on a case-by3 case basis. Nanotechnology, like genetic

4 engineering, irradiation and sewage sludge is

5 antithetical to the letter and intent of OFPA

6 which limits the use of synthetics in the

7 production and handling of organic products. 

8 Synthetics are intended to be the exception

9 rather than the rule. 

10 To reinforce this intent, OFPA and

11 the organic rules state that, if the substance

12 is allowed on the National List, it must not

13 be harmful to human health or the environment. 

14 Nanomaterials cannot meet the standard due to

15 the many documented risks of harm that we have

16 presented in our current and previous written

17 testimony to the Board. We strongly urge the

18 Board at this meeting to recommend a complete

19 prohibition of nanotechnology in organic

20 production and handling without any exceptions

21 or caveats, but adding it to Section 205.105

22 of the Rule in a new letter (h).
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1 Packaging is a predominant product

2 category where food-related nanotechnologies

3 are being deployed to extend a product's shelf

4 life, particularly through the use of anti5 microbials like nanosilver. This type of nano

6 packaging is designed as a delivery system

7 whereby the nano particles are embedded in the

8 packaging act as a preservative, anti9 microbial or anti-fungal, among other things. 

10 As such, we believe that the authority already

11 exists within the organic rule to prohibit

12 nano in packaging in Section 205.272(b)(1). 

13 The rule states that packaging materials and

14 starched containers are bins that contain a

15 synthetic fungicide, preservative or fumigant

16 are prohibited for use in the handling of any

17 organically-produced agriculture product and

18 ingredient. 

19 CFS and ICTA disagrees with the

20 recommendation to delay making a permanent

21 decision to prohibit nano in organic and

22 instead hold a symposium. There is sufficient
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1 evidence today about the environmental and

2 health risks of nano to conclude that it

3 contravenes the principles of organic and that

4 it needs to be prohibited. Failure to take

5 immediate action in the face of growing and

6 unregulated industry threatens to undermine

7 both the integrity of organic products, the

8 consumer confidence in the USDA seal.

9 In conclusion, when it comes to

10 nano in organic, we believe that a firewall

11 should be built without a door.

12 Thank you.

13 MR. GIACOMINI: Questions? Tracy?

14 MS. MIEDEMA: Lisa, I'm going to

15 ask the program a question based on what you

16 just said. We know that we created a problem

17 for you all with cloning and how we took a

18 very strong stand that was very hard to take

19 action on. At least that's our -- what we've

20 kind of gathered. What is or what would be

21 the most actionable stance that the NOSB could

22 take to prohibit nano?
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1 MR. McEVOY: Well the cloning

2 recommendation that you made, we issued a

3 policy statement on that that cloning is not

4 compatible with organic production. So the

5 part that we couldn't take on was the part of

6 the recommendation to prohibit the progeny of

7 cloned animals. It's also prohibited because

8 that's not specifically outlined in the

9 current regulations. So I wouldn't

10 necessarily say you caused a problem. We took

11 your recommendation and did the best we could

12 with what we could through a policy memo. And

13 then, in terms of additional work on the

14 progeny piece, that would have to be done

15 through rule making.

16 In terms of your nanotechnology

17 recommendation, when there's a final

18 recommendation -- we've worked with you in

19 terms of the development of the

20 recommendation, but when you have a final

21 recommendation, we'll look at that and we'll

22 see how we can move towards implementing the
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1 NOSB's recommendation. So it's hard to say

2 specifically what's the best recommendation

3 for us to have to move forward. It sounds

4 like the intent is that you want to prohibit

5 nanotechnology and we'll take that and see

6 what's the best way to move forward on that.

7 MR. GIACOMINI: Thank you. Yes,

8 we've certainly heard over the past year, as

9 we said before, with all the caveats of the

10 confusion around it, that no one wants nano in

11 organic, including at one point in time the

12 people, the 1,655 people who responded to my

13 personal email being posted on a web site to

14 respond to whether they wanted nano in

15 organic. So we -- I know I certainly heard it

16 in those 20 hours when I was -- before I was

17 able to get that web site changed. So -- 

18 And next up is Michael Brandt,

19 Hugh Karreman and Wendy Buckwalter.

20 MR. BRANDT: Good afternoon. My

21 name's Mike Brandt. My connection to the

22 organic industry is primarily that of a
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1 consumer. I haven't been with you for what is

2 now almost three days of hearing so I don't

3 know what may have transpired. I'm not

4 wishing to waste anyone's time. The first

5 thing I need to ask is, is the topic of

6 henhouse porches, as relates to outdoor access

7 for laying hens, is this still a relevant

8 topic for addressing the board? Great.

9 I live in Arena, Wisconsin in

10 what's known geologically as the driftless

11 area. Our region is characterized by wooded

12 hills that are scoured with deep valleys,

13 hollows and coolies, therefore mostly

14 unsuitable for large-scale agriculture. One

15 could always raise cattle there and grow

16 enough feed for them, so for a long time the

17 driftless area was dominated by family-run

18 dairy farms. 

19 During the past 50 years,

20 industrialization of the dairy industry has

21 made it increasingly difficult for small

22 operators to survive on conventional product. 
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1 That a viable, even growing dairy business

2 remains in the driftless area can be credited

3 to one thing more than any other, it's the

4 organic brand. The organic brand represents

5 the margins needed to support small scale

6 family farms. The evidence of this is

7 everywhere throughout the driftless portions

8 of Wisconsin, Minnesota, Iowa and Illinois and

9 has come to encompass not only dairy products

10 but meat, wool, fruits, vegetables, poultry

11 and, yes, eggs. Hundreds if not thousands of

12 producers in this region are in business, can

13 only be in business, in fact, because of what

14 the organic brand represents to consumers.

15 For over 35 years, my wife and I

16 have gone out of our way to find and purchase

17 organic product. We've done so for a variety

18 of reasons, including nutrition, environmental

19 impact, the humane treatment of livestock. 

20 It's only been within the last decade or so

21 that we've come to appreciate the ways in

22 which the organic brand serves to support the
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1 health of our local economy and the farm

2 families who contribute to it.

3 We buy our eggs and chickens from

4 a neighbor who's certified organic. They and

5 their young children also milk cows. When I

6 drive past their farm, I can see the chickens

7 in the field, I know they're getting exercise,

8 I know they're getting fresh air, I know

9 they're supplementing their feed with things

10 that they're scratching out of the ground. 

11 What everyone in this room knows is that the

12 scene I just described is exactly what the

13 consumer imagines when he or she looks at the

14 word organic.

15 The image of thousands of chickens

16 crammed together, whether it be in an enclosed

17 warehouse or on a concrete floored porch, that

18 bursts the bubble. That is not what people

19 think they're paying for. And it serves in

20 the mind of the consumer to degrade the

21 organic brand down to just another phony22 baloney gimmick. And that will not enable
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1 families like my neighbors to support

2 themselves on a small farm.

3 I'm here today both as a consumer

4 and as a concerned member of an agricultural

5 community to remind members of the NOSB that

6 the value of the organic brand has everything

7 to do with matching the expectations of the

8 consumer with the realities on the farm. In

9 that context, eggs that come from a chicken

10 that never sees the light of day are not

11 organic eggs, and people will not knowingly

12 pay an organic premium for them. 

13 I therefore appeal to you to

14 recognize hen house porches for the sham that

15 they are and submit to the National Organic

16 Program new rules excluding porches as a means

17 of satisfying outdoor access requirements. 

18 Large producers who do not choose to comply

19 with reasonable organic standards have other

20 avenues for differentiating their product and

21 increasing their margins. To allow them to do

22 so by degrading the organic brand is a
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1 disservice to the consumer, like myself, as

2 well as to my neighbors and the larger

3 community of driftless area organic farmers. 

4 Thanks.

5 MR. GIACOMINI: Questions and

6 comments?

7 (No response.)

8 MR. GIACOMINI: Thank you.

9 Hugh Karreman, Wendy Buckwalter

10 and Jonathan Woolick -- Jonathan.

11 MR. KARREMAN: Good afternoon,

12 folks, glad to be back up here. It feels nice

13 to be near you but not stuck in those seats. 

14 I'm Hugh Karreman, former Board member, near

15 my livestock folks here, and just

16 congratulations to the graduating class. Well

17 done Kevin and Jeff and whoever all else. I

18 still get a little nervous up here as I used

19 to before I was on the Board.

20 So anyway, I just wanted -- I have

21 a few thoughts here, I don't know how long it

22 will take. Less than five minutes though,
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1 okay.

2 So last night I gave a talk at the

3 veterinary school here in Wisconsin, here in

4 Madison. It's about 40 students, to the

5 Integrative Medicine Club which about three6 quarters of them were dairy-oriented. Well,

7 we're in Wisconsin, so that makes sense. And

8 I invited them to come here if they had any

9 spare time, to watch democracy in action,

10 which this totally is and it's wonderful. 

11 They had a lot of questions throughout my talk

12 -- of course, I'm talking about organic dairy

13 cows, having been immersed in this 15, 20

14 years now. And they had questions which were

15 pretty difficult to answer and -- such as, why

16 is Ivermectin allowed in dairy stock but not

17 beef, or why does the EU and Canada allow

18 antibiotics and the U.S. doesn't? Those kind

19 of questions.

20 And my answer to them, generally

21 to any group, is that the organic industry,

22 just like the other gentleman said, is very
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1 consumer driven and you have to listen to the

2 consumers. And because they're paying the

3 premiums to the farmers, okay? So when you're

4 talking about, I don't know, corn steep

5 liquor, and you guys are getting into what I

6 would call the realm of the absurd, think

7 about what the organic consumer would think

8 about just the big picture of what you're

9 talking about.

10 So I mean, on that corn steep

11 liquor, the thing I would say, I would sit on

12 the that it's a non-synthetic type thing, or

13 hold your vote, whatever, okay? Don't make

14 the song come true that Jim so nicely sang.

15 Anyhow, on some other things,

16 239(c)(2), I agree with your recommendation,

17 I also agree with Harriet Behar's addition

18 that there needs to be a note that materials

19 need to be on 603 and/or in compliance with

20 organic standards, otherwise some non-listed

21 items might be used as preventives. Okay, so

22 you just have to make that extra statement
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1 that it's got to be in compliance with

2 organics in the list.

3 In animal welfare, I agree with

4 the outcome-oriented stance, but always keep

5 in mind that whatever resembles a factory-type

6 farm, where a completely-enclosed facility

7 will create at some point a black eye for the

8 industry. And I agree with the person from,

9 I think it was Coleman, who said that the

10 organic label should say all so they don't

11 have three or four different labels that add

12 it's humanely raised and this and that. 

13 Don't forget that the organic

14 system, we use no sprays and that's why I

15 really, really love organics. There's no

16 herbicides, pesticides, fungicides,

17 insecticides sprayed into the environment. 

18 And those humane stickers can't say that, or

19 they don't, as far as I know. The organic

20 sticker does. So the organic sticker also

21 should have that humane aspect in it, just

22 keep it in mind for the consumer so it's not
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1 so confusing for them, so they can have it all

2 in that one seal.

3 Natural behavior, definitely

4 critical to animal welfare and is a function

5 of being in their natural environment, not

6 sawdust on wood flooring as a proxy for real

7 outside living. Sawdust on wood flooring or

8 concrete is pseudo-natural behavior -- that

9 allows for pseudo-natural behavior. 

10 Poultry houses. Has anyone asked

11 if the land that they sit on is certified

12 organic? I know one place in Pennsylvania

13 where it is not. It's a certified organic

14 poultry house, the land on it, under it and

15 everything is not certified organic. That's

16 a big question.

17 Let's see. Methionine. I think

18 there needs to be a regulatory change to allow

19 poultry to express their natural behavior by

20 being omnivores and not herbivores. That's a

21 forced condition. And it's a shame that

22 methionine, as a residual, the cheapest way to
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1 feed totally confined conventional poultry. 

2 Origin of livestock, poultry should be also

3 made to be organic from whatever the

4 equivalent is to the last sort of gestation

5 and not just one day of live when they're

6 given a variety of things on that first day. 

7 Mammals have -- mammal-type things have to be

8 -- last through gestation, so should poultry. 

9 Vaccines, there's a lot of genetic

10 -- not a lot, there's some genetically11 engineered vaccines, there's 24 in existence

12 with about 11 labeled for poultry. Are they

13 being used? 

14 Ending thoughts, I would just say

15 is that, always keep in mind what the organic

16 consumer would think if they were standing

17 wherever you are in the organic industry in

18 real time outside on a farm, what they would

19 think if they were standing there right then

20 and there. Can you explain what is happening,

21 would they accept it? Because they're the

22 ones paying the premiums. So anyway, thanks.
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1 MR. GIACOMINI: Questions and

2 comments?

3 (No response.)

4 MR. GIACOMINI: Okay. Oh, wait, I

5 do, Hugh. Back up, please. Could you give us

6 -- we've got a number of other documents that

7 we're working on, hopefully what we need to do

8 on 238(c)(2). Could you give us some specific

9 -- you can just write it down on a piece of

10 paper and hand it to us later for us to

11 consider tonight, the specific changes you'd

12 like to see us consider on that?

13 MR. KARREMAN: Sure.

14 MR. GIACOMINI: Also on -- an on

15 the poultry, the issue of the one-day-old

16 chicks being organic is something that we've

17 grappled with forever. Unfortunately that's

18 the way OFPA wrote it. And unless, you know -

19 - so as the former Deputy Administrator of the

20 program -- no, I guess you would -- anyway,

21 Barbara, whatever her highest title was,

22 Congress trumps.
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1 MR. KARREMAN: Oh, I would say,

2 though, that I believe that is in OFPA, the

3 basis for things, and the regulations can be

4 tighter. I was just -- that was more to the

5 NOP as far as the origin of livestock --

6 MR. GIACOMINI: Yes.

7 MR. KARREMAN: -- to make it

8 consistent for livestock. If it can be done.

9 MR. GIACOMINI: Comments,

10 questions?

11 (No response.)

12 MR. GIACOMINI: Okay. Wendy,

13 Jonathan and Gary Zimmer.

14 MS. BUCKWALTER: Good afternoon. 

15 My name is Wendy Buckwalter. First I want to

16 say thank you for the opportunity to

17 participate in this process.

18 In a few minutes you're going to

19 hear from my husband Gregg who is an egg

20 processor. So while I do have ties to the egg

21 industry through him, I'm not directly

22 involved in the industry at all. So my
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1 comments today are my own and are not

2 affiliated with any specific company.

3 I should be considered more of an

4 informed consumer. I buy organic and I

5 believe in organic, especially when it comes

6 to the topic of animal welfare. And I really

7 appreciate the discussion on outdoor access

8 that is going on, and I think this concept

9 needs to be strengthened and clarified to

10 maintain the integrity of the organic egg

11 industry.

12 I support the idea of

13 strengthening and clarifying the outdoor

14 access requirement for several reasons. 

15 First, the standards state that outdoor access

16 must be provided. There are several large

17 organic producers that have small, sometimes

18 even enclosed porches allowing only a small

19 percentage of the birds outside, and the

20 others have to remain inside. And I know that

21 this was not the intent of the standard and

22 I'm certain that any reasonable farmer would
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1 understand that this is not the intent of the

2 standard. Yet several organic farms are doing

3 this, using the small porches or deck as their

4 outdoor access. 

5 Also, providing outdoor access is

6 intended to allow for the chickens to engage

7 in their natural behaviors, pecking,

8 scratching, foraging, and a porch or deck

9 obviously would not have soil or grass and

10 would not provide for these behaviors. And

11 again, anyone who's reasonably familiar with

12 the philosophy behind the organic production

13 should understand what the intent is, yet

14 several farms seem to favor the idea of, quote

15 unquote, meeting the standards without true

16 regard for the animal welfare.

17 Another big reason why I support

18 the idea of strengthening the outdoor access

19 requirement is that, as a consumer, I and

20 other consumers, I'm sure, too, want to know

21 that buying organic means something. I

22 personally care a lot about where my food
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1 comes from. I care about the animals that are

2 involved in producing my food. And if organic

3 standards begin to slack, there are people who

4 would probably switch to maybe cage-free which

5 would be less expensive but still be perceived

6 as having higher animal welfare standards than

7 conventional eggs, or people like me. I'm

8 vegetarian, I eat very few animal products as

9 it is. I would simply stop eating eggs if I

10 felt that they weren't produced with a high

11 standard of animal welfare. So it would just

12 be easy for me, and probably there are others

13 that are kind of on that edge, not eating many

14 animal products.

15 I can see the organic industry

16 getting bigger, and I think that's truly a

17 mixed blessing. While it does mean that

18 organic products are easier for us consumers

19 to get, it can also mean that organic farms

20 being to look like factory farms and that's a

21 slippery slope. My opinion on factory farms

22 is that humans have taken an idea that is
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1 basically good, that idea being that farming

2 is a symbiotic relationship between humans and

3 animals, and they've distorted this idea so

4 drastically that it doesn't even resemble the

5 simple premise that it was based on anymore. 

6 And I would hate to see organic farming go

7 down that road.

8 In conclusion, I believe that the

9 organic program has a very important place in

10 this country, and I encourage you to keep

11 organic standards high and to maintain the

12 trust that consumers have in organic foods. 

13 Thank you.

14 MR. GIACOMINI: Thank you. Any

15 questions or comments?

16 (No response.)

17 MR. GIACOMINI: Okay. Message

18 from Lisa that Jonathan is not here. Go to

19 Gary, Patty and then David. Good to see you,

20 Gary. This will be interesting, I've never

21 seen you under a clock before. So it will

22 either be five minutes worth of words in two
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1 minutes or eight minutes worth of words in

2 five. So we'll see how it goes.

3 MR. ZIMMER: My reputation

4 precedes me, I can tell you that. Yes, I'm

5 Gary Zimmer, and our farm is 40 miles west of

6 here, we're an organic dairy farm, and

7 Midwestern Bio, my company, we consult on

8 about 1,000 organic farms, of which about 900

9 of them are dairy, or 90 percent of that.

10 So anyway, my point is this, and I

11 listened to the speeches and all the comments

12 made, and I'm reading a book right now called

13 The Need To Stick. So my ideas have got to

14 stick. Of all the comments you've heard, how

15 do I make them stick and what do I want to

16 make stick? I'm not going to sing a song,

17 Jim. And so that's how you make things stick.

18 And so my point is on animal

19 welfare it this: I do think -- and I agree

20 with Dr. Karreman, that the consumer's the one

21 really we deal with. I'm having troubles

22 with, and the farmers are having troubles with
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1 the fact that we need more animal welfare but

2 we don't need more paperwork and regulations. 

3 You can drive into my yard and take a look

4 around, and you ought to be able to recognize

5 that I'm within compliance.

6 Now we had an organic inspection

7 this year, and I happened to be gone which was

8 fortunate for somebody -- not somebody else. 

9 Anyway, we were accused of only having 24

10 percent dry matter intake coming from our

11 pastures. Now we were offended because we're

12 about 55 percent. Now who will get the math

13 and how? So just like someone's going to come

14 and score my cows, you're going to score

15 wings, they're going to count lesions one day

16 a year? I mean, with NEB, that was really

17 money and I had to lock them in and they

18 looked dirty. Is that fair?

19 And so now I got my paperwork in

20 here and so I want to say that, in this whole

21 thing, that I do like the higher standards on

22 animal welfare, but how to manipulate and
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1 monitor this? You ought to do a survey on how

2 many farms the night before inspection fill

3 out all that paperwork. Do a carbon

4 measurement of the age of the ink on the

5 paperwork when you do the organic takeaway. 

6 I know too many of them. I'm one, myself.

7 So my point is this: If you're

8 going to -- and we're going to have those

9 higher standards, we've got to get down to

10 common sense. And you can drive in my yard,

11 you ought to be able to recognize it by

12 degrees. And so I'm asking and saying, if

13 you're going to have higher rules, bring me

14 someone skilled that can interpret and

15 understand a dairy cow. Don't send me someone

16 who doesn't even know the front from the back

17 of a dairy cow. How many people know what 30

18 percent dry matter intake is? How many know

19 how much my cows eat? 

20 And so see, I'm saying that if you

21 get that match in line to where this -- you

22 know, the professionalism that comes onto my
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1 farm. And so I know the DPO parts, but how

2 we're going to do that paperwork, how we're

3 going to do it, I think it needs to be more

4 skilled, trained inspectors onto my farm.

5 In the old days, back in the '90s,

6 I was the guy that was against the National

7 Organic Program, because I figured if the

8 government got in it, it was bound to screw it

9 up. Now, I've changed my mind, kind of,

10 because I was certified with three agencies in

11 the late '90s. Because if that one didn't do

12 it right then I took that paperwork and

13 presented it. I'm afraid I'm getting back to

14 that. I'm going to go to agencies that got

15 the guys that know the most about dairy to

16 inspect my farm. That's all I'm asking is

17 that, make a higher standard, but then hire

18 someone that's got dairy skills if they're

19 going to do me an animal welfare thing on my

20 farm. Have them come and help me and work

21 with me, and I'll gladly share my farm. But

22 one day a year isn't going to cut it.
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1 Does it stick? I got my point

2 across, thank you.

3 MR. GIACOMINI: How are we doing

4 on time there, Tina?

5 MS. ELLOR: One forty-seven.

6 MR. ZIMMER: I got it in, huh?

7 MR. GIACOMINI: Got it in. The

8 five minutes in three. There we go. I was

9 wondering which was --

10 MR. ZIMMER: Three minute running

11 my mouth.

12 MR. GIACOMINI: Questions or

13 comments for him? Kevin.

14 MR. ENGELBERT: So you think,

15 Gary, that you want more than one inspection

16 a year, is that right?

17 

18 (Laughter.)

19 MR. ZIMMER: I would actually --

20 actually now they come in the summertime for

21 the grazing, either more or a communication

22 that's different or a system that I'm more
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1 involved with someone who's on my farm. I

2 don't know how to do the more. Either you're

3 going to have to entrust my integrity or we're

4 going to -- so where do we go next? I don't

5 like the one-day thing there. Maybe a

6 connection with my veterinarian. I don't care

7 what that connection is, if they're going to

8 force a higher standard then we're going to

9 have to have a better way of figuring out how

10 people meet it.

11 MR. ENGELBERT: We talked about

12 that in the committee, but we know that we

13 can't put veterinarians in that kind of

14 position. I understand exactly where you're

15 coming from, but we're trying to meet consumer

16 expectations, as you've heard, and maybe it's

17 just simply a case of we're going to have more

18 training or better training, more training,

19 and maybe even some type of exam for a

20 livestock inspector to pass to become a

21 livestock inspector.

22 MR. ZIMMER: Especially when
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1 you're bringing in health, welfare and

2 evaluating what sickness is. When we write

3 down how many sick animals we have on the

4 farm, we write down very few because we don't

5 have any drugs to give them. We have lost one

6 this -- a while ago to pneumonia that had to

7 be treated with an antibiotic, but otherwise

8 we see them looking rough and we give them

9 extra vitamins and minerals. Is that a sick

10 animal we treated? So we don't record that. 

11 So I agree, maybe a higher standard of

12 training for those people that would do that,

13 in some means. And make sure that one day a

14 year doesn't judge me.

15 MR. GIACOMINI: Thank you. Patty

16 Lovera, Dave Will and Gregg Buckwalter.

17 MS. LOVERA: Okay?

18 MR. GIACOMINI: Yes.

19 MS. LOVERA: My name is Patty

20 Lovera. I work for a group called Food and

21 Water Watch. We're a non-profit consumer

22 advocacy group. I work in our Washington,
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1 D.C. office. We're also a member of the

2 National Organic Coalition, so we're also in

3 support of the comments that have already been

4 submitted by NOC, which I probably won't have

5 time to get to all of those issues.

6 So we've already submitted a

7 formal comment on nano technology and we also

8 had folks who are our members and supporters

9 weigh in as well. They were combining their

10 concern on nano technology and hops at the

11 same time, which is probably a first for us to

12 be able to combine those two topics. But the

13 short version of the easier one first. You

14 know, our members and consumers are very

15 concerned about ingredients in organic

16 processed food and they were very anxious to

17 hear about when hops would come off that list

18 of commercially unavailable things, and so I

19 think they will be encouraged that you're

20 planning to do that faster.

21 On the more complicated topic of

22 nano technology, I've been here before, lots
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1 of other folks have been here before, we've

2 all been doing this for a while. And the

3 short version of this is we think it's time

4 for the Board to say something definitive

5 about nano technology to get the ball rolling. 

6 We understand there's a lot to figure out, we

7 understand that it's complicated, and we have

8 to figure out a way to enforce it. But it's

9 time to take that step and to put that signal

10 out there. And we think that that actually

11 helps to start the process and sends the

12 signal to the market that, if you are in the

13 organic business, whether it's -- at whatever

14 stage, or you're making materials that you

15 want organic folks to start using, that

16 there's a clear signal that it's not allowed. 

17 The first step of that comes with a vote from

18 the Board.

19 You know, we saw a lot in the

20 recommendation that we agreed with. Lisa from

21 Center for Food Safety outlined some of these,

22 the definition and the size, the -- specifying
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1 that just because something is allowed in its

2 bulk form doesn't automatically mean it should

3 in its nano form. We agree with that and

4 appreciate you spelling that out in the

5 recommendation. 

6 We would suggest a little bit of a

7 clarification in the definition. We

8 understand, and we're not quibbling with the

9 need to talk about traditional food processes

10 and homogenization in milling. We get that. 

11 We're not asking to reopen that can of worms. 

12 But we would like just a little bit of

13 clarification to talk about the way we're

14 using those processes now so that ten years

15 from now someone doesn't find a way to do

16 extreme homogenization or call something

17 homogenization then we out what it really was

18 intentionally done to produce a nano scan

19 material. We have had this kind of slippage

20 in words in other parts of the food industry

21 when we fight about the word pasteurization

22 being used to describe things that are nowhere
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1 near what we think of as pasteurization. So

2 we would just like to put in there the way

3 we're using these traditional food

4 technologies now so we don't have some future

5 problem on our hands.

6 And so when it comes to dealing

7 with nano technology in the organic standards,

8 we think that they are synthetic, and we agree

9 with that assessment, and that does take you

10 down the road to, you know, food contact,

11 preservatives in packaging. All of that is

12 important. But given some of the current

13 challenges in dealing with synthetic materials

14 and given really the unregulated state of nano

15 technology in the rest of the economy, in the

16 food supply, we think that synthetic

17 classification isn't enough. And so we very

18 strongly urge the Board to go a step further

19 and to make it prohibited, to get it up into

20 Section 105.

21 We've had lots of analogies today,

22 and then the one, you know, for nano about
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1 walls and doors, whatever. We think that the

2 door option, no matter how you lock it, does

3 present a risk to the credibility of the

4 organic label to consumers. We think it's

5 time, at this stage, just to have a wall and

6 make it very, very clear that we don't want it

7 getting in there. And we feel the way to do

8 that is to put it up there in 105 as

9 prohibited.

10 You've -- a lot of your attention

11 and time and the burden that you have to deal

12 with being on this Board is dealing with this

13 synthetics process and adding nano materials

14 to that mix doesn't seem like a good idea to

15 us. You have enough to do without trying to,

16 in the future, deal with specific, you know,

17 case by case issues of nano versions of the

18 materials you're already struggling to make

19 decisions about. And so there's not -- and

20 there's not good technical information out

21 there to help you do that. 

22 Some researchers have estimated
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1 that we're 30 years behind in evaluating the

2 potential health and safety impacts of nano

3 materials, and it could cost billions of

4 dollars to do so. So we think the best way to

5 deal with that at this point is to just keep

6 them out.

7 So I'll just stop there. I think

8 you've heard this from us before, and lots of

9 other folks before. We just think, you know,

10 given the really unregulated state of these

11 materials, no one is looking for them. You

12 know, the FDA's not keeping up, the EPA's not

13 keeping up, the best way for organic to try to

14 deal with this is to just keep them out. And

15 so we'll put in the organic principles of, you

16 know, trying to prevent environmental harm and

17 to think about human health, whether it's

18 consumer health or worker health in the

19 facilities that might have to deal with these

20 things. And then acting in the interest of

21 precaution, we think that that all leads us

22 down the path of having to have a prohibition. 
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1 So I'll stop there.

2 MR. GIACOMINI: Questions? Jay?

3 MR. FELDMAN: Do you think -- is

4 there a simple way to characterize the issue

5 around homogenization, about what we're doing

6 now in terms of current techniques that would

7 be -- would we view, and we have defined in

8 the document as acceptable processes that

9 result in incidental nano particle size, is

10 there -- do you think you have a suggestion

11 for language for a simple way to characterize

12 future abuses in those categories?

13 MS. LOVERA: Two things that we

14 thought of, which I think we included in the

15 comment we submitted a few weeks ago, was to

16 talk about saying, that are in use now, you

17 know, setting a point how things are being

18 used now. And also another idea for

19 homogenization might be to talk about milk,

20 because we're hearing about homogenization for

21 rice, you know, to make a different form of

22 rice products that could be used in
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1 ingredients. And maybe spelling out the way

2 that they're being used now, the materials

3 that are being used now, is one place to start

4 thinking about it.

5 MR. GIACOMINI: Yes, question. In

6 the final analysis I'm a little confused about

7 what you recommend for us to do with this

8 document. I think two points, first of all. 

9 I think the rewrite in the document to make a

10 completely 105 prohibition would not be

11 possible in the time we have before voting

12 tomorrow, and the public disclosure and all

13 those things. And also the risk that, with

14 everything needing to be two-thirds off this

15 Board with 14 people, that would need to be at

16 least ten people voting in favor of it. And

17 we're very concerned with the risk of that.

18 Considering those two things,

19 would it be your recommendation to proceed

20 with this document as I was kind of hearing

21 you say, take the first step, start down the

22 road, you know, start going there, or to take
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1 no action at all?

2 MS. LOVERA: I think we'd like to

3 see you give it a shot on prohibition, and see

4 how we do. I mean -- and then the other piece

5 that I should have mentioned and didn't was,

6 we don't see a need to wait for a symposium or

7 for further work to really outline what you're

8 going to do. I mean, we would like to see

9 some action now. We feel very strongly that -

10 - and other public comments might say this as

11 well, that if there is time to put that

12 prohibition in, that you should try it.

13 MR. GIACOMINI: But how do you

14 feel about, if this document is the best we

15 have right now, are we better proceeding with

16 it or doing nothing? Understanding it's a

17 step.

18 MS. LOVERA: Yes. I think we

19 would like to see you go for the prohibition. 

20 I think we need -- you know, we need to draw

21 that line. And if -- also, we'd like to see

22 who doesn't want to prohibit it. We'd like to
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1 see where the votes are and what the problem

2 is.

3 MR. GIACOMINI: Okay. Any further

4 questions, comments? Thank you. Oh, Jay.

5 MR. FELDMAN: Can you characterize

6 for us the -- what you think the organic

7 consumer is going to think? I mean, the

8 perception here in crafting a compromise is

9 that the consumer will see a relatively good

10 definition, hopefully we can add a sentence in

11 there that clarifies, that we're talking about

12 technology, non-nano technology homogenization

13 as it's used now. I think we need more -- we

14 need to clarify that language. But I'm

15 worried that, if the Board does nothing -- but

16 I'm interested in your perspective as whether

17 the organic consumer will perceive that as a

18 failure on the part of the organic community

19 to adequately -- or to move in the direction

20 of regulating this. So that's why I got

21 behind the compromise, although as I said

22 yesterday, I think a number of us on the Board
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1 would prefer the 105 approach.

2 So to clarify, you think the

3 definition is okay with that one

4 clarification, and that will send a message to

5 consumers that at least we got the definition

6 right?

7 MS. LOVERA: I think the consumers

8 would like to know that we started the process

9 to get it settled. But putting out a process

10 that has what we think is a risk of not having

11 a prohibition, you know, I mean, I can speak

12 for the consumers that communicate with us,

13 that come to us, that ask us questions, and

14 they are increasingly concerned about the

15 synthetics issue, about the ingredients issue. 

16 They couldn't articulate which lists, you

17 know, and the sunset process. But they're

18 increasingly concerned about those, it's not

19 allowed but except these are allowed. I mean,

20 there are people -- and that's why we're

21 getting a lot of response and concerns and

22 questions about, you know, when we have these
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1 processes for individual chemicals.

2 And so I think putting in that

3 track, for lack of a better word, reinforces

4 the fears that are starting to nibble at their

5 confidence in organics. So I think if there

6 is a chance, you know, to have more discussion

7 and to move quickly towards prohibition, I

8 think it's worth that chance for the

9 credibility and the confidence of consumers.

10 MR. GIACOMINI: Thank you. I

11 guess where, you know, this is a body of

12 stakeholders with different positions on this,

13 and I'd like to send a clear signal that we

14 are grappling with the definition, that we've

15 met the expectation of the consumer community

16 and hopefully, in terms of the definition, and

17 that we'll initiate a process to collect more

18 consumer input to, in effect, activate. I'm

19 sure we'll see a lot more comments than we'd

20 like to see, you know, in terms of processing. 

21 But I assume that this process will activate

22 consumer involvement.
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1 Anyway, I appreciate your comments

2 on this.

3 MR. GIACOMINI: Program?

4 MR. McEVOY: Yes, I want to go

5 back to what Tracy was asking about in terms

6 of this document, and the cloning in

7 particular. Because with cloning, we're

8 eventually going to go into rule making around

9 cloning, but currently, because of the NOSB

10 recommendation to consider cloning an excluded

11 method or prohibited practice, that the

12 program was able to put out a policy memo and

13 cloning became prohibited under the National

14 Organic Standards. So you can make an analogy

15 here to what you were -- what this proposal

16 is. Synthetic substances are prohibited,

17 unless they're specifically allowed. If the

18 Board states that nano technology substances

19 are synthetic, then therefore they are

20 prohibited, and we can issue a statement that

21 that, in fact, is -- that nano technology

22 substances are prohibited because they are
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1 synthetic by the Board determination.

2 To make a rule change to 105,

3 that's a much more complicated process. It's

4 going to take a much longer period of time. 

5 So if you want this to happen now, the best

6 way to make it happen now is to call nano

7 technology substances and therefore, at least

8 initially, the wall is put up.

9 MR. GIACOMINI: Katrina?

10 MS. HEINZE: And does this

11 document do that for you?

12 MR. McEVOY: It appears to, yes.

13 MR. GIACOMINI: Tracy?

14 MS. MIEDEMA: Should that be

15 paired with the more plant-a-flag type

16 statement, too, that leads to a firm

17 prohibition? Like should we try to shoot for

18 both in the same document or do this

19 sequentially?

20 MR. McEVOY: Well, I'm not sure

21 how you handled the cloning recommendation. 

22 Did you ask for both a rule change or did you
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1 just make a statement that cloning was not

2 compatible with organic production? If that

3 was what the recommendation was, what the

4 Program then did was issue a statement and

5 then put it into the work plan that eventually

6 it would require rule making. To get to the

7 full extent of what your recommendation

8 stated. 

9 So the same consideration could be

10 here. You just need to make a recommendation

11 of what you want and we figure out the best

12 way to implement that. If a rule change is

13 required, then we can go forward with a rule

14 change. If you want to make that explicit

15 that you want the rule to be changed, you can

16 do that as well.

17 MR. GIACOMINI: We proceeded with

18 the document that, number one, we were fairly

19 confident would pass, that we could provide to

20 you on issues that you could take action on as

21 soon as you could deal with the document. 

22 Whereas, within this definition of nano, of
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1 engineered nano particles, they are synthetic

2 under the rule, they are not allowed unless

3 listed, and the recognition that the nano farm

4 particles of anything currently on the list

5 have never been reviewed in the nano form. 

6 We further then asked you to

7 review the possibility of -- the issues of the

8 enforcement for primary packaging, for food

9 contact surfaces, which may or may not be

10 problematic. If they're not, that's great. 

11 If they are, we would like to know about --

12 that we were -- we thought the Board should

13 know about them before they took full action.

14 I don't remember what the other

15 bullet points were off the top of my head, but

16 it was an effort to give you something to deal

17 -- to work with as soon as possible so that we

18 could then proceed. We called for a symposium

19 as a way to sort of bring all that information

20 together. That may not, in the long run,

21 being the absolute best mechanism, but it was

22 what we had to work from at the point in time
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1 of preparing the document. But it was to give

2 you something to work with right now, or as

3 soon as you could get to it, anyway.

4 MR. McEVOY: Yes, it would be a

5 good document for us to work with, the

6 substances part will be very clear. It's the

7 things beyond the substances that the

8 regulatory status of that is -- needs some

9 exploration. 

10 MR. GIACOMINI: And that's what we

11 asked for you to do.

12 MR. McEVOY: That's what we could

13 do.

14 MR. GIACOMINI: Jay?

15 MR. FELDMAN: The only thing I

16 heard missing from that, I think --

17 MR. GIACOMINI: I said I forgot

18 something.

19 MR. FELDMAN: Yes, I know -- that

20 I think I'm hearing from Patty and others is,

21 obviously their long-term goal is to stop this

22 use, to stop this substance from being used in
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1 organic. And I believe that the proposal does

2 that pending our consultation, either through

3 a symposium or some other mechanism.

4 MR. GIACOMINI: Yes. Yes. We

5 basically request that the Board do not review

6 nano substances until it's fully resolved or

7 are extremely judicious in consideration of

8 what they're looking at on anything that comes

9 forth as a nano particle for consideration

10 before listing.

11 I mean, we can't say that someone

12 can't submit a petition, but to come to this

13 document and to look at where we are at this

14 point, at least, before -- if they have to

15 consider that petition.

16 MR. McEVOY: I guess we can talk

17 about this tomorrow. I viewed it more as a

18 moratorium until we collected the community's

19 opinions, but --

20 MR. GIACOMINI: With as much

21 authority as we can. Thank you, I think.

22 David Will -- let's see, we are --
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1 three, four, five -- we need to take a break. 

2 We are at 5:20, 5:15, 5:20. Let's take --

3 shoot for ten minutes, we will go 5:30. And

4 try and be back promptly. And this is when we

5 should be recessing and I believe we have

6 about between 15 and 20 to go. So we may be

7 looking at another two hours.

8 (Whereupon, the above-entitled

9 matter went off the record at 5:18 p.m. and

10 resumed at 5:31 p.m.)

11 MR. GIACOMINI: Board members can

12 please find their seats. Gallery please find

13 a seat. Any conversations, please take them

14 outside. We'd like to get started again. 

15 We'd like to be done, but we will get started

16 again. We try to offer you the full respect

17 we did for the first person speaker of the

18 morning, but it's hard.

19 Okay. We have a quorum and we

20 need to get going again here. Like I say, we

21 are close to two hours behind schedule. Let's

22 -- we're going to try to be respectful but
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1 expedient. And we'll go with our first one

2 up, Dave, Gregg Buckwalter and then Alexis.

3 MR. WILL: Thank you. Good

4 afternoon, Mr. Chairman and the NOSB Board and

5 the Program. I first want to thank you very

6 much for the hard work you guys did in these

7 last couple years with the methianine issue,

8 and I'm glad it looks like we may be closer to

9 conclusion. 

10 On behalf of our company --

11 MR. GIACOMINI: You haven't been

12 paying attention.

13 

14 (Laughter.)

15 MR. WILL: I just got here.

16 (Laughter.)

17 MR. WILL: I do want to let you

18 know that, based on the comments earlier, that

19 our company will be supplying to the MTF the -

20 - our levels of need as a bare minimum for

21 organic poultry, and we'll make sure to be in

22 contact with all the other members of the
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1 Methianine Task Force to make sure they get

2 that to you as soon as possible so you can

3 have that to review at the next meeting.

4 Also I just wanted to remind you

5 again, as members of the NOSB, we would love

6 to have you out to one of our ranches. During

7 a break, you're more than welcome to come grab

8 me for a card or I'll leave some here with the

9 secretary so you can grab one. If we're not

10 available for you geographically, I'm sure I

11 can find somebody on the MTF, on the organic

12 poultry side or the layer side, that would

13 love to have you guys out to take a tour. I

14 know the Program's been out and seen a couple

15 ranches, and we'd sure like them to come to us

16 as well and take a look at some productions

17 there.

18 Third, we really like the

19 guidelines that we've seen and the direction

20 that MP-50.24 went, the guideline for outdoor

21 access to organic poultry, and we'd like to

22 see that go to rule making if at all possible. 
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1 We really liked a couple things in there which

2 was, they addressed the threat of an avian

3 influenza break or influenza break and dirt. 

4 We thought those were key changes to the

5 existing rule and we're hugely in favor of

6 those.

7 Also we, as a company, would

8 oppose any rule making that would offer grand

9 fathering in and anything that had a two-step

10 program. We just think that the marketplace

11 would be too confused by those and just would

12 not see how that would benefit the organic

13 consumer.

14 In 50.24, we do have one word that

15 we'd like to change, and that's the word six

16 where it refers to the age of pullets that

17 need to go outside. And this is actually Ron

18 Christiansen, he's our ranch manager at one of

19 our facilities. He's been in the industry for

20 32 years and been in a dedicated organic

21 facility for the last five. And I brought him

22 along to specifically speak to or answer any
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1 questions that you have on pullets.

2 So Ron, let me get the guitar for

3 you. Here.

4 (Laughter.)

5 MR. CHRISTIANSEN: Again, thank

6 you, Board, for your hard work. This is my

7 first meeting and it's been encouraging to see

8 your desire to listen to all parts of the

9 organic family. We are a diverse family and

10 sometimes it's very hard to bring all the

11 components together. We don't agree all the

12 time. And I thank you for listening very

13 genuinely, to our concerns.

14 The issue at hand is the

15 requirement to change to require outside

16 access for grain pullets at six weeks of age. 

17 As a poultry producer, I am given charge of

18 many responsibilities, and two of those are to

19 the health and safety of the birds that I am

20 in charge of and care of. And then I'm also

21 given responsibility of the food supply, the

22 organic eggs that we put out. And requiring
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1 pullets to the outside access at six weeks of

2 age doesn't allow me, in my opinion, to do

3 both very well. 

4 On the outside, the pullets are

5 subjected to higher risk being exposed to

6 diseases and disease-causing agents, which

7 that's obvious I can control the indoor

8 environment much better than I can control the

9 outside. Rodents and varmints and wild birds

10 and the like, which is on the outside that I

11 can control on the inside to a certain degree

12 of success. 

13 I have the tools available to me

14 to protect the birds and to keep them safe and

15 to protect their food supply. I just don't,

16 with the six weeks of age, to implement this

17 vaccination program that I need to to build

18 the birds' immunity. The science behind that

19 scene is the need for boosting, we follow

20 vaccinations and the time needed to build

21 adequate immunity in pullets are well

22 established. At six weeks of age, I just have
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1 begun the process. 

2 As an example, on our particular

3 ranch, I give four Newcastle vaccinations. At

4 six weeks of age, I've only given two. I give

5 four bronchitis vaccines. At six weeks I've

6 only had time to give two. I give three E7 coli vaccinations, and at six weeks of age,

8 only one has been given. Salmonella, I give

9 three, and at six weeks of age only one has

10 been given. I have not yet even given a

11 fowlpox vaccination or the Asian

12 encephalomyelitis vaccine. And I understand

13 that AE -- AI is on the horizon for

14 vaccinations, and that will take a procedure

15 or protocol.

16 I have talked with California

17 State Animal Vet, Dr. Grey Cutler, and Texas

18 State Animal Vet, Jose Aguirre-Ramirez and

19 both agree that allowing birds outside access

20 before their vaccination program is complete

21 and they've had time after that last

22 vaccination for the immune system to build, is
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1 not in the birds' best interest.

2 MR. GIACOMINI: Okay. Can you --

3 your time is up.

4 MR. CHRISTIANSEN: Okay.

5 MR. GIACOMINI: Do you have a

6 final concluding comment? Otherwise questions

7 and comments. Kevin.

8 MR. ENGELBERT: To state the

9 obvious, you're very reliant on vaccines to

10 maintain the health of your birds. Has this

11 always been the case with raising poultry and

12 do you know offhand what percentage of these

13 vaccines are GMO?

14 MR. CHRISTIANSEN: On my operation

15 -- let me answer the second one first. I

16 believe I might have one, that might be the

17 only one. As far as -- I do rely heavily on

18 the protection that vaccinations provide. I

19 am a believer in that. We have the tools, and

20 given the time we can adequately prevent the

21 birds from getting the diseases that they're

22 challenged with.
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1 MR. GIACOMINI: Questions --

2 further questions, comments?

3 (No response.)

4 MR. GIACOMINI: Okay. Thank you,

5 gentlemen.

6 MR. WILL: Thank you.

7 MR. CHRISTIANSEN: Thank you.

8 MR. GIACOMINI: Gregg Buckwalter,

9 Alexis and Jeff Richards. Go ahead.

10 MR. BUCKWALTER: Thank you. Good

11 afternoon, my name is Gregg Buckwalter. And

12 my wife, she was the vegetarian -- and I'm not

13 --

14 (Laughter.)

15 MR. BUCKWALTER: -- that spoke

16 earlier. I'm going to go ahead and give my

17 conclusion or thoughts first before I go into

18 my speech so that I have time to do that.

19 I applaud you in setting density

20 figures to take away the interpretation of the

21 law and making it clearer. Right now our

22 operation can meet the standards as they are
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1 intended, and be under the PEQAP program,

2 which is the Pennsylvania Egg Quality

3 Assurance Program, which is what FDA mirrored

4 in their egg rule. We have 50,000 birds of

5 organic in four farms that are on pasture at

6 the stated levels. We haven't done the

7 pullets yet at the moment, but we have -- we

8 do have 50,000 of our 100,000 birds of organic

9 that are right now compliant with these new

10 regulations.

11 And I would echo David as well as

12 -- don't allow two different organic

13 classifications. And don't grandfather. The

14 people that put up some of these facilities

15 that they did, they knew what they were doing

16 when they did them, they knew that they were

17 making -- taking something good and making it

18 bad, or making it less desirable, shall we

19 say. It's just different production styles.

20 I'm a third-generation egg

21 processor. I should have said that first. 

22 But -- from Pennsylvania. The older I get the
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1 more I understand the benefits of organic

2 farming, and the more it makes sense to me. 

3 It bothers me to see the beautiful landscapes

4 of farms, in Pennsylvania anyway, turn into

5 blacktop and houses. In my opinion, the

6 organic farming could be a solution to this

7 following -- allowing smaller family farms to

8 stay in business. 

9 The United Egg Producers have a

10 comment in one of their newsletters stating

11 that if the U.S. would go to cage-free

12 production styles, we would need tens of

13 thousands more farms to produce that. Great,

14 I thought. People complain about one of those

15 things, that family farms are disappearing. 

16 I see that as a way for families to make good

17 income for their -- off their farms instead of

18 having to sell them for development.

19 In our company, we have made a

20 decision not to bring in product or eggs from

21 farms that have two or more houses or any

22 aviaries. We feel that having too many birds
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1 on a location is becoming a complex and is too

2 much like the conventional-style production. 

3 We also believe that if paid well enough, that

4 farmers can make a good living with what they

5 have.

6 If you look at what happened in

7 the organic egg industry over the last 30

8 years, it's starting to mirror the

9 conventional industry. The mindset of the

10 conventional guys, to offer what the customer

11 wants so that no one else can get into the

12 customer base. There's a large midwest

13 producer that, in the past year, has talked

14 about how bad cage-free and organic styles of

15 production are, yet he bid on and supposedly

16 got a contract for the cage-free and organic

17 business of a large grocery chain in the

18 southeast U.S.

19 Many of the conventional producers

20 only see organic production in terms of dollar

21 signs. If you look at most of the

22 conventional guys' organic housing, it is an
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1 aviary-style housing, 30 to 60,000 birds in

2 one house and a row of houses beside each

3 other. They don't know anything other than to

4 cram birds into a house and they get away with

5 it and sell as cheap as they can.

6 The conventional market has been

7 very good to a lot of these producers and has

8 given them money to put up houses, complexes

9 and gain economies of scale to put the smaller

10 the smaller producers with integrity out of

11 business. They've also been flush with cash

12 because of the conventional market being so

13 high that it enabled them to outlast their

14 competition and they can sell to low cost and

15 play a few games.

16 In southeast Pennsylvania, close

17 to one of our -- close to our facilities,

18 there is one larger conventional farm that has

19 an organic house that's two stories high with

20 30,000 birds in each level. Their access is

21 a wooden porch with steps, and I'm not even

22 sure, from what I understand, they don't even
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1 let the birds out, according to their vet. 

2 That doesn't sound very organic to me, in

3 fact, I understand that there are some

4 certifiers that won't certify them, and -- but

5 there's still one particular one that will. 

6 But that's a whole other story, I guess.

7 One certifier's idea of birds

8 exhibiting natural behavior is different from

9 another. A certifier wants to keep their

10 income up. With these larger facilities they

11 may be able to do that. I have one more

12 comment. They may be willing to view things

13 in a different light than others would. 

14 If all the producers that had put

15 up these new facilities can use them as cage16 free, they don't need to be grand fathered in. 

17 They pretty much everyone that produces

18 organic also produces cage-free along with

19 them.

20 MR. GIACOMINI: Questions and --

21 Kevin?

22 MR. ENGELBERT: Thank you. How
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1 much outdoor access do you allow your birds,

2 and if you feed synthetic methianine, at what

3 levels do you feed it?

4 MR. BUCKWALTER: Right now, we are

5 -- I know we're at at least the two -- minimum

6 of the two square foot. And as far as the

7 methianine, I believe it's what the levels had

8 ratcheted back to. I'm not exactly sure

9 offhand, I'd have to look it up. I'm sorry.

10 MR. GIACOMINI: Questions, comments?

11 (No response.)

12 MR. GIACOMINI: All right. Thank

13 you. Alexis, Richard and Paul.

14 MS. BADEN-MAYER: Hello, I'm

15 Alexis Baden-Mayer here on behalf of the

16 Organic Consumers Association and the 900,000

17 organic consumer activists who have worked

18 with us over the last decade to keep organic

19 standards strong.

20 On behalf of our 250,000 current E

21 activists and our 118,000 Facebook activists,

22 I'm here to talk to you today about phasing
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1 out non-organic and synthetic ingredients,

2 keeping nano technology out of organic and the

3 importance of animal welfare, especially the

4 maximum stocking densities and outdoor access

5 for organic poultry.

6 On nano technology, over 13,000

7 Organic Consumers Association activists have

8 submitted comments to you about the importance

9 of keeping nano technology out of organic. 

10 Nano technology is already being used in food

11 without being safety tested or labeled or

12 regulated. Very little is known about the

13 health and environmental effects of current

14 commercial applications of food nano

15 technology but the dangers are beginning to be

16 exposed. Nano silver, for instance, is a

17 powerful biocide that kills beneficial as well

18 as harmful bacteria and is toxic to fish. 

19 Nano gold decreases earthworms' reproductive

20 capacity by 90 percent. Titanium dioxide nano

21 particles cause DNA damage in mice.

22 If you sincerely agree with
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1 consumers that nano technology should be

2 excluded from organic, please do not pass the

3 current committee recommendation. The current

4 committee recommendation simply states the

5 current status quo. It doesn't require any

6 action of the NOSB or the NOP to recognize

7 products of nano technology are synthetic. 

8 They are not allowed in organic, and if a

9 company wants to use engineered nano materials

10 in organic production, processing or

11 packaging, they have to petition the NOSB for

12 permission.

13 A year ago, there was a committee

14 recommendation to ban nano technology from

15 organic altogether. That is the only

16 recommendation worth voting for -- voting on,

17 is what I meant to say. But if it didn't

18 pass, it wouldn't be the end of the world. 

19 Nano technology still isn't being used in

20 organic, and it isn't going to be without

21 specific engineered nano materials being

22 petitioned. So if you want to go ahead and do
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1 the right thing, ban nano technology from

2 organic, but do not pass the current committee

3 recommendation.

4 Before I finish on nano tech, I

5 just want to refer you back to the statements

6 from the Center For Food Safety concerning

7 packaging. Nano technology is not allowed in

8 organic packaging. 

9 On animal welfare, over 11,000

10 Organic Consumers Association activists have

11 submitted comments on the importance of animal

12 welfare standards. In favor of phasing out

13 synthetic methianine, and to enforce current

14 regulations that require hens to be able to

15 exhibit their natural behaviors and have

16 meaningful year-round access to the outdoors. 

17 We will continue to submit comments in support

18 of the animal welfare discussion document on

19 stocking density. Please continue to keep up

20 the good work you all are doing on animal

21 welfare. 

22 Now that the National Organic
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1 Program has put out a draft item on outdoor

2 access for poultry, we are directing our

3 comments to the NOP. We would like to see

4 much stronger guidelines. The NOP should

5 implement the NOSB's recommendations as

6 minimum standards that should guide the

7 creation of organic system plans.

8 Sulfites in organic wine. So far

9 nearly 6,000 Organic Consumers Association

10 activists have submitted comments opposing the

11 petition to change the annotation on sulfites

12 in organic wine. Please reject the petition. 

13 Currently, wine made with organic grapes and

14 no synthetic sulfites is USDA organic while

15 wine made with organic grapes and sulfites is

16 made with organic. USDA organic should

17 continue to be reserved for sulfite-free wine. 

18 Wine makers are already getting a huge

19 exemption to the general ban on sulfites in

20 organic. Sulfites are prohibited in organic

21 along with genetic engineering, sewage sludge

22 and irradiation. The wine exception for
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1 sulfites should not be expanded any further.

2 Non-organic ingredients. More

3 than 4,000 Organic Consumers Association

4 activists have sent letters in support of

5 organic beer and bratwurst being made with

6 organic hops and sausage casings. Please pass

7 a recommendation on hops. The logic that was

8 finally applied to hop should be applied to

9 all agricultural products that are currently

10 allowed in non-organic form. The commercial

11 availability evaluation should require an

12 investigation into whether the ingredient can

13 be used on a contract basis. 

14 It's time for companies to take

15 responsibility for their supply chain. For

16 example, imagine your -- an organic sausage

17 brand that is owned by the third largest beef

18 and pork processor. Your certifier should be

19 talking to you about contracting for the

20 production of organic sausage casings. The

21 National List sunsets every five years so that

22 producers have five years to look for,
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1 contract for or create themselves ingredients

2 in organic form.

3 Just a few more issues. The OCA

4 would like to see the NOSB review each of the

5 lists for inerts. We would like to see the

6 Board pass the committee's corn steep liquor

7 recommendation -- could I just finish the

8 sentence? We do not seek a change in the made

9 with organic label and we oppose the use of

10 non-organic and synthetic vitamins in organic

11 food and we continue to submit consumer

12 comments to the NOP regarding passing the NOSB

13 recommendation on personal care products.

14 MR. GIACOMINI: Questions and

15 comments? Joe.

16 MR. SMILLIE: One of the best ways

17 that we've seen to get something off 606 is to

18 submit a petition. That way, the NOSB can

19 start to move. Sunset, I think, is still not

20 the best way. They have a battle at sunset. 

21 I prefer to do it in the full light of day,

22 and I would suggest that your organization or
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1 others submit a petition for removal of

2 casings.

3 MS. BADEN-MAYER: Well, it's

4 supposed to be in the law already, that says

5 that sunset is a phasing out. You have five

6 years to prepare for that. That's why it's

7 called a sunset. You know, if it were called

8 something else like, you know, consumer gets

9 a petition to get ingredients off the list

10 that the companies could make themselves, then

11 we'd have a different process.

12 MR. GIACOMINI: Well, they could

13 have called it orange, but we have -- it also

14 has a definition as to what the process is. 

15 So there's two parts to it. It's not just a

16 name.

17 MR. SMILLIE: Just giving you the

18 benefit of my experience, the best way to get

19 things done.

20 MR. GIACOMINI: Jay. 

21 MR. FELDMAN: So what is the

22 headline, if we pass this nano --
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1 MS. BADEN-MAYER: Organic --

2 MR. FELDMAN: Can we write it

3 down?

4 MS. BADEN-MAYER: Organic Board

5 opens the door to nano technology.

6 MR. FELDMAN: Would you consider

7 Organic Board sets moratorium ending further

8 review?

9 MS. BADEN-MAYER: If that's what

10 you guys actually do, but that's not what this

11 recommendation looks like.

12 MR. FELDMAN: Why not?

13 MS. BADEN-MAYER: Because it's

14 just saying it's a synthetic. It's not

15 stating a prohibition. 

16 MS. ELLOR: Yes, it does.

17 MS. BADEN-MAYER: So you have less

18 -- you have the GMOs, irradiation, sewage

19 sludge, nano technology. That's where it

20 belongs. It is not a synthetic to be

21 petitioned, in my opinion, into organic. But

22 that's where this recommendation leaves it.
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1 MR. FELDMAN: Yes, and I think

2 many on the Board -- I don't think it's quite

3 enough to pass, but many on the Board agree

4 with that but want to establish -- the intent

5 is to establish moratorium pending --

6 MS. BADEN-MAYER: Well --

7 MR. FELDMAN: -- pending now, but

8 we needed to give the NOP -- this is my

9 perspective, you know, anybody else can chime

10 in here. But I believe we needed to give the

11 NOP a definition of what to create a

12 moratorium on. So if that's the case, if

13 we're not achieving that, we -- would it not

14 be better to do that than -- because I could

15 read a headline, if we do nothing, that looks

16 something like NOSB fails to restrict nano

17 technology.

18 MS. BADEN-MAYER: It's a problem,

19 because I came in the spring with another

20 attempt to ban nano technology entirely

21 forever, before somebody comes with the first

22 petition for a nano material. 
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1 But you know, there are lots of

2 crazy technologies out there. They could all

3 potentially incorporate it into organic, but

4 we understand that they're synthetic. And we

5 already have a process to exclude them on a

6 case-by-case basis. What you all were trying

7 to do a year ago is say, I had a thought

8 process, we are letting everybody know, don't

9 bother petitioning nano materials to organic. 

10 They are prohibited forever, excluded, an

11 excluded process. If you just did the

12 recommendation that's currently in front of

13 you, it's just stating the status quo, it's

14 not necessary. I think we heard from the

15 Program earlier that it wouldn't require a

16 regulatory change.

17 MR. GIACOMINI: I respectively

18 disagree. I don't think the Program has any

19 directive at all or any information that the

20 nano form of existing allowed substances are

21 considered any different than what the listing

22 is.
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1 MS. BADEN-MAYER: I haven't seen

2 any comments that say nano technology is not

3 a synthetic. I haven't heard anybody on the -

4 -

5 MR. GIACOMINI: On the list of the

6 allowed synthetics, currently the nano forms

7 would be allowed.

8 MS. BADEN-MAYER: Okay. Well, if

9 you're going to think that -- if that tiny

10 issue is the problem that you think you need

11 to address that tiny issue.

12 MR. GIACOMINI: It's part -- it's

13 just part of the issue.

14 MS. BADEN-MAYER: Well, address it

15 directly, then. But if this is -- because

16 this is right now your statement on nano

17 technology in general. And it is better to be

18 specific than it is to say -- you know, it's

19 sort of like passing this recommendation is

20 sort of like saying, come on, petition nano

21 materials to organic because we're leaving the

22 door open to it. We have decided not to
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1 prohibit, it is an exclusion method. We're

2 treating it as a synthetic, it can be

3 petitioned. I mean, that's where that

4 currently stands. But there's no reason to

5 announce that to the world and say that, you

6 know, that's where -- 

7 MR. GIACOMINI: I --

8 MS. BADEN-MAYER: Let's keep that

9 on the down-low until we get it --

10 MR. GIACOMINI: You know, we have

11 a difference of opinion of what this

12 recommendation does, and we worked very hard

13 to try and come up with a path that gets to

14 the place where we can have a recommendation

15 that will pass and it's in the direction of

16 where we all want it to go. Unfortunately, we

17 don't control the yank at the end of the day. 

18 Any other questions or comments? 

19 Thank you, Alexis.

20 Jeff, Chris and Bob.

21 MR. RICHARDS: Good evening. My

22 name is Jeff, I'm from Pines International,
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1 Kansas. We're primarily a grower, organic

2 grower and manufacturer of wheat grass, barley

3 grass and alfalfa products for the last 34

4 years. Our most popular retail products are

5 tablets of which we used two excipients. A

6 percent and a half of silicon dioxide and half

7 a percent of magnesium sterate. 

8 We were very excited to hear that

9 there could be an organic substitute for these

10 two ingredients, or two different substitutes. 

11 One for the magnesium sterate and one for the

12 silicon dioxide. So we experimented and found

13 that the magnesium sterate substitute worked

14 excellent. And we're in the process of

15 switching over to it and changing our labels. 

16 However, the silicon dioxide replacement, we

17 could not make a decent tablet, even when we

18 doubled the amount of the ingredient.

19 The substitute -- well, in

20 particular the silicon dioxide substitute

21 definitely has a place in the industry, but

22 obviously it is not acceptable or workable in
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1 all applications. Last week I was at the

2 supply side show and talked with another

3 organic manufacturer that does vegetable and

4 juice powders, and they use silicon dioxide as

5 an anti-caking agent. He had also tried the

6 rice substitute and with no success. He was

7 not aware of this petition to get rid of

8 silicon dioxide, and I think there's a lot of

9 manufacturers out there that are not. And so

10 I think there needs to be more manufacturer

11 input on this subject.

12 If we cannot silicon dioxide, it

13 will seriously affect our ability to continue

14 our sustainable farming and also provide our

15 consumers with inexpensive and convenient form

16 of organic green leafy vegetables. Silicon

17 dioxide is not harmful to the environment,

18 neither its use or manufacture, and we

19 sincerely ask the Board to continue to leave

20 it on the National List.

21 Thank you.

22 MR. GIACOMINI: Questions or
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1 comments?

2 (No response.)

3 MR. GIACOMINI: Thank you. Chris,

4 Paul -- Chris, Paul and Bob. Chris, are you

5 here? 

6 (No response.)

7 MR. GIACOMINI: Paul, are you

8 here? Let's go, Bob.

9 MS. BRINES: Paul is here.

10 MR. GIACOMINI: Pardon?

11 MS. BRINES: Paul is here.

12 MR. GIACOMINI: We will -- no, go

13 ahead. You didn't know you were going to be

14 next, so -- Silvia is next up.

15 MR. DURST: While she's loading

16 that up, I'll start up.

17 I'm here as a proxy for Whitmeyer

18 MicroGen, which in this case it's a facilities

19 processing pesticide manufacturer. And one of

20 the concerns that we have is -- and I'll point

21 the question back to the Board and to the

22 Program here, is that after -- it has to do
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1 with inerts in pesticides. And what's showing

2 there, I'm sorry it's not a very good copy, is

3 after the August 2004 listing of inerts in

4 pesticides, the List 4 stuff, EPA continued to

5 reevaluate materials for inclusion on List 4. 

6 And this is a letter from them,

7 August 2006, and the materials in question

8 here, you can read at the very bottom there,

9 said that the materials on -- that they had

10 petitioned for should be included in List 4B. 

11 So this is 2006. Obviously you know that that

12 list got dropped later on and EPA quit

13 evaluating things. But the Program in -- what

14 was it, December of 2007 said, we're only

15 going to use the EPA List 4 things from August

16 2004, minus a handful of items that had been

17 excluded from List 4, but not including things

18 that had been reevaluated in good faith

19 between 2004 and when they ultimately dropped

20 that. 

21 And so a bunch of this stuff is

22 orphaned until sometime when this new EPA NOP
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1 thing gets sorted out. And I'm -- what I'm

2 asking and requesting, and we heard the same

3 from Cameron a little earlier this afternoon,

4 is they -- we would like these things that got

5 orphaned to be included in this interim period

6 while things get reevaluated. And I've had a

7 discussion with Miles and he says they're not

8 going to do that. But I'd like the Board to

9 say, gosh, what's the problem here, why can't

10 we include these things that got orphaned? 

11 Because when that List 4 2004 publication came

12 out, there were things that people said, gosh,

13 it's not on our list, let's get it on our

14 list. In good faith they did that and they're

15 still out of luck with using them in the

16 interim time period.

17 Having said that, leave it at

18 that. This is the table of what those five

19 items were in this particular case here. 

20 They're petroleum distolates, hydrocarbons

21 used as solvents in carriers for pesticides.

22 While I still have a little bit of
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1 time, let me go on to the next slide here. 

2 And first off, I want to say, I was speaking

3 earlier on the CSL issue, and in a direct

4 question or response to a direct question from

5 Jay Monday, he asked whether disulfide bonds

6 were covalent bonds. I said no. That was

7 wrong. I should not have said that. They are

8 covalent bonds but they're unique and very

9 interesting in covalent bonds in that they're

10 weak covalent bonds. They are reversible and

11 the typical protein structure which has a

12 covalent bond, covalent backbone, is not

13 broken like disulfide bonds are broken, it

14 only changes the quaternary structure of the

15 protein and it doesn't change the character of

16 that protein, just the physical shape of that

17 protein. So I just wanted to correct some

18 misstatement that I made earlier and clarify

19 a little bit about what's going on with that.

20 So just for your interest, here

21 are some photomicrographs -- go back one. 

22 This is what we're talking about here. These
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1 are photomicrograph of the endosperm and what

2 we're looking at, these are starch granules. 

3 And the little dimples, dots on top of there

4 are actually the zein protein bodies which are

5 the proteins that are surrounding the starch

6 granules. And our next slide -- sorry it's a

7 little hard to see, but here's a place where

8 these protein bodies have been stripped off of

9 the starch granule and there's little dimples

10 left behind there. Here's a spot where the

11 protein bodies are still present on there,

12 they haven't been ripped off yet. Just to

13 show an example of what we're talking about as

14 we're dealing with the steeping process. The

15 steeping process is releasing the zein protein

16 bodies from the starch granules so that they

17 can be used later on.

18 Here's another shot of what the

19 starch granules look like when most of the

20 protein bodies have been removed. You can

21 still see some dimples from them here. 

22 So my time is mostly up, I'll say
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1 thanks. But I just wanted to show what was

2 actually going on with that.

3 MR. GIACOMINI: Questions,

4 comments?

5 Thank you.

6 Silvia. Next is Paul in the room

7 yet? Okay, next up, Erin, is Erin in? Is

8 that Erin? Okay.

9 All right, go ahead.

10 MS. ABEL-CAINES: My name is

11 Silvia Abel-Caines, I'm a veterinarian and

12 dairy nutritionist with Organic Valley Co-op.

13 I would like to focus my comments

14 on the animal welfare and animal stocking

15 density. Consumers today are increasingly

16 concerned about the welfare of farm animals,

17 and we in the organic community have led the

18 way in this regard, and I believe we should

19 continue to make progress to get closer to a

20 more clear definition of what an appropriate

21 indoor space and outdoor pen should be.

22 A couple of considerations I would
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1 like to make. First, there is need to be --

2 there needs to be some clear definition on

3 species-specific confinement spaces. The

4 language is not precise on what are the NOSB's

5 specific conditions in which a ruminant could

6 be temporarily confined. To improve its

7 health condition and to change the status, the

8 health status of the animal.

9 When we take a close look at the

10 table provided in the Animal Welfare

11 Discussion document under the dairy cattle

12 section we have the space calculation base in

13 body weight. For instance, 770 through 1,100

14 pounds called for a 50 square feet indoor

15 space. But in reality, these need to be

16 refined because, in a typical operation we

17 have maternity pens, we have sick pens, which

18 will require different settings depending on

19 the condition and the reason why the animals

20 are staying there.

21 Also what kind of ventilation is

22 assumed for this kind of spacing? For this
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1 amount of square feet in a sick pen with two

2 to three 1,300 pound cows, the 25 parts per

3 million ammonia level will be quickly

4 surpassed. Given the documented effect of

5 ammonia on upper respiratory health

6 conditions, I would like to suggest that those

7 levels should be lowered to at least 20 parts

8 per million for organic production.

9 Along these lines, I want to

10 mention the recommended stocking area for

11 poultry which is set around two square feet

12 per bird. We at Organic Valley have found

13 that five square feet provide the best

14 stocking density to minimize parasite load,

15 protect the soil and keep ammonia levels at

16 minimum. 

17 I also want to bring the point

18 that, when it comes to definition of adequate

19 shelter design to allow for adequate exercise,

20 freedom of movement and reduction of stress,

21 the language is not clear and it's overly

22 prescriptive. For instance, there is no
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1 consideration for tie-stalls or stanchion

2 barns. I believe the recommendations that

3 should come should be a guide and the language

4 we use should be minimized so the confusion

5 between producers and certifiers is kept at

6 the minimum.

7 And on another subject, regarding

8 the use of nanotechnology, I will say that

9 nanomaterials should stay out of organic

10 production. We don't completely understand

11 their mechanism of action but we must

12 differentiate between natural and synthetics.

13 And with that I will take any

14 comments and questions.

15 MR. GIACOMINI: Questions and

16 comments? Jeff?

17 MR. MOYER: Not so much a question

18 but just to go on the record to say that, what

19 we're trying to do is, when you look at --

20 when you're talking about tie-stalls and

21 stanchions, that was already addressed in a

22 previous document that this Board approved and
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1 passed on to the program. I don't remember

2 what the date was on that. But it's -- so

3 there's two parts to the document, the one

4 that's currently being reviewed by the public

5 and the livestock committee and then the one

6 that's already been approved by this Board. 

7 So those two will have to be looked at in

8 unison.

9 And the other piece is, the

10 stocking densities that we're looking at,

11 while those minimums may seem very small in

12 some circumstances, what we're trying to do is

13 we're trying to partner that minimum stocking

14 density chart with an outcomes-based scoring

15 system. So the two go hand-in-hand. If, for

16 example, your animals are not meeting the

17 conditions scoring that we're trying to

18 achieve, you may have to have more space in

19 your particular operation. 

20 We're trying to be non21 prescriptive and allow farmers as many

22 management options as they can find to achieve
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1 those two outcomes. But we're also trying to

2 set a minimum on how tightly they could

3 possibly dense -- pack their animals under any

4 circumstances. I just wanted that on the

5 record. Thanks.

6 MS. ABEL-CAINES: Okay.

7 MR. GIACOMINI: Other comments? 

8 Katrina?

9 MS. HEINZE: Thank you, Jeff. 

10 That was totally helpful. That's the first

11 time I've understood that point.

12 MR. GIACOMINI: Okay. Is Paul

13 here yet? If anyone knows Paul, if they could

14 go fetch him, that would be wonderful. 

15 Otherwise he's going to miss out.

16 Erin, Dave Engel, is Dave still

17 around?

18 MR. ENGEL: Yes.

19 MR. GIACOMINI: Okay, Dave, you're

20 next. And then we'll -- go ahead.

21 MS. FREIBERG: Good evening, my

22 name is Erin Freiberg. I don't have a lot to
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1 say so I'll probably be giving you some of

2 your time back. Hopefully that's appreciated.

3 I'm a mother of three kids under

4 the age of six and I'm a consumer of organic

5 foods. I'm here today and I've waited for a

6 couple of hours just to get the chance to talk

7 to you all and urge you to pass -- to issue

8 meaningful standards regarding outdoor access

9 for organic laying hens. 

10 Now as an egg consumer, I'm just

11 kind of -- I'm not a scientist, I'm going to

12 bring you back to sort of a everyday shopping

13 experience. I'm confronted with numerous

14 labels at the grocery store, and I'm sure

15 you've all seen them also. Antibiotic free,

16 cage free, vegetarian fed, free range, the

17 list goes on. But I know, as a knowledgeable

18 consumer, that none of these labels is

19 required to be certified by a third party. 

20 The only really meaningful label for me is the

21 one that reads USDA certified organic, that

22 you all are responsible for.
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1 Now this label, let me remind you,

2 because you're hearing from a lot of different

3 stakeholders here, it's not primarily for the

4 benefit of the producer, it's for the benefit

5 of the consumer. Consumers like me that are

6 in the grocery store and are looking for a

7 certain standard. The certified organic label

8 enables the consumer to choose to support

9 agricultural practices that align with what

10 they value.

11 I know that consumers purchase

12 organic foods for a variety of reasons, but a

13 major reason why I purchase organic eggs and

14 other organic animal products specifically is

15 because I believe animals should be raised in

16 a way that allows them to exhibit their

17 natural behaviors. For laying hens, this

18 includes being able to go outside to forage

19 for grit and insects and other things. I

20 understand that large egg production factories

21 have achieved economies of scale that allow

22 them to produce far more eggs for a far lower
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1 price in high intensity indoor facilities. 

2 But my family and many others like mine have

3 opted out of that and chose -- choose to pay

4 more to get our eggs from farmers who allow

5 and encourage their hens to go outside.

6 Now I know that under the current

7 rules there are some large organic egg

8 producers who don't provide meaningful access

9 to pasture. They provide maybe a small door

10 for outside access and the birds never

11 actually go outside. Or else the birds are

12 allowed to go on small porches, maybe

13 sometimes even elevated on a couple of levels

14 as we heard previously. 

15 Frankly, it disgusts me. It

16 disgusts me that producers are basically

17 allowed to manipulate these rules or take

18 advantage of the ambiguity, I should say, to

19 deceive consumers. I feel like it really is

20 deception. I feel like these producers are

21 essentially scamming me into paying more for

22 nothing, and I really resent that as a
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1 consumer. I deserve better. Other consumers

2 deserve better in our organic label, and it's

3 up to you to provide it and make sure it

4 happens. 

5 If you fail to issue strong

6 outdoor access regulations, the certified

7 organic label will no longer live up to its

8 name, and it will just become another useless

9 label that we see on our egg carton. I, for

10 one, know that I would rather not have to

11 raise my own hens in addition to raising my

12 children, so I need the help of this body to

13 ensure that I can make a meaningful choice

14 when I purchase organic food. We consumers

15 need you to issue a strong outdoor access rule

16 that requires more than two feet of space per

17 bird. I know there are farmers that currently

18 provide much more than that and will be happy

19 to comply with such a rule. We also need you

20 to require outdoor access to be to soil rather

21 than an artificial porch. And if that means

22 that some of the large conventional egg
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1 factories cannot go organic or some existing,

2 quote, unquote, organic farms can no longer be

3 certified, so be it. I'd rather purchase my

4 eggs from a farmer that truly cares about

5 organic livestock practices, even if that

6 means I have to continue to pay a premium.

7 Thank you so much for your hard

8 work, for staying tonight and for taking these

9 comments into consideration.

10 MR. GIACOMINI: Questions and

11 comments for Erin? Katrina.

12 MS. HEINZE: I just wanted to

13 thank you so much for your comments.

14 MS. FREIBERG: Yes.

15 MR. GIACOMINI: Okay. One second,

16 Paul? Is Paul here? Okay. Dave first, then

17 Paul then Will.

18 MR. ENGEL: Is this thing working? 

19 I don't think it is, is it?

20 Want me to come over there?

21 MS. BRINES: Yes.

22 MR. ENGEL: Okay. My name is Dave
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1 Engel. I'm a dairy farmer and that's where my

2 comments are coming from primarily this

3 evening. I also have been informed with 20

4 years of working for different certification

5 agencies and that is definitely informing my

6 comments also.

7 And I am struggling to find a way

8 to share with you tonight what I'd like to. 

9 It has to do with pasture. Gary Zimmer here

10 a few minutes ago shared a little bit of it in

11 a nutshell. Gary Zimmer, an Otter Creek

12 organic farmer at 24 percent on the dry matter

13 intake, and it's October right now, or they

14 were on the day of their inspection. And on

15 Sunday, the Millers were at 35 percent. These

16 are two premier farms here in Wisconsin, in

17 the Midwest. They are in the know, they have

18 resources that most farmers do not have,

19 millions of dollars, and they're just scraping

20 by.

21 Most of you know that from the

22 beginning I have not been in favor of numbers. 
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1 They're problematic when one does not heed

2 them. There have been few numbers in the rule

3 to date, the three years, 36 months free of

4 prohibited materials, 12 months organic

5 management of a dairy cow before shipping

6 organic milk. Having to keep records for five

7 years, the 90/120 day raw manure restriction

8 for food crops, the specs that were put in the

9 rule for -- from the EPA for producing safe

10 compost. And then there's a couple of other

11 one-year mentions in the rule. For example,

12 under seeds, for planting stock and then the

13 obvious, 100 percent, 95.5 percent, greater

14 than/less than 70 percent labeling. These

15 numbers have made sense from the beginning,

16 they worked. And they are what I call

17 production neutral. In other words, they are

18 broad, well-founded baselines that all

19 operations must meet and they are not size

20 biased.

21 But the numbers in the new pasture

22 rule, from the beginning, are meant to get the
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1 big guys. With the expectation that smaller

2 producers, of course, would have to comply --

3 could comply. As it's turning out, the

4 opposite is happening as the big guys have the

5 resources, and I have not heard anything to

6 prove otherwise, that they're having any

7 problems with it. In fact, I've talked with

8 one of them, the one operation that has -- I

9 don't want to go in that direction too far.

10 Anyway, the numbers in the rule,

11 though, that we have now. For example, a

12 grazing season number must be established,

13 plus the number of pounds, weight of the

14 animals must be known. Drainage and dry

15 matter to matter numbers must be established,

16 and then the number of pounds of feed adjusted

17 to a dry matter basis that are being fed when

18 not on pasture, and must be established, to

19 which must be compared then the number of

20 pounds, feed adjusted to a dry matter basis

21 being fed when on pasture, and at which point

22 the difference in grazing must be greater than
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1 that 30 percent and that greater than 30

2 percent number has to be averaged out over

3 their established grazing season number, which

4 number must be a minimum number of 120 days. 

5 And all of these numbers must be calculated

6 for each of the different parts of the grazing

7 season, early, mid-early, late-early, mid,

8 early-mid, early-late, mid-late, late-late. 

9 And all of these numbers must be calculated

10 for each of the different age and weight

11 groups and similarly, for the different parts

12 of the grazing season, for each of those

13 different age/weight groups, as above and as

14 applicable. And that's just for the 3126. 

15 There are another 10 to 15 numbers the pasture

16 rule brought in.

17 If those numbers don't work for

18 you, then there are other methods that the

19 USDA and the NOP, in their graciousness, have

20 provided and which you can use, but they are

21 much more involved and difficult to both

22 understand and to do. And then, of course,
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1 whichever way you choose must be documented so

2 that a certification agency can come out for

3 a few hours once or twice a year and see if

4 you're meeting the numbers.

5 As you can see, it's not so simple

6 anymore. I don't have a whole lot more to

7 say. I'm personally meeting -- I've got four

8 groups of animals and I'm meeting minimum on

9 three of them, I think, I hope. I've got, you

10 know, a system of documentation that I'm

11 doing, one of them I'm not meeting it on. And

12 you know, there's questions that the

13 certifiers are having and are in discussions. 

14 A big one centers around

15 correctable/noncorrectable. But I'll stop at

16 that. I think I've made my point.

17 MR. GIACOMINI: Questions or

18 comments? Kevin?

19 MR. ENGELBERT: Dave, I'd just

20 like to comment in case you're worried about

21 me. We have 300 animals. I did all those

22 calculations, we meet that requirement with no
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1 problem whatsoever. The 30 percent, 120 is a

2 -- guarantees a minimum of 10 percent of the

3 animal's -- a ruminant animal's feed for an

4 entire year, comes from pasture. What -- how

5 much of their feed do you think should come

6 from pasture in a year? And lastly, as you

7 know, my wife works for a certification agency

8 in New York. They have no super -- all their

9 farms would be considered small, and every one

10 of their farms is in compliance in 2010 with

11 the new pasture rule.

12 MR. ENGEL: Yes, I -- it is very

13 little time to try to express all the nuances

14 of what I'm trying to say, Kevin. I am in

15 support of trying to make this work. I do

16 know that one of the things I would have said

17 if had I gotten to it is, I think there's

18 going to be 20 percent of the farmers, none in

19 New York, thank goodness, that are -- that

20 could be in a major non-complaint situation. 

21 And I will bet that there's 10 percent of the

22 dairy farmers in the United States will be
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1 having proposed sanctions against them, not

2 just major noncompliances. The Midwest is not

3 set up for this, it's not. We just haven't

4 done it. And you know, I'm saying let's go

5 ahead with it, obviously we are. But the part

6 that I got to in my comment here was, the

7 certifiers are the ones that are going to have

8 to be managing this and we just -- the idea of

9 continual improvement is not built into the

10 numbers here. That's what I said right at the

11 beginning. When you have numbers that are

12 there and you don't meet them, then in this

13 case here, we're out. So --

14 MR. GIACOMINI: Joe.

15 MR. SMILLIE: I would respectfully

16 ask everybody to leave the mic in the holder. 

17 My ears hurt, a little sensitive at this

18 point, but that's okay.

19 But the other thing is, you know,

20 that's what -- that's what the badges said at

21 the pasture symposium. That's what the badges

22 said, they had those numbers on them. I
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1 remember the pasture symposium, one of my

2 first NOSB meetings as a member. The badges

3 said 30 -- you know, 30/120. So it was a

4 community that demanded the numbers and now

5 we've got to live with them.

6 MR. GIACOMINI: Thank you. Okay,

7 Paul and then I think I'm still up on the

8 right order -- Paul and Will -- are we Paul,

9 Will and JoAnna. Jim -- no, JoAnna. Okay,

10 Paul, Will and Jim. Well, Will needs to be

11 there next. So Paul, you go ahead. Will will

12 be after you and we'll figure out who is left.

13 MR. HABHAB: Thank you,

14 distinguished Board members. My name is Paul

15 Habhab, I'm director for Islamic Services of

16 America, founders basically of the Halal

17 industry in North America since 1975. We have

18 worked with the USDA, FDA over the years to

19 develop credible, authentic and responsible

20 Halal programs. Beginning I suppose in 1976

21 with Tamu Beef Pack and also with Louis Rich

22 in 1978, with turkey.
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1 Regarding animal welfare and the

2 policies by the Organics Board, again we want

3 to applaud the efforts of the NOSB to improve

4 the understanding and compliance with humane

5 animal care standards. But we also want to be

6 sure that these standards are also in

7 consideration of religious production

8 standards. There are a great number of

9 parallels between Halal and organic, as well

10 as with kosher. However, when we look at

11 proteins in that -- in those productions and

12 processes, things become or can become a

13 little more challenging by differences in

14 opinions.

15 With regards to stunning, it is

16 specifically written within the religion in

17 Halal criteria that animals may not be subject

18 to blunt force or bludgeoning or otherwise

19 what would equate or similarly to captive bolt

20 stunning, which is outlined in this version of

21 the standard that I received. The one thing

22 that I didn't see any clarification on,
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1 relative to captive bolt stunning was whether

2 it was penetrative or non-penetrative. And I

3 apologize if it's already been pre-written and

4 I didn't see this. But I would think that

5 whether we're talking about penetrating or not

6 penetrating the skull on the animal should be

7 something of a critical point to at least

8 address.

9 When we -- our organization

10 understands that USDA intends to double its

11 exports in the coming years. Global Halal

12 industry is a $2.3 trillion industry. In the

13 global economy, the Muslim world, whether

14 we're talking about Southeast Asia, Indonesia,

15 Singapore, Malaysia even Brunei and Thailand,

16 as well as the Gulf, the Middle East, GCC

17 region, UAE and so forth, they are demanding -

18 - and these are extremely lucrative markets,

19 and they are demanding Halal and that the

20 products that come in there are in accordance

21 with Halal standards.

22 I remember hearing some of the
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1 other speakers that said, when you look --

2 when a consumer looks at the package and says

3 on the label and it says organic that it means

4 something, it means something specific. And

5 while there are exclusions or opportunities

6 for Muslims or consumers of Halal foods to eat

7 foods that are not specifically Halal, those

8 are under other -- a whole other set of

9 criteria and need to remain separate. Because

10 when you look at a product and it says Halal,

11 it means something very specific, just as the

12 organic label does.

13 I can't expect to educate or

14 inform -- pardon that word educate -- but

15 inform everyone about the criteria of Halal

16 and relative to Halal. But it is very simple. 

17 We have been very successful. We have

18 dedicated plants, we operate in batch

19 production facilities, from beef to lamb to

20 veal to turkey, poultry, chicken, duck, et

21 cetera.

22 I just wanted to provide the
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1 information on who we are and that we can and

2 we'll be more than happy to provide additional

3 information and resources for proper

4 development of Halal within the National

5 Organics standards. Thank you.

6 MR. GIACOMINI: Kevin.

7 MR. ENGELBERT: Paul, we

8 appreciate the information. That's part of

9 why we have kept these as discussion

10 documents. We're looking for input from the

11 public, but we're not trying to gear these to

12 any specific -- any other specific standard. 

13 If Halal falls in with the standards we come

14 up with, that's fine, but that's not our goal. 

15 We appreciate your input, we appreciate input

16 from any other group of people. But I just

17 wanted you to be sure that, you know, we're

18 not trying to meet your standard or anybody

19 else's. We're trying to come up with our own

20 standard for organic handling, transport and

21 slaughter.

22 MR. HABHAB: Sure.
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1 MR. ENGELBERT: Okay.

2 MR. HABHAB: Understood, thank

3 you.

4 MR. ENGELBERT: Yes.

5 MR. GIACOMINI: Is there -- okay,

6 Joe, go ahead.

7 MR. SMILLIE: My understanding

8 earlier, when I mentioned about the kosher

9 stunning thing, you guys have already moved on

10 that, though, right? That that's under

11 consideration already, to have other methods

12 other than the stunning that are -- 

13 MR. HABHAB: Yes.

14 MR. SMILLIE: Okay.

15 MR. MOYER: Are you considering --

16 MR. GIACOMINI: Jeff, mic.

17 MR. MOYER: We're considering

18 everything, Joe. Like I said, we want input

19 from everybody. We're not trying to exclude

20 any type of anything, but we're also not

21 trying to accommodate specific, you know,

22 requirements of any other organization or
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1 group of people. We're trying to set the

2 standard for what all consumers expect with

3 the organic label.

4 MR. SMILLIE: And so once kosher

5 and Halal organizations understand what you're

6 doing, they can have specific -- they'll look

7 at their standard and see which things would

8 bar and they can send that input to you.

9 MR. GIACOMINI: Program?

10 MS. BAILEY: Melissa Bailey. I

11 just wanted to raise attention to the Board

12 that there is a federal humane slaughter act,

13 and there are certain exemptions under that

14 federal act for ritual slaughter that you

15 would maybe want to take a look at as you're

16 entertaining what you're working on.

17 MR. HABHAB: If I might --

18 MR. GIACOMINI: Yes, go ahead.

19 MR. HABHAB: -- real briefly. We

20 really have a great respect for Dr. Temple

21 Grandin in the work that she's done over the

22 years. We have been big proponents of her
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1 work, her kill methods as well, and her boxes

2 and her restraint units. And we really think

3 that the use of a restraint method, especially

4 if we're talking about beef, of course it's a

5 completely different process than poultry. 

6 But stunning really serves very little

7 purpose, if the procedures are done correctly.

8 MR. GIACOMINI: And has Temple

9 looked at these and -- I mean, have you worked

10 with -- has your organization worked with --

11 MR. HABHAB: We're currently

12 corresponding with Temple --

13 MR. GIACOMINI: Okay.

14 MR. HABHAB: -- because of the

15 Halal industry, to -- so that she can actually

16 see a correct, proper, authentic Halal

17 slaughter. We've been under scrutiny by -- I

18 won't say scrutiny, but we've been very

19 closely watched by USDA. I mean, it's very

20 sensitive. This whole entire industry is very

21 sensitive, especially after Westland, you

22 know, several years ago. But we have been
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1 able to very easily satisfy the curiosity of

2 any inspectors that are curious as to what --

3 if the procedures are done correctly, the

4 animals are rendered insensible extremely

5 quickly without -- there are -- have been

6 previous studies. 

7 There's an old study in '97 that

8 was done in Europe where they said there was

9 two and a half minutes of massive brain

10 activity with -- via captive bolt stunning

11 versus very limited brain activity for a

12 period of less than 30 seconds, without

13 stunning, with a proper cut. We're in the

14 process of recreating that study. I can't

15 elaborate on the university that we're working

16 with at this point in time, but basically

17 recreating that study and adding -- to

18 understand what aversion is, what brain

19 activity is, so on and so forth. 

20 But Temple has done a great amount

21 of work, and I think that's a good basis for

22 any standard that you guys are establishing. 
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1 And I hope that we can find parallels between

2 organizations and find that neither -- whether

3 -- I won't say organizations, but industry

4 segments, whether we're talking about Halal or

5 kosher or organics or whatever, that neither

6 one of us present ourselves as a barrier to

7 the industry and the consumer. That's all.

8 MR. GIACOMINI: And we don't want

9 to become a barrier for you to participate in

10 that with us, either. So any further

11 questions or comments? Go ahead, Wendy.

12 MS. FULWIDER: I just wanted to

13 say that I have discussed this with Temple,

14 and there are humane ways to do the Halal

15 slaughter. So that's really not a problem.

16 MR. GIACOMINI: So we should be

17 able to get those as this develops from the

18 discussion document, get those more concretely

19 and in acceptable format?

20 MS. FULWIDER: Yes, yes.

21 MR. GIACOMINI: Okay. I think

22 we'll be able to work this out.
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1 MR. HABHAB: Thank you.

2 MR. GIACOMINI: Thank you.

3 Okay. Will, Luis and Reg. 

4 MR. FANTLE: Joe, may I ask you to

5 shield thy ears while I adjust the mic here?

6 MR. SMILLIE: Okay.

7 MR. FANTLE: Thank you. My name

8 is Will Fantle, I'm the co-director of

9 Cornucopia Institute. Since we presented our

10 testimony on Monday, we've had another 189

11 signed letters come in from stakeholders in

12 organics around the country on the poultry

13 issue. I'm going to leave those with staff. 

14 I'm not sure that we passed around a copy of

15 the letter for the Board to review, I will do

16 that as well.

17 I've got a couple of areas that I

18 want to talk about, and I won't use up my five

19 minutes. The first area deals with testimony

20 that was provided earlier this afternoon by

21 Martek --

22 MR. GIACOMINI: Excuse me, Will. 
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1 Could we have a little order, a little more

2 order? We realize it's getting late and we're

3 all distracted. But let's try to keep down on

4 the additional discussions and give the

5 attention to the speaker.

6 MR. FANTLE: Thank you.

7 MR. GIACOMINI: Please.

8 MR. FANTLE: Earlier this

9 afternoon, there was a representative from

10 Martek Biosciences that asked for a science11 based approach as we assess the accessory

12 nutrients and in particular the DHA-ARA issue. 

13 We totally agree. We think that it's the way

14 to go, a science-based approach, and we

15 welcome that and encourage you to take that

16 approach to this issue.

17 We don't have a pony in this show,

18 a horse in this game, a dog that we're

19 backing. We don't make nutritional

20 supplements, particularly those made from soil

21 fungus or algae, so we're totally open to a

22 discussion of this and a look at this through
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1 the lens of science. And we would encourage

2 you to adopt that approach.

3 Just for the new Board members

4 that have taken their seats since January of

5 2008, when we released a report replacing

6 mother imitating human breast milk in the

7 laboratory, we included a rather detailed

8 appendix in there of peer reviewed scientific

9 studies. We'd be delighted to provide that to

10 any of the Board members who haven't seen

11 that. If not, you're certainly welcome to go

12 to our website, there's a free download there. 

13 Our lead researcher on that has advanced

14 degrees from Harvard and Tufts and she, too,

15 is interested in participating in the science16 based approach that has been asked for today.

17 The other area I'm just going to

18 briefly comment on is the poultry issue. 

19 There was a discussion today about porches. 

20 And when the decision was made by the program

21 some years ago to approve the first porch, I'd

22 like you to recall or learn or know that this
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1 decision was made without consulting with a

2 certifier reviewing the documents or

3 interviewing the inspector. We know this from

4 talking with people involved in that decision. 

5 We also conducted a FOIA to obtain documents

6 from the program to help us understand how

7 that decision was made. Again, we would be

8 delighted to share these materials with the

9 Board if there's any interest in that. And

10 we're more than willing to do that.

11 Last remark, again, those that are

12 departing from the Board, thanks for your

13 service. This is a meat grinder of a job. 

14 I've talked with former Board members and

15 current Board members about the amount of time

16 and effort and energy that's required between

17 meetings, for your committee meetings, reading

18 of documents, and we appreciate that. And

19 hopefully those that are interested that are

20 coming on the Board will still be willing to

21 do that because we know it's a lot of work. 

22 So, thank you.
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1 MR. GIACOMINI: Thank you. 

2 Questions, comments?

3 (No response.)

4 MR. GIACOMINI: Thank you for the

5 kind words, we appreciate it.

6 Luis and Reg. Reg, are you here? 

7 Reg? Gregg Stevens? I'm not sure which one

8 you are.

9 MR. STEVENS: Gregg.

10 MR. GIACOMINI: Okay. Go ahead.

11 MR. MONGE: Thank you. I'm going

12 to try to take your attention for the

13 following five minutes. My children in here

14 brought me this evening from Costa Rica. My

15 name is Luis Monge, I work with Dole. And in

16 order to express our support, the support of

17 the whole industry, to the petition presented

18 weeks ago by the company to amend the National

19 List to include gibberellic acid on their

20 205.605.

21 These bananas made the trip from

22 Ecuador to the States and this is happening
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1 every week. The main organic banana producing

2 countries for the U.S. market are Peru,

3 Ecuador and Colombia. Bananas are a

4 perishable crop, once bananas are harvested

5 they have a limited shelf life. The shipping

6 time from the tropics to the U.S. market could

7 take from 15 to 21 days depending on the

8 logistics. Some fungus and diseases have an

9 effect over the banana's natural ripening

10 process.

11 One of those fungus, by far, is

12 the main concern in this, it's the fungus

13 known as black sigatoka. Black sigatoka

14 appears during the rainy season and rainy

15 season could mean from three to six months a

16 year in the tropics. And it means a -- or the

17 black sigatoka has the effect to make the

18 bananas ripe very fast. And in order to

19 prevent the ripenings, the banana producers

20 reduce their harvest and age of the fruit and

21 the number of banana fingers per stem. It

22 means that they are reducing the weight of the
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1 stem and the yield of the plantation, and then

2 their income.

3 Quality claims during the ripening

4 -- no, quality claims due to ripeness can be

5 found all year round. Gibberellic acid, a

6 plant growth regulator found in plants, is

7 commonly used in conventional banana

8 production to prevent early ripeness problems. 

9 Gibberellic acid is applied to the cluster

10 crown to the plants' fruit and increases the

11 shelf life of the product. Applying

12 gibberellic acid will mean one week more in

13 the shelf life of the bananas.

14 Gibberellic acid is a natural

15 byproduct of the fungus, known as gibberella

16 fujikuroi. Some presentation of gibberellic

17 acid are only registered and thus allowed to

18 be used in organic production. The use of

19 gibberellic acid in banana -- in organic

20 banana processing, post-harvest, is necessary

21 to prevent one of its major quality problems,

22 early ripeness. Without the use of this
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1 substance, the producer's income is strongly

2 affected by a reduction in the plantation's

3 yield and the quality claims. The whole

4 industry is affected by a reduction in the

5 offer, the quality claims and the increase in

6 the production cost.

7 So we will see you in April when

8 the -- this issue will be hopefully on the

9 floor. Thank you.

10 MR. GIACOMINI: Joe.

11 MR. SMILLIE: You're asking for it

12 to be added as a post-harvest handling to 605?

13 MR. MONGE: Yes.

14 MR. SMILLIE: You're not asking

15 for it to be on 601?

16 MR. MONGE: No.

17 MR. SMILLIE: No?

18 MR. MONGE: No, it's already

19 considered a non-synthetic.

20 MR. SMILLIE: Okay. So it's

21 already considered non-synthetic, natural --

22 MR. MONGE: And there is a
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1 document that is found -- that can be found on

2 your database that the gibberellic acid is

3 considered as non-synthetic. 

4 MR. SMILLIE: Okay.

5 MR. MONGE: So out of the scope of

6 the National List of the program.

7 MR. SMILLIE: So you're going to

8 be requesting it to be added to 605(a)?

9 MR. MONGE: It's already allowed

10 to be used as a crop use.

11 MR. SMILLIE: Okay.

12 MR. GIACOMINI: Katrina?

13 MS. HEINZE: Thank you so much for

14 coming, and your comments. It is my turn to

15 confess that your petition got lost in the

16 Material Chair's email. So --

17 MR. MONGE: I would be happy to

18 submit it again.

19 MS. HEINZE: No, no, I found it. 

20 We will be dealing with it post-haste.

21 MR. MONGE: We're praying that we

22 will meet the 145 days requirement.
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1 MS. HEINZE: So we will see what

2 we can do, but there was some confusion about

3 which committee needed to handle it, so the

4 materials committee will be talking about it

5 at our next meeting.

6 MR. MONGE: Thank you.

7 MS. HEINZE: It's already on the

8 agenda.

9 MR. MONGE: Thank you, thank you.

10 MR. SMILLIE: Gibberella is on my

11 computer and is already slowing it down.

12 MR. GIACOMINI: Okay. 

13 MR. MONGE: May I make my final

14 comment?

15 MR. GIACOMINI: Yes.

16 MR. MONGE: I want to thank for

17 all the energy that you are putting during

18 this week on this meeting. I am maybe one of

19 the biggest fans of you guys, you can -- maybe

20 you can recognize my face because I have been

21 present several times. And you will continue

22 to see me every time I consider that this is
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1 needed, my presence here, to speak or present

2 a paper or something. 

3 Believe me, if you were trying to

4 comply with the social standards that we have

5 to comply in Latin America, you won't make it. 

6 You are working more than eight hours a day.

7 (Laughter.)

8 MR. GIACOMINI: Does that mean

9 we're invited to visit you in Costa Rica?

10 MR. MONGE: Absolutely.

11 MR. GIACOMINI: Okay.

12 MR. MONGE: Absolutely.

13 MR. GIACOMINI: Kevin.

14 MR. ENGELBERT: What purpose does

15 this serve, to give you the extended shelf

16 life that you need by applying that?

17 MR. MONGE: Well, it means that

18 you can leave the stem on the plant hanging

19 one week more. It is extremely necessary to

20 enlarge the time of the fruit on the plant in

21 order to make it grow and the thickness, the -

22 - I don't know how to explain that in English,
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1 I'm sorry. But it is extremely necessary in

2 order to increase the yields and the quality

3 also, and to avoid the early ripeness. It

4 means that when you open the container at the

5 port of destination, the bananas are still

6 green. That's what we need.

7 MR. GIACOMINI: Okay. 

8 MR. ENGELBERT: We have organic

9 bananas right now. We buy them every week

10 with no problems with quality whatsoever.

11 MR. MONGE: I brought a 14 pounds

12 of bananas this morning for you guys. I put

13 it on the desk. The problem is, this is

14 happening and this is affecting the economies

15 of the producers. In order to provide this

16 quality, the producers are sacrificing their

17 yields. It means that from one stem, maybe

18 one stem could be, let's say, eight hands. 

19 Eight hands could be -- one hand will be three

20 of them, okay? So imagine that. 

21 In order to comply with the

22 quality requirements, because the organic
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1 consumers are not accepting anything less than

2 this, okay? So in order to provide this

3 quality, the producers are cutting the stem at

4 the hub in order to provide all the clusters

5 of the hands, that we comply with this

6 quality.

7 The problem remains on, during the

8 rainy season, the plant is seriously affected

9 by funguses. It makes the -- many of the

10 leaves of the plant will die. With few leaves

11 on the plant, the stem will grow less, and it

12 is -- the mature ripening process is affected. 

13 It is shortened. So what we want to do is to

14 apply the gibberellic acid on the crown and it

15 will give the harvested fruit one week more of

16 shelf life. That is extensively proved by our

17 research department.

18 MS. BRINES: Jeff?

19 MR. MOYER: I've got to admit, I

20 guess I'm confused. If you're applying the

21 material to the ground or to the plant while

22 it is in the field, that is not a 605 item. 
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1 That would be 601, if it were synthetic. But

2 if it's already a natural, then you can

3 already do that. You don't need --

4 MR. MONGE: We apply the

5 gibberellic acid post-harvest. When this is

6 being processed, when this is being plucked.

7 MR. MOYER: I understand that. 

8 But you're not applying it post-harvest to the

9 banana. You're applying it post-harvest to

10 the soil?

11 MR. MONGE: No, to the banana. 

12 MR. MOYER: Oh, to the banana.

13 MR. MONGE: What we want to do is

14 to apply it here, in the crown, in the crown

15 of the banana, right here.

16 MR. MOYER: I'm sorry, I

17 apologize. You're applying it to the crown?

18 MR. MONGE: The crown.

19 MR. MOYER: How does that enable

20 the plant to support more fruit?

21 MR. MONGE: Sorry?

22 MR. MOYER: How does that -- 
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1 MR. ENGELBERT: It's two different

2 uses.

3 MR. MONGE: It is already allowed

4 to be used as a crop input. But we want to

5 apply post-harvest.

6 MR. MOYER: Post-harvest, to the

7 fruit? 

8 MR. MONGE: Yes.

9 MR. MOYER: Thank you.

10 MR. GIACOMINI: Okay. Thank you. 

11 Gregg.

12 MR. STEVENS: Thank you for giving

13 me the opportunity to speak. My name is Gregg

14 Stevens and I'm a new certification specialist

15 with Vermont Organic Farmers, VOF. And I'm

16 speaking on behalf of Nicole Dehne who is the

17 program administrator there. She had to leave

18 a little bit earlier today.

19 First and foremost, we all wanted

20 to thank you for your hard work in covering so

21 many important topics. And regarding the

22 apiculture standards, VOF participated on the
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1 ACA committee for apiculture regulations, and

2 generally are very supportive of this NOSB

3 recommendation. VOF currently has one

4 certified organic bee keeper that has been

5 certified to Vermont organic apiculture

6 guidelines since 2000, and it is of great

7 concern to us that the regulations for organic

8 honey and other apiculture products are

9 attainable and enforceable for all areas of

10 the United States.

11 Our current organic bee keeper has

12 hives in the northeast corner of Vermont, an

13 area that still has a great deal of

14 agricultural land and generally a low

15 population density. His forage zone is made

16 up of woodlands, hay field and some

17 residential lawns. We feel it would be an

18 unnecessary burden to ask this producer to

19 annually verify with every residential

20 property within the forage zone that they have

21 not used prohibited substances on their lawns.

22 Do they understand what prohibited
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1 substances are? Are they willing to sign an

2 affidavit stating this? Do lawns in the

3 forage zone really post a serious risk to the

4 contamination of the honey? Our producer has

5 found that neighbors were more willing to sign

6 a restraining order or a get-off-my-property

7 affidavit. Not that Vermonters aren't

8 friendly, but many people are suspect to

9 having to sign off on a document such as that.

10 There is suggested language in

11 VOF's written comments that have already been

12 given, that could be considered for a

13 compromise, or perhaps requirements for

14 affidavits from land owners could be limited

15 only to those land owners who grow crops on

16 their land that can be expected to

17 significantly impact the bees. We recommend

18 the Board give certifiers the ability to make

19 decisions about risks in the forage zone that

20 may need to be evaluated on a case-by-case

21 basis. These potential risks can then be

22 mitigated by testing apiculture products for
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1 chemical contamination.

2 In addition, it should be noted

3 that, although the original NOSB

4 recommendation required a four-mile radius

5 from the hive, it also had an allowance for

6 some non-organic land within that forage zone. 

7 Of course, the plants from which the bees

8 collect pollen are important, it's what makes

9 them organic, but the forage zone is not

10 everything. Of course, standards for organic

11 apiculture products should be strict,

12 especially when it comes to hive management. 

13 Organic bee keepers differ greatly from their

14 conventional counterparts when it comes to the

15 pesticides that are used to treat the hives. 

16 Let's put the focus on -- put less focus on

17 the forage zone and more focus on the things

18 we can control.

19 And that concludes these written

20 remarks.

21 MR. GIACOMINI: Questions or

22 comments? Kevin.
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1 MR. ENGELBERT: I spoke with a

2 certifier from MOSA this afternoon, and they

3 have a bee producer there that they certify

4 that has 47 residential neighbors that they

5 get an affidavit from. Does -- and have no

6 problem with it. How many does your producer

7 have?

8 MR. STEVENS: I don't know.

9 MR. GIACOMINI: Questions,

10 comments?

11 (No response.)

12 MR. GIACOMINI: Thank you. We

13 lost you, Lisa. What's the next one?

14 MS. BRINES: Stefan Hauke.

15 MR. GIACOMINI: Stefan, please.

16 MR. HAUKE: Good afternoon,

17 everybody. I need to correct that a little

18 bit. My name is Stefan Hauke, but I'm of

19 Hauke Consulting, which is a consulting firm,

20 and we have international companies to come

21 into the organic market here in the United

22 States. Lammsbrau happens to be one of my
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1 clients. 

2 I will just give you a little bit

3 of a background. Lammsbrau is a organic

4 brewery, the brewery is 230 -- 280 years old,

5 and they've been brewing organically since the

6 '70s, and they are certified organic since

7 1992 and they are at the forefront of organic

8 brewing in Europe, certainly in Germany. So

9 they have a lot of stake in the organic

10 processes.

11 Lammsbrau is available in the U.S.

12 for two years now. I guess they started in

13 2008 to export here. And we were at the show,

14 at the trade show, the Expo East a couple of

15 weeks ago, and we had a few attendees from the

16 show coming to us to ask the brewery about the

17 opinion on the organic hop petition.

18 Well, you know, we didn't want to

19 give the opinion there, so we decided to wait

20 a little bit and, you know, work on it and

21 give you an official opinion. And I'm very

22 glad that we were allowed to actually do that. 
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1 So we provided written opinion, which is right

2 here, five pages to read. So if you have some

3 time, I encourage you to do that. And I just

4 want to quickly summarize what the opinion of

5 the brewery is. Again, that is the leading

6 German or leading European organic brewery.

7 Now the opening statement of that

8 letter, and I'm just reading that for you, we

9 are concerned that the NOSB handling committee

10 recent recommendation to keep hops on the

11 National List until January 2013 unnecessarily

12 prolongs consumer confusion, continues to

13 damage the integrity of the organic beer

14 category as well as the USDA organic seal, and

15 unnecessarily inhibits the growth of organic

16 hop acreage. Furthermore, breweries selling

17 organic beers made with conventional hops have

18 enjoyed a substantial and unfair trade

19 advantage for three years at the cost of

20 breweries that choose to use organic

21 agricultural ingredients exclusively.

22 The current recommendation of the
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1 handling committee will prolong this

2 unjustified trade advantage for another two

3 years, penalizing breweries who support

4 organic hop growers, the organic beer category

5 and the integrity of the National Organic

6 Program by using exclusively organic

7 agricultural ingredients in their organic

8 beers.

9 And I just want to give you --

10 it's a long document, I don't know if you have

11 time to read that, but I just want to give you

12 some key points the brewery believes are true. 

13 Lammsbrau believes that the petitioner made a

14 compelling case that a wide variety and a

15 sufficient quantity of good qualities hops are

16 available. Lammsbrau concurs that it is

17 unreasonable to expect that all hundreds of

18 hop varieties should be available in organic

19 farms. Lammsbrau concurs that for most beer

20 styles, there are good organic hop substitutes

21 available. 

22 Lammsbrau believes that the
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1 breweries serious about developing and brewing

2 truly organic beers from organic hops will be

3 able to do so with the organic hop varieties

4 available in the market as proven by breweries

5 which already make organic beers of very

6 different styles with organic hops.

7 Lammsbrau, and that is very

8 important to the brewery -- Lammsbrau believes

9 that consumers have the right to know if an

10 organic product is made exclusively with

11 organic agricultural ingredients. Since beer

12 is not required to provide ingredient

13 information -- and no beer does, pretty much -

14 - on the label, consumers have no way to know

15 if a organic labeled beer is made with organic

16 or with conventional hops. This, in

17 Lammsbrau's opinion, is very problematic. 

18 Many consumers buy organic foods to avoid

19 pesticides and other chemical processing

20 agents. The consumer enjoying an organic21 labeled beer has no way to know if she

22 consumes ingredients she actually wanted to
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1 avoid in the first place by choosing organic.

2 Lammsbrau believes that beers made

3 from organic grains and with conventional hops

4 have a place in the market, and that place is

5 made with organic, whatever the grain might

6 be. This is already there and that could be

7 used. Lammsbrau is also concerned about the

8 public trust in organic beer and the integrity

9 of the USDA organic seal. Beer in its most

10 simple form is made from two agricultural

11 ingredients; malt and hops, plus water and

12 yeast. Lammsbrau is concerned that the

13 public, if it would become wide knowledge,

14 would have a hard time to accept that a beer

15 can be labeled organic if one of the two

16 agricultural elements was grown

17 conventionally.

18 And I just want to read to you the

19 last sentence of the letter, and then I'm

20 finished. We believe -- and that again is the

21 brewery. We believe that every additional day

22 hops remains on the list harms the integrity
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1 of the National Organic Program, causes

2 consumer confusion and distrust, inhibits the

3 growth of organic hop acreage and promotes

4 brewers using conventional hops at the expense

5 of brewers using organic hops. For these

6 reasons, we support the petition of the

7 American Organic Hop Growers Association to

8 remove hops from the National List.

9 And that is signed by Susanne

10 Horne, who is the general manager of the

11 brewery. Thank you.

12 MR. GIACOMINI: Thank you. 

13 Comments and questions? Joe.

14 MR. SMILLIE: You make great beer.

15 MR. HAUKE: Thank you.

16 MR. SMILLIE: No question about

17 it.

18 MR. HAUKE: And everybody is

19 invited to visit the brewery when you are in

20 Germany. It's very close by. Twenty miles.

21 MR. SMILLIE: We have reached, we

22 think, a solution that is a win/win for
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1 everybody, and I really urge your company to

2 really promote and market its use of organic

3 hops for all these years. That's, you know,

4 a marketing advantage that you have over the

5 people who don't use organic hops, and you are

6 allowed to do that in the romance language,

7 and even on the ingredient panel, as I

8 understand the U.S. of A. So I think that's

9 the benefit that you can go forward with in

10 the marketing department. 

11 But I think we have reached our

12 recommendation for January of 2013, I think

13 has been fairly well accepted by everyone, and

14 --

15 MR. HAUKE: Well the brewery

16 accepts the compromise and the brewery doesn't

17 necessarily like it. And this is, you know,

18 what the reasons the brewery thinks that's not

19 the case. But again, you know, that is the

20 comment of the brewery, which is the leading

21 organic brewery in Germany, and probably in

22 the world.
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1 MR. SMILLIE: Thank you.

2 MR. GIACOMINI: Thank you. Any

3 other questions?

4 (No response.)

5 MR. GIACOMINI: Okay folks, thank

6 you very much. And we're done.

7 (Whereupon, the above-entitled

8 matter was concluded at 6:59 p.m.)

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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A

Aaron 179:6 186:8

206:21,22 211:12

Abbott 10:14

Abel-Caines

467:10,11 472:6

aberrant 99:7

102:16

abide 134:3

ability 87:2 174:10

266:7 311:9 325:3

340:20 341:11

342:9 461:13

511:18

able 7:6 12:4 20:12

20:18 32:11 68:2

72:14 84:12

120:20 153:14

161:5,11 176:13

179:1 185:6

195:19 196:5

259:17 261:17

279:18,19 298:16

335:9 373:1

382:16 391:17

409:4 410:11

415:12 427:12

446:11 450:14

474:18 493:1

494:17,22 517:3

abnormal 181:3

above-entitled

85:15 155:10

244:13 343:5

433:8 521:7

absence 84:2,14

absolute 181:21

430:21

absolutely 18:20

81:6 163:15 251:1

278:10 282:13

283:14 313:4

316:14 372:2

377:20 505:10,12

absorb 237:3

absurd 398:6

abuse 376:22

abuses 421:12

ACA 61:20 207:3

338:8 510:1

academic 9:10

Academy 10:4

17:14

ACAs 54:19 61:17

61:17 346:12,17

ACA's 318:3

accept 263:8

401:21 518:14

acceptability 76:7

227:7

acceptable 120:12

120:16 183:13

188:8 231:18

339:20 421:8

460:22 494:19

acceptance 226:3

accepted 200:8,22

311:4 383:3

520:13

accepting 507:1

accepts 520:16

access 31:15 54:9

75:12 97:6 100:2

101:17 106:5

118:12 132:22

133:20 140:21,21

141:6,10 225:1,19

225:20 226:2,8,12

227:3,13,17,19

229:14 231:18

232:9 249:22

253:11 254:9,19

294:11 297:11,13

297:15 298:8

339:18 392:6

395:17 404:7,14

404:15 405:4,5,18

435:21 437:16

438:1 439:19

445:20 447:1

448:4 450:16

451:2 473:8 475:8

475:10 476:6,15

476:20

accessing 141:12

accessory 7:22 14:8

15:16 16:3,12

17:5 18:4 173:20

496:11

accommodate

490:21

accompanying

24:22

accomplish 4:13

accomplished

304:1

account 328:3

accredited 54:19

accumulates 93:2

accumulating

313:3

accuracy 342:15

accurate 148:9

322:4

accurately 340:7

accused 409:9

accustomed 304:7

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achievable 292:2

achieve 119:14

182:15 471:18,22

achieved 75:4 76:3

124:20 217:11

295:3 474:21

achieving 280:1

456:13

acid 37:12 41:7,13

41:21 44:5 81:8

91:22 93:5 198:16

198:16,20 207:7

223:7 240:16

265:6,15,21 266:2

266:16 267:13

268:13,19 269:3

269:19 272:13,16

275:17 278:14

324:8 325:12

328:5,15 499:19

501:5,9,12,14,17

501:19 503:2

507:14 508:5

acidity 279:4

acids 81:11 89:7

273:2 274:13

275:17

acknowledged

148:4

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122:20 181:22

acknowledging

285:20

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36:8 179:14 386:6

acquire 333:10

334:21

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290:16

acreage 308:19

515:16 519:3

acres 99:20 100:3,3

100:21 247:16

347:2

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261:4 378:8 388:8

491:12,14

acting 420:20

action 15:19 25:10

89:4 138:3 309:13

321:17 340:18

341:22 386:2

389:5,19 397:9

423:1,9 429:20

430:13 449:6

470:11

actionable 389:21

activate 426:18,21

active 63:12,17

183:7,8 214:6

265:21 268:12

269:10,12 270:15

271:1,2,6,22

277:16,22 278:15

325:21 367:7,11

368:12 380:14,18

activists 447:17,21

447:21 448:7

450:10 451:10

452:4

activities 100:9

226:7

activity 254:10

270:3 275:14

284:16,21 285:9

493:10,11,19

actual 40:8 181:1

247:15 281:6

323:16 383:10

acutely 22:7

add 15:2 59:12

89:18 117:12

139:17 140:5

157:10 161:16

163:2,3 189:2

206:10 273:10

296:12 366:1

399:11 424:10

added 8:11 28:2

37:12 39:1,2 44:6

106:13 107:6,6

108:3 109:2,3

110:7 112:7

113:12 134:14

142:17 259:5

260:9,13 261:21

265:7,18,19

267:14 270:11

271:7 273:13

278:12 281:15

295:11 296:7,7

302:22 303:7,17

304:2,12 306:5

314:12,14 315:18

327:4 366:21

381:19,21 382:4

502:12 503:8

adding 10:1,16

16:3 44:13 74:19

109:12 147:2

207:7 302:7

387:21 419:13

493:17

addition 25:19 26:4

41:12 75:22 91:15

271:1 277:8 296:8

299:4 338:21
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512:2

additional 14:13

50:1,13 70:12

177:13 214:17

234:15 293:15

295:10 297:4,7

390:13 489:2

496:4 518:21

Additionally

117:14 119:3

additions 21:5 25:1

108:21

additives 8:15,22

12:15,20 239:7

305:6

address 21:18

22:11 57:13 58:3

61:14 123:4 170:2

170:8 221:5 227:9

227:10 255:11

292:11 294:7

343:22 346:6

376:11 458:11,14

487:8

addressed 86:19

132:10 149:20

156:7 436:2

470:21

addresses 149:16

addressing 294:10

373:22 392:8

adds 139:18 197:20

214:17

adequate 58:8

117:20 125:1

438:21 469:18,19

adequately 31:8,9

240:12 424:19

440:20

adhere 262:15

adheres 297:2

Adhesive 256:9

Adjourn 3:22

adjust 6:1 495:5

adjusted 198:15

214:10 480:16,20

adjustments

221:10 354:2

Administered

216:18

Administration

2:20

administrator 2:8

58:13 402:19

509:17

admirable 51:7

admire 226:6

admit 507:19

Admittedly 189:2

adopt 143:10

286:17 293:6

362:7 497:2

adopted 143:14

292:16 359:19

adopting 118:8

309:14

adoption 90:16

293:12

adopts 293:8

adult 112:9

adulteration

107:20 109:9

advance 58:8 216:2

advanced 110:22

217:10 317:20

497:13

advances 111:5

advantage 475:18

515:19 516:2

520:4

adverse 8:14 13:8

20:4 125:9 370:2

370:6,17

adversely 300:18

advertising 72:5

228:20

advice 63:3 363:20

364:17

advised 221:20

Advisor 2:16

advisory 91:1

319:20 324:13

348:10,15,21,22

349:2

advocacy 414:22

advocate 373:13

advocating 375:15

AE 439:13

aerobic 192:7

affect 81:22 300:18

461:13

affidavit 511:2,7

513:5

affidavits 511:14

affiliated 404:2

affirm 317:13

afford 67:20 83:8

afforded 95:14

afraid 161:10

411:13

afternoon 4:21

56:20 220:20

300:6 306:15

316:19 332:13

337:9 384:6

391:20 396:11

403:14 434:4

441:11 464:3

495:20 496:9

513:2,16

afterward 166:10

301:6

age 105:20 127:8

128:10 410:4

436:16 437:16

438:2,16,22 439:4

439:7,9 473:4

481:10 500:20

agencies 54:19

226:21 318:4

411:10,14 478:5

agency 482:2 483:7

agenda 4:14 170:4

237:8,10 504:8

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benefit 255:18,18

295:18 436:12

454:18 474:4,4

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benefits 10:15

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250:17 374:11

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BER 38:5

best 1:10 7:12

26:18 108:9 262:4

271:22 339:7

363:22 364:5,15

373:11 390:11

391:2,6 420:4,13

423:14 428:5

429:11 430:21

440:1 453:16,20

454:18 469:13

bet 247:7,7 374:21

483:21

Beth 156:2 164:7

169:9,11,13

175:15 178:5

Beth's 177:18

better 61:20 83:9

83:14 91:6,10

116:7 139:14

166:20 170:9

185:1 211:3

260:15 301:15

329:6 413:9,18

423:15 426:3

438:8 456:14

458:17 476:1,2

betting 271:16

beverage 23:7

261:9 301:10

Beyerlein 9:17

Beyers 218:11

beyond 24:2

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357:15 431:7

bias 178:12

biased 118:2

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bid 338:1 444:15

bifenthrin 204:5,8

204:11,15

big 33:19 230:5,6,7

246:10 248:6

255:15 267:19

331:13 398:8

400:16 405:17

480:1,4 482:14

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bigger 19:5 406:16

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bill 159:12 186:9

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billing 48:13

billions 420:3

bins 38:20 45:10

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bio 29:12 408:7

biocide 448:17

biodegradable

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biodegrades 93:1

biologic 285:9

biological 284:15

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biologically 306:18

Biosciences 8:10

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biotech 30:9

bio-available 256:4

bio-herbicide

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bio-security 227:15

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bird 97:14,16 102:5

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117:10 181:21

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birds 97:5 99:8,16

99:19 100:4,6,22

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117:20 118:5

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181:14,17 183:1

231:3 291:12

297:13,22 298:11

298:16 404:19

437:19 438:9,14

438:18 439:19

440:1,10,21 442:4

442:8 443:22

445:1,4,20 446:1

446:7 447:1

475:10,11

Bis 275:22 279:22

283:11 284:2

285:18 286:17

287:21

bit 20:13 42:16

43:1 115:20 138:5

165:8 166:11

169:18 180:13

202:4 229:7

239:22 268:10

321:13 342:21

350:18 359:12

378:13 382:15,17

417:6,12 464:22

465:19 478:10

509:18 513:18

514:2,20

bite 58:21 96:15

black 239:14 399:7

500:13,13,17

blacktop 443:5

bleaching 369:9

bleed 117:20

blended 195:6

blessing 406:17

blew 376:8

Blind 215:22

bludgeoning

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blunt 486:18

board 1:5,10 4:5,17

5:17 7:3 19:18

20:18 26:12 27:1

27:22 29:22 36:8

36:16,21 44:8,10

46:9 47:3,10,19

48:18 49:16 50:4

50:22 51:3,5,8,17

51:22 57:8 62:5

63:1,11,21 64:2

67:1 76:4,9 79:13

82:12 85:19 86:14

86:15 87:3 88:19

93:15 95:19 122:6

122:11,17 123:5

127:21,22 128:3,6

128:11 135:18

136:3 137:4,9

138:4,19 146:15

153:8 155:14

156:7,16,17,20

158:11 159:2,6

171:3,3 180:3,5,9

184:22 188:18

196:18 197:2,10

197:19 198:12,19

200:5,14,14 201:2

225:12 226:7

229:14 233:7

235:12,20 236:7

236:13,15,16,18

236:22 237:7,18

237:21 238:9

240:10 241:4

245:3 249:9 257:8

282:16 294:7

300:2 308:6,7

311:3 314:8

316:13,22 331:4,6

331:19 343:8,19

344:3 348:14,22

349:2 353:7,18

360:6 363:8,22

385:7,12 387:17

387:18 392:8

396:14,19 416:4

416:18 418:18

419:12 422:15

424:15,22 427:18

428:1 430:12

432:5 433:11

434:4 437:6 453:6

455:4,7 456:2,3

461:19 462:21

464:8 470:22

471:6 485:14

486:2 491:11

495:15 497:3,10

498:9,12,14,15,20

511:18

boards 63:22,22

169:1,2 172:2,2

232:11 256:14

374:10 375:11

Board's 35:3 76:15

237:5 241:1 385:3

Bob 459:20 462:4,8

bodies 466:4,8,11

466:16,20

body 30:22 34:20

75:3 80:13 143:17

143:18 144:2

152:17,20 214:13

303:4,9 339:21

340:4,5,6 341:20

426:11 468:13

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boiled 107:11

bold 140:7

bolt 486:19 487:1

493:10

bolus 214:6,9,12,19

217:1 219:3,11,11

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bond 268:21

270:21 465:12

bonds 264:1 268:14

269:1,4 270:3

272:2 275:10,12

275:12,14,15,16

277:2,12 279:20

280:1 281:15,18

282:18,21 284:6,8

284:18,21,22

285:12 324:9,21

327:10 465:5,6,8

465:9,10,13

book 408:12

books 50:6

boosting 438:19

Born 116:11

borne 61:17

Boston 167:12

231:1

bother 172:8 457:9

bothers 306:2

443:3

bottle 13:18 160:21

303:19,20

bottles 160:5

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bottling 111:2

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bottom 195:19

282:4 463:8

bought 13:8 133:9

160:9

bound 284:18,19

411:8

bovine 29:11

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bovines 290:9

box 144:21

boxes 492:1

brain 493:9,11,18

brand 373:16

393:4,4,14,22

394:21 395:6,22

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branding 144:7

Brandt 378:11

384:5 391:18,20

391:21

bratwurst 452:5

brave 144:14

Bravo 62:12

Brazil 209:16

breach 305:13

Bread 142:21,22

breadth 23:5

break 3:18 74:8,9

85:13 154:17,17

235:8 244:7 277:2

279:19 281:15,18

322:9 343:2

380:15 433:1

435:7 436:3,3

breakage 268:21

280:1

breakdown 324:18

324:19

breakfast 166:3

breaking 268:14

269:1,4 282:18,20

334:6

breaks 264:1

266:17 275:10,13

breast 497:6

breed 98:18 105:6
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brewer 29:20

breweries 72:7

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brewery 34:13

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515:6 516:12

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519:11,19 520:15

520:16,18,20,21

brewing 59:7

245:18,19 248:6,7

514:5,8 517:1

bribing 252:9

Bridges 64:11

brief 67:14 106:14

107:1 169:15

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briefly 20:17

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bright 375:1

Brin 179:7 206:22

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BRINES 2:13

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358:2 462:9,11

477:21 507:18

513:14

bring 4:3 18:10

24:13 26:11,21

31:3 50:15 64:3

222:14 225:11

267:10,17 280:14

344:21 348:18

351:11 410:13

430:19 437:10

443:20 469:17

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bringing 69:18

110:8 141:15

151:19 158:15

275:22 324:2

360:3 414:1

brings 248:14

Britain 65:12

broad 76:10 82:11

296:20 313:16

344:1,11 351:11

479:18

broiler 294:13

295:6

broilers 181:12,15

broken 239:4 270:4

272:2 277:12

465:13,13

broker 64:12

310:15 312:21

333:4,6,10,15

335:2 336:14

brokering 332:20

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brokers 310:11

334:3,14 335:5,12

335:17 336:4

bronchitis 439:5

brought 8:7 15:11

28:17 30:9 50:3

71:5 96:20 133:3

157:19 172:13

173:16 200:13

206:2 222:6,7,18

244:4 322:6

347:18 361:16

378:9 436:21

481:16 499:14

506:11

Brown 2:21 382:18

BROWN-ROSEN

382:18

Bruce 213:16 220:7

220:7,8,9,18,22

Brunei 487:15

bubble 394:18

Buckwalter 391:19

396:9 403:14,15

414:16 434:2

441:8,10,11,15

447:4

budgets 379:4

buffered 279:17

bugs 254:20

build 147:11

299:15 438:17,20

439:22

building 97:17

127:1

built 192:18 345:11

389:11 484:9

bulk 40:2 325:10

328:17 386:16,16

417:2

bullet 39:6 430:15

bulletin 90:8

bunch 102:22

152:7 193:21

463:21

Bunin 384:6,7

burden 61:17

309:19 419:11

510:18

Bureau 300:11

burn 330:17

burner 27:14

burning 107:14

burrow 166:11

burrows 166:13

bursts 394:18

Busch 29:19 33:17

33:19,21 34:12,18

35:1 86:21

business 22:17 32:4

32:11 63:14 87:7

156:22 162:2

191:21 192:18

195:1 237:3 258:5

259:11 262:8

294:14 302:1

379:17 381:16

393:1,12,13

416:13 443:8

444:17 445:11

butt 236:1

button 265:16,17

buy 10:10 134:12

210:11 253:21

254:8 257:22

274:2 287:21

296:4 303:15

304:21 305:1

394:3 404:4 506:9

517:18

buyer 133:10

buying 101:8 109:7

132:15 305:12

335:1 336:14

405:21

buzzer 115:18,21

318:21

bypass 12:21

byproduct 141:19

349:5 352:4,6

375:4 501:15

byproducts 352:8

b-e 337:12

C

c 144:12 285:4

374:5

CACC 39:13 310:9

Cadbury 256:21

CADOUX 245:15

248:10,22

CAFO 289:14

CAFOs 290:10

CAFO-trained

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cage 446:15 473:16

cage-free 406:4

443:11 444:14,16

446:18

cake 242:5

Cal 381:4

calculated 222:1

481:5,9

calculation 242:6

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calculations 54:11

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California 53:5

100:14 125:17

136:16 156:13,15

159:7 187:9 195:3

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301:21 439:16

call 3:13 72:14

96:12 99:4 186:19

225:2 398:6

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479:16

called 23:8 49:2

83:10 142:7

188:22 216:15

225:14 264:21

265:3 278:11

365:18 408:12

414:20 430:18

454:7,7,13 468:14

calling 41:4 152:15

152:19 338:11

calls 66:15,16

236:17

calving 215:17,20

218:16

camera 117:16

Cameron 356:2

365:7,10 372:21

378:6,10 464:3

campaign 152:12

Canada 29:8 208:1

217:8 397:17

cannibalism 97:8

103:11

canvass 183:17

capability 272:17

capable 268:13

269:1
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capacity 35:17

448:20

Captain 142:19

caption 267:11

280:14,20

captive 486:19

487:1 493:10

captured 358:8

Capulet 375:17

Capulets 376:3

car 295:22

carbon 369:19

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carbon-to-carbon

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carbon-to-nitrog...

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card 127:4 435:8

care 18:12,13 19:2

118:4 130:8,17

131:3 132:20

140:18 143:4,6,11

143:17 144:2,9

151:19 152:17,20

239:7 297:8 369:9

405:22 406:1

413:6 437:20

453:13 486:5

cared 130:18

careful 127:19

262:15

carefully 140:20

141:1 370:22

cares 477:4

Cargill 256:21

caring 130:19

carpet 156:8

carriers 62:14

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carrot 163:17

carrots 152:7,13

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carry 40:3 260:18

261:10,15 300:20

cart 357:11

carton 254:16

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cartons 228:20

254:7

CAS 89:13

case 24:6 25:8 59:4

77:9 83:4 109:21

157:14 192:14

215:19 268:2

300:21 305:15

312:21 367:18

387:3 413:17

419:17,17 440:11

456:12 462:18

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484:13 516:14

520:19

cases 83:5 84:13

157:13 261:12

334:6,8 335:1,4

case-by 387:2

case-by-case 457:6

511:20

cash 40:18 445:11

casings 452:6,20

454:2

cask 110:6

casual 189:20

catch 251:19

catches 326:10

catching 299:5

categorically

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categories 83:3

151:12 239:4,5

289:4 421:12

category 27:5

40:16 77:22 114:5

150:16 163:8

238:10 307:14

388:2 515:14

516:4

Cato 107:10

cattle 75:2 80:14,15

290:14 392:15

468:11

caught 120:1

135:12 348:6

382:15

cause 43:13 113:12

125:19 213:4

216:3 240:10

253:11 267:22

287:2 321:22

448:21

caused 90:14

390:10

causes 285:7

321:21 519:1

causing 13:7 76:13

324:9,16,18,19

328:16

caution 136:8,11

caveats 387:21

391:9

CCOF 71:1

cell 256:3

censor 87:15 88:3

center 22:17 52:5

52:11 139:3 165:2

217:1 384:8,16

416:21 450:6

centers 482:14

central 95:16

209:16 221:2

cents 247:15

Cereal 142:20

certain 96:11

123:13 129:4

157:16 177:1

230:18 253:17

292:3,4 304:11

305:5 404:22

438:11 474:7

491:13

certainly 20:5 24:1

35:15 83:1 85:22

87:4,15,19 88:2

92:18 150:1,20

180:4 184:7

185:11 243:3

315:2,5 324:17,19

336:12 358:8

372:4,6 375:7

391:8,15 497:11

514:8

certificate 333:4,10

334:9,12 335:6,13

certification 53:16

55:15,19 61:15

69:10 78:9 116:10

116:13 120:18

162:18 200:8

243:5 296:6,8,11

296:13 307:10,16

309:7 332:14

334:14,22 335:8

336:4,13 347:7

478:4 482:2 483:7

509:14

certified 22:2 23:1

23:5,6,21 24:16

25:3 39:14 58:22

59:1,2 65:7 67:17

91:17 94:8 113:10

116:21 119:2

131:20 134:13

139:1,2,17 145:10

150:2 156:11,12

160:9,18 162:11

167:5 222:5,6,8

240:6 246:2

249:14 296:9

307:6,12,21

310:12,14,18,18

332:16,19 333:5,6

333:11 334:2

335:17,21 336:9

351:18 394:4

400:11,13,15

411:10 473:19,21

474:7 476:6 477:3

510:4,5 514:6

certifier 54:19

61:20 116:18

156:15 200:12

208:11 212:5,11

213:7 373:11

446:9 452:18

498:2 513:2

certifiers 52:14

54:20 55:6 66:16

118:19 120:17,20

123:10,16 124:6

140:8 147:22

200:20 221:17

239:9,9 314:1

340:21 341:9

376:7,17 383:3

446:4 470:5

482:13 484:7

511:18

certifier's 22:22

446:7

certify 446:4 513:3

certifying 53:22

225:7 227:19,20

cetera 237:8,8

280:18 488:21

CFR 17:8 171:9

188:15 311:5

313:20

CFS 384:9 385:14

386:4 388:19

CFS's 384:15

chain 76:13 139:1

143:9 444:17

452:15

chains 284:18

chair 12:6 17:21

36:6 57:7,14 63:9

82:19 88:7 115:16

115:22 137:1

138:8 226:10

235:11,22 362:20

chaired 37:18 57:6

Chairman 1:12,15

10:22 138:18

156:19 162:7

338:20 372:18

434:4

Chairman's 177:18

Chair's 503:16

challenge 97:2 99:2

challenged 58:12

247:14 440:22

challenges 91:16

226:20 236:5

418:13

challenging 486:13
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champions 356:1

chance 95:14,17

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chances 95:7

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change 5:12,20,21

6:5,10 7:14 16:19

17:2 25:1 26:4

33:4 37:4 39:5,7

47:6 62:3 66:4

71:16 74:14 76:11

79:16 82:9 97:19

131:15 135:7

151:14 174:1,19

175:5 200:9 259:2

259:6 267:22

270:20 283:2,11

284:4 285:8

286:21 321:19

322:6 323:7 339:2

358:11,15,19,20

361:17 380:12

400:18 428:2,22

429:12,14 436:15

437:15 451:11

453:8 457:16

465:15 468:7

changed 34:7 39:15

99:5 261:19

341:22 342:2,4,17

347:15 391:17

411:9 429:15

changes 37:22

161:5 174:20

237:5 285:13

338:18 354:2

380:9,10 381:8

386:19 402:11

436:4 465:14

changing 109:15

178:1 290:1

352:15 460:15

character 109:16

465:15

characterization

42:13

characterize 194:4

421:4,11 424:5

characterized

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charge 130:18,22

131:14 173:13

357:5 363:22

437:17,20

charged 320:17

Charlotte 6:17

7:19 10:18 17:21

20:9

Charlotte's 6:20

chart 310:21

315:11 471:14

charts 124:10

221:6 289:21

357:4

chase 147:20

Chauvet 110:15

cheap 445:5

cheapest 400:22

checking 66:16

checklist 56:3

123:22

checklists 56:1

cheers 36:17

cheese 131:14

253:7 272:18

cheeses 266:5,6

chelater 366:1

chelaters 366:4,5,8

366:12 368:2,4,15

368:18,20 369:7

chemical 37:3,4,5,7

76:11 79:16 81:3

81:4,9,10,18 82:9

160:20 267:22

270:20 283:2,11

284:3,12,22

286:21 321:18

322:6 323:7

326:11 330:7

358:12,15,19,20

361:17 385:6

386:19 512:1

517:19

chemically 358:10

chemicals 210:5

301:13 304:2

305:6 426:1

chemistry 111:3,7

157:18 268:19,22

270:18 271:18

285:5 286:14

317:22 329:18

358:17 368:18

369:21 380:6

385:10

chemists 270:8

284:10,11

Cheney 249:5,7,7

251:4,10,15,18

252:8

cherry 51:4

chicken 99:4 132:8

132:21 231:12

254:7,14,17

296:19 395:9

488:20

chickens 32:2,18

95:20 102:1

140:19 253:19

254:2,6 394:3,6

394:15 405:6

chicks 181:15

402:16

Chico 302:4

chief 263:6

childhood 19:20

children 122:1

256:5 394:5

476:12 499:13

chime 456:9

China 115:6

167:22

chip 163:5

chlorine 223:2,13

240:16

chock 18:19

chocolate 144:21

155:18,19 256:6

choice 71:22

363:22 364:5

476:13

choices 83:7 134:11

choose 54:20,21

77:7 196:18 250:4

261:17 395:18

474:8 475:3 482:1

515:20

choosing 13:22

518:1

chopped 31:11

330:10

chose 475:3

chosen 39:21

Chris 288:13

459:20 462:3,4,4

Christiansen

436:18 437:5

440:4,14 441:7

Christopher

258:15 263:3

288:11

chromium 311:22

church 117:15

CIA 86:2,3

circles 264:20

circulated 45:13

50:4

circumstances

277:11 471:12

472:4

citations 46:14

citizens 159:13

citrus 198:15

City 231:1

claim 39:14 40:7

146:22 149:4,16

150:4,7,8 161:6

241:18,19,20

242:2,9,18 307:20

308:3

claimed 103:13

claiming 383:2

claims 39:19 61:21

296:1 501:3,4

502:3,5

clamoring 61:6

clarification 74:15

120:5 176:15,17

195:8 203:10

238:13,15 241:13

311:8 316:6

320:11 332:17

341:18 417:7,13

425:4 486:22

clarified 120:13

172:19 203:14

404:9

clarifies 424:11

clarify 16:1,15

120:11 308:8

310:16 313:19

336:18 351:14

424:14 425:2

465:18

clarifying 16:9

149:3 205:6

352:18 383:7

404:13

clarity 76:6 82:7

123:10 135:19

137:9 172:14,18

179:22 338:7

339:19

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coyotes 167:10

co-chair 27:3

co-chaired 362:20

co-director 495:8

co-mingling 38:8

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co-op 129:15

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co-ops 143:13

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crafting 424:8

cram 445:4

crammed 394:16

crappy 163:5

crate 254:14

crazy 24:11 102:8

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create 7:1 97:13

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137:9 191:13

193:10 195:22

200:18 257:17,18

295:14 325:22

346:16 399:7

453:1 456:11

created 283:11

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creating 8:22 39:13

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credential 350:17

credibility 419:3

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credit 153:1

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creditor 124:2

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crew 131:14

cringing 147:22

criteria 127:7

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292:21 345:4

360:21 361:18

364:11 374:9

486:17 488:9,15

critical 121:16

128:18 237:13

238:12 289:2,16

344:16 346:9

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crop 54:15 55:3,16

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119:17 169:13

187:2,5 188:8

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204:20 207:15

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348:21 360:14

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157:17 204:15,18

205:14 221:3

317:17 324:14

329:15 348:20

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372:4 479:8

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crosses 239:5

crowding 130:14

crown 501:10

507:14 508:14,14

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crucial 237:15

crude 182:19

Crunch 142:19

crushed 107:13

crux 374:4

CSL 43:10 81:21

194:22 206:2

263:10 314:13

319:21 322:3,13

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cultivated 60:20

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culture 266:4,8

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129:16 178:2

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305:3 308:13

312:15 324:4

326:6 332:22

334:12 337:18

344:20 345:16

346:4 347:8

348:17 349:17

353:2,4 356:6

357:3,9,17 358:18

377:14 383:9

399:15,15 404:6

408:21 409:16

417:17 418:14

420:10 423:7

435:18 436:1

473:20 475:19,22

491:20 492:2,6

494:15 511:3

520:1,2

realm 398:6

reared 333:2

reason 26:17 92:10

174:9 181:18

192:16,17 199:9

210:10 265:2

276:18 278:10

279:22 328:11

363:9 380:19

405:17 459:4

468:19 474:13

reasonable 124:13

208:1 211:7 230:8

347:11 395:19

404:22

reasonableness

208:18

reasonably 84:3

311:11 370:13

405:11

reasons 68:10

151:7 367:16

393:18 404:14

474:12 519:6

520:18

reassessing 382:21

reassuring 35:5

recall 34:22 497:22

receive 53:17 128:1

received 49:13,13

124:5 189:5 314:9

314:11 327:1

342:20 366:17

367:5 486:21

receiver 217:3

receivers 214:14,22

217:4

receives 266:11,11
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receiving 129:16

recessing 433:5

recognition 181:4

353:22 385:15

430:3

recognize 121:21

124:22 125:8

128:15 309:16

312:6 395:14

409:4 410:11

449:6 504:20

recognized 53:1

57:14 63:9 112:9

231:10 338:16

379:1

recognizes 308:20

309:2

recommend 73:21

110:9 127:3

146:19 290:1

291:21 360:11

387:18 422:7

511:17

recommendation

16:10 24:10 27:6

41:3 42:15 47:19

62:16 69:4,7,16

69:22 70:4 71:17

74:17 75:11 77:2

84:6 123:12 139:6

144:9 146:20

149:2,8,12,22

170:20,22 172:6,9

172:14,18 174:18

177:20,21,22

207:6 221:18

226:2,4,13,14,14

227:1,6 236:22

238:2,21 250:11

310:10 338:10

353:17 357:20,21

358:9,21 359:6

361:3,16 378:14

381:12,18 382:3

388:20 390:2,6,11

390:17,18,20,21

391:1,2 398:16

416:20 417:5

422:19 427:10

428:21 429:3,7,10

449:3,4,14,16

450:3 452:7 453:7

453:13 455:11,22

457:12 458:19

459:12,14 510:3

512:4 515:10,22

520:12

recommendations

39:11 126:1

184:18 208:17

225:13 236:19

246:5 289:19

320:9 346:7 353:1

363:12 376:14

451:5 470:2

recommended 10:5

17:10,15 249:20

291:2,17 293:6

309:14 311:3

362:8 366:20

469:10

recommending

58:5

recommends 293:5

reconcile 150:22

reconvene 155:7

record 11:12 12:1

18:16,18 33:15

34:1 35:18 53:4

62:20 63:3 85:16

87:19 114:2 116:7

138:17 155:11

162:10 165:12,16

171:19 198:10

226:8,16 227:5

244:3,14 250:16

307:13 343:6

373:11 377:4

414:10 433:9

470:18 472:5

records 479:6

record-keeping

55:14

recreating 493:14

493:17

recycle 186:22

recycled 186:18

recycling 186:17

189:3 192:18

red 93:7 99:1 106:5

111:19 254:17

reduce 52:18

144:10 214:1

217:15 218:2

500:20

reduced 104:18

106:4 218:9

291:22,22

reducing 189:4

500:22

reduction 101:14

469:20 502:2,4

Redundancy 85:9

Redundant 85:6

reevaluate 463:5

reevaluated 463:18

464:6

refer 17:8 22:13

26:19 62:8 307:1

450:5

reference 83:18

170:17 311:5

313:17

references 45:9

312:4 316:4

referred 338:20

350:10 359:2

referring 264:2

refers 436:16

refined 468:16

refineries 272:9

reflect 54:3 250:11

350:11,15

reflects 123:6

reformulated 25:4

reformulation

379:5 380:20

refrain 10:19

reg 74:21 495:3

499:6,6,7

regard 87:3 108:9

221:7 230:3

232:22 339:11

405:16 467:18

regarding 5:8 7:11

45:10 70:10 117:3

118:18 124:9

132:8 133:19

139:5 144:6

249:13,15 259:2

339:14,20 367:3

372:1 453:12

470:7 473:8 486:1

509:21

regardless 187:22

375:6

regards 110:6

185:14 332:19

486:15

region 90:21 259:9

392:11 393:12

487:17

regional 53:4

103:18 109:11

232:18,20 234:2

regions 60:19

Register 237:11

registered 223:14

501:17

registering 379:13

regular 252:10

260:1 377:19

regularly 130:12

regulated 448:12

regulating 424:20

regulation 74:15

225:17 308:1

345:10

regulations 12:21

39:15 123:11

124:18 147:9

157:5 228:3

229:18 230:19,21

234:17 239:10,17

259:3 307:3,7,12

307:21 336:3

390:9 403:3 409:2

442:10 450:14

476:6 510:1,7

regulator 501:6

regulatory 225:9

237:5 347:4 356:8

380:10 400:18

431:8 457:16

reinforce 65:3

387:10

reinforces 426:3

reiterate 177:10

321:14 371:10

reject 30:22 451:12

rejected 39:17

rejecting 303:5

rejects 112:18

relate 43:9

related 53:15 86:16

89:6 109:13

149:21 218:6

226:19 253:9

359:20

relates 94:21 96:10

149:13 171:13

253:12 392:6

relating 76:11

relation 124:7

172:3

relationship 243:22

318:2 407:2

relationships

259:21

relative 212:17

299:4 487:1

488:16

relatively 184:2

424:9

relaying 331:14

release 293:4

released 131:9

497:5

releases 266:18

releasing 466:15

relevant 64:15

171:10 172:21

175:11 178:4

392:7

reliant 440:9
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122:19

relieve 84:13

relievers 84:1

religion 486:16

religious 486:7

relist 24:10 240:10

relisted 241:2

relisting 58:6 62:15

378:16 381:12

rely 44:8 189:10,12

200:21 379:2

383:9 440:17

remain 177:2 188:7

262:14 343:20

404:20 488:9

remains 23:16

214:10 249:16

393:2 507:7

518:22

remark 498:11

remarks 384:22

512:20

remember 79:2

80:20 159:9,12

430:14 471:1

485:1 487:22

remembering 79:6

remind 350:19

395:5 435:4 474:1

reminder 362:6,13

reminds 20:15

removal 66:5 176:4

177:1 379:6 454:1

remove 50:12

175:21 176:2,21

190:13 324:11

519:8

removed 39:17

214:9 466:20

removes 141:20

render 326:2

358:14 386:20

rendered 257:12

493:4

rendering 333:14

368:13

renders 321:19

Renew 347:9

renewal 53:3

renewed 61:7 93:18

93:21 99:11

222:21

reopen 417:11

repeat 351:22

375:14

repellant 93:21

replace 366:5,11

replaced 368:19

369:7

replacement 210:9

210:10 460:16

replacing 497:5

replenish 277:5

replenished 280:18

replenishing 280:2

replicating 286:20

reponse 365:3

report 30:14 31:19

55:3,5 327:1

340:7 346:17

497:5

reported 34:12

reports 8:13 20:1

123:21

represent 57:9

264:20

representation

129:2

representative 83:1

138:21 496:9

representatives

91:2

representing

259:12 384:15

represents 366:3

393:4,14

reproductive

448:19

reputation 408:3

reputations 109:11

request 12:2 14:13

20:16,19 54:6

120:12 238:2

310:9 315:21

371:18,20,22

372:22 432:5

requested 331:4

339:20

requesting 177:6

464:2 503:8

requests 368:22

require 26:2 28:3

44:15 70:11 92:5

227:19 310:11

381:7 429:6

437:15 449:5

450:14 452:11

457:15 468:18

476:20

required 17:9 24:2

55:14 68:13 71:4

71:15 126:22

237:6 247:3 256:2

335:4,9 336:8

340:6,10 341:1,11

429:13 473:19

498:16 512:4

517:12

requirement 66:12

69:9,20 100:14

125:13 233:21

341:12 404:14

405:19 437:15

482:22 503:22

requirements

23:19 62:1 71:8

92:5 100:12

124:18 154:21

249:13 309:3

339:19,22 340:2

340:22 342:8

395:17 490:22

506:22 511:13

requires 102:1

176:20 225:18

251:11 381:2

476:16

requiring 25:12,16

125:1 140:1 336:3

437:22

research 76:21

90:18 91:5 99:11

173:7 183:7

240:13 263:20

275:11 379:4,9

385:9 507:17

researcher 497:13

researchers 12:12

282:5 419:22

research-based

118:9

reselling 334:5

335:19

resemble 407:4

resembles 399:5

resent 475:22

resentment 127:22

reserved 451:17

reservoir 167:11

reset 5:13,15,17 6:7

6:9

resetting 5:10

residential 510:17

510:19 513:4

residual 400:22

residue 318:1

residues 93:8

190:13 194:8,9

204:1,8,11,12,20

resin 107:13

108:11

resist 295:20

resolution 180:6

184:9

resolved 58:11

72:16 292:7 432:6

resort 115:22

resources 52:20

88:17 183:10,17

478:18 480:5

489:3

respect 32:16 57:18

64:1 87:5 88:1

172:1 307:4 311:1

339:18 347:21

349:9 371:16

433:16 491:20

respectful 87:5,13

433:22

respectfully 87:1

130:20 144:7,22

146:16 484:15

respectively 457:17

respects 308:12

respiratory 469:5

respond 69:2

169:18 175:7

232:6,14 331:5

345:19 391:14

responded 228:8

391:12

responding 360:5

367:10

response 82:5

144:8 171:3

172:10 175:16

250:12 258:10

260:4 263:1 288:7

293:22 299:19

306:10 316:11

319:14 332:7

337:2 341:16

349:20 355:21

360:6,12 362:17

384:1 396:7 402:3

403:11 407:16

425:21 441:3

447:11 462:2,6

465:4 499:3

513:11 521:4

responsibilities

263:9 437:18

responsibility

76:16 341:2

352:21 437:21

452:15

responsible 249:17

473:22 485:19

responsive 115:18

115:21

rest 63:3 67:14

296:15 343:13

418:15

restart 155:14
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restaurants 259:8

restraining 511:6

restraint 492:2,3

restrict 47:11

141:2 173:13

174:7 176:22

456:16

restricting 173:17

173:19 176:3

restriction 174:20

479:7

restrictions 89:10

93:19,22 231:2

restrictive 171:21

172:7 239:11

result 60:21 75:21

76:18 99:7 103:9

188:17 190:5

285:8 328:4 336:5

366:8 368:8

379:18 381:14

386:20 421:9

resulting 188:2,10

308:19 379:19,20

380:10

results 9:12 188:13

281:7

resume 86:11

resumed 244:15

343:7 433:10

retail 22:4 103:17

138:21,22 139:10

143:9 151:21

460:4

retailer 131:21

retailers 142:7,7

260:2,7 261:9,15

261:22

retain 304:19

retired 300:7

retiring 343:19

352:16

retransmit 217:5

retransmitted

214:22

return 42:10 120:3

321:5

revalidated 249:18

reverse 44:18

reversed 43:14

reversible 465:10

review 5:13,16 9:20

22:6 26:6 27:4

43:20 47:15 48:2

61:16 87:2 88:21

113:18 170:3

171:10,14 173:5

175:11 178:6,16

222:19 249:12

314:9 317:11,16

317:18 318:12

326:8,9 327:12

353:1,16 357:5

367:6,21 378:19

380:6 381:4 430:7

432:5 435:3 453:4

455:8 495:15

reviewed 9:10

34:21 54:22 55:9

76:3 178:10 293:2

347:13 357:7

367:7 430:5 471:4

497:8

reviewing 79:8

172:9 226:6 498:2

reviews 225:4

revise 380:2

revised 54:2 189:18

revisit 44:20 250:9

revisiting 44:16

rewrite 422:9

re-evaluate 175:22

re-listing 5:14

re-posting 5:19,20

RFID 214:6

Rhode 98:22

RIBOS 49:1

Rica 499:14 505:9

rice 49:3,3,18

421:21,22 461:6

rich 226:8 253:20

485:21

Richard 29:2 35:21

48:6,9,10 49:14

51:12 155:4

224:17,18,19

228:14,16 229:8

232:5 235:6

447:13

Richards 441:9

459:21

rid 238:10 461:7

Riddle 36:1,3 41:14

41:22 42:4,14

43:16 44:18 45:2

45:12,16,19 46:6

46:10 47:1 79:15

right 7:4 11:7

13:17,21 15:12,20

17:9 23:11,11

36:16 38:2 41:7

42:22 45:19,21

46:6,8 58:9 66:18

70:14 71:20,21

83:21 87:11 95:4

95:7 98:6 129:7

131:8 133:14

140:6 146:18

147:7,18 148:16

152:19 153:20

155:19 165:17,18

165:20 168:19

186:8 201:20

208:6 213:11

220:5,16 230:11

240:21 243:1

247:5 248:5,9,10

248:22 249:1

251:5 252:12

258:15 274:3

278:21,22 279:3

291:6 314:20

315:13 319:5

325:15 331:19

360:13 365:15

373:9 377:7

401:19 408:12

411:12 412:16

423:15 425:6

431:2 441:21

442:9 447:4,12

450:1 458:16

467:9 478:13

484:10 485:8

490:10 506:9

508:15 515:1

517:9

rightly 361:2

rigorous 307:16

rigorously 297:2

ripe 500:18

ripen 266:6 272:18

ripeness 501:4,8,22

506:3

ripening 500:9

501:3 507:12

ripenings 500:19

ripped 466:12

rise 27:16

risk 91:20 226:19

227:9 233:1

370:18 419:3

422:13,17 425:10

438:5 511:3

risks 226:18 387:15

389:2 511:19,21

ritual 491:14

road 127:19 145:13

407:7 418:10

422:22

roam 291:12

Robert 51:21 215:8

Rock 99:1 158:20

Rodale 51:21

Rodents 438:9

role 128:18 276:10

348:15

rolling 416:5

rollout 294:21

Roman 107:9

108:1

romance 520:6

Romans 107:9,16

Ron 436:17 437:2

roof 168:12,15,22

169:3

room 7:11 14:14

18:11,19 19:8

21:20 51:17

171:18 244:5

270:9 320:2

323:11 394:11

467:6

roots 344:17

Rosen 2:21 382:19

rotation 130:6

222:16 339:17

rough 160:6 414:8

roughly 66:2

248:12

round 163:19

501:5

rounded 356:16

route 153:19

row 445:2

rows 90:3

rude 116:1

Ruden 116:10

rule 17:7 24:22

31:8 38:19 45:9

54:9 84:7 131:10

131:22 133:22

141:1 157:5 161:5

171:4,4 172:10

179:18,21 197:22

197:22 230:16

232:19,21 234:6

253:10 261:19

333:17 339:2,15

345:8 387:9,22

388:11,13 390:15

427:8 428:2,22

429:6,12,13,15

430:2 435:22

436:5,8 442:4

476:15,19 479:2,9

479:11,22 480:10

481:16 483:11

ruled 328:18

rules 29:22 30:13

31:4,14 32:21

109:4 117:15

134:10 193:17

221:14 255:2,4

258:3,4 387:11
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475:7,17

ruling 136:13

ruminant 54:12,16

55:4,5 214:6

468:5 483:3

ruminants 214:10

340:1

run 17:12 111:10

128:11 136:20

166:7 187:13

344:6 430:20

running 372:8

412:10

R&D 381:6

S

sacrifices 122:10

sacrificial 290:18

sacrificing 134:11

506:16

sad 33:5

safe 112:2 258:6

309:21 438:14

479:9

safely 341:8

safety 30:15 132:10

226:18 227:11

240:18 250:15

255:22 384:8

416:21 420:2

437:19 448:11

450:6

sails 148:15

sake 44:15 45:7

sales 65:18,22

139:10 259:20

Salmonella 439:8

salt 107:12

salts 89:7,7

Sam 223:4

sample 247:21

sanctions 484:1

sand 157:5

Sandy 350:6

sang 398:14

sanitization 240:18

sanitize 223:3

sanitizers 240:15

sanity 46:3

sat 156:15

satellite 208:7

satisfy 83:13

158:13 371:22

493:1

satisfying 395:17

sausage 452:6,16

452:20

save 46:3 217:17

293:8,13

saved 218:12

savings 217:14

218:18

saw 31:22 101:13

207:12 221:18

230:15 322:18

359:13 416:19

sawdust 400:6,7

saying 19:12 40:16

77:14 80:12

110:13 152:13,20

161:13 195:8,12

276:10 282:17

286:6,16 300:15

364:3,3 410:12,20

421:16 455:14

458:20 484:4

says 15:17 17:10

39:6,21 40:8

84:16 110:5

112:16 117:11,18

147:8,17,17

157:16 162:22

237:6 241:5 242:3

280:11 314:12

327:2 454:4 464:7

488:2,3,10

scalder 117:8,10

118:7

scale 117:6,6 118:3

255:3 386:8 393:5

445:9 474:21

scallops 300:19

scamming 475:21

scan 417:18

scene 394:12

438:19

Schahczenski

33:14 34:10 46:1

51:14 52:4

Schahezenski

51:15

Schaller 220:5

schedule 57:2

74:10 154:18,19

300:3 326:17

331:11 433:21

scheduled 237:10

343:2

scheduling 154:17

school 397:3

Schultz 133:8,8

science 9:8 12:22

251:19,19 263:7

314:10 340:13

341:3 438:18

496:10 497:1,15

sciences 317:20

science-based

249:22 289:5

292:18 496:14

scientific 9:4,22

10:8 182:8 183:12

249:12 289:7

497:8

scientist 247:22

281:4 473:11

scientists 9:8 10:14

286:13 325:5

364:3,3

scope 503:5

score 80:15,16

119:13,15 127:4

142:15,15,16,20

142:21 340:4,5

409:14,14

scores 75:3

scoring 80:13

119:7 340:6

471:14,17

scoured 392:12

scraping 478:19

scratch 227:4

228:12

scratching 100:10

232:10 291:14

394:10 405:8

screen 6:16 20:13

252:14

screw 411:8

scrutiny 492:17,18

se 71:9 345:18

seal 13:13,22 39:22

40:4,6 76:15

139:18 140:5,7

147:6,8,12,16

151:10,13 153:20

389:8 400:2

515:14 518:9

seals 140:4

season 95:5 125:3

248:8 480:12

481:3,7,12 500:14

500:15 507:8

seasons 248:3

seat 4:7 433:13

seats 4:6 245:4

343:9,10 396:13

433:12 497:4

second 15:22 19:15

26:17 39:5 50:7,7

116:18 133:16

170:1 181:9 222:3

224:16 264:3,5

276:15 277:17

319:20 346:19

440:15 477:15

secondary 284:12

285:13

secondly 59:22

73:11 173:5

seconds 62:2 173:2

493:12

second-guess

304:22

secret 59:13

secretary 2:17

372:19 435:9

section 124:9

188:15 197:16

225:17 387:21

388:12 418:20

468:12

sections 345:12

sector 128:17 380:9

see 7:8 9:6 11:21

12:3 15:2 20:22

23:14 28:21 50:17

57:3 59:8 66:8,21

66:21 75:10 79:4

82:22 83:2 87:2

87:15 88:3 95:17

98:9 102:11

127:20,21 132:20

137:13 142:19

152:10 154:7

165:8 195:16

202:6 208:8 210:6

212:13 216:11

223:19 226:22

235:1 239:3 241:2

254:5,13,15

255:17,17,18

264:19,22 267:11

270:5 280:10,20

296:3 297:3 300:4

302:15 303:20

304:4,5 307:15

316:3 351:17

361:21 364:2

377:13 385:15

390:22 391:5

394:6 400:17

402:12 406:15

407:6,19 408:2

410:20 414:8

423:3,3,6,8,19,21

424:1,9 426:19,20

432:22 435:22

436:12 437:7

443:3,16 444:20

451:3 453:4,5

466:7,21 476:9

482:3,5 486:22

487:4 491:7
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327:22 334:3

seek 66:13 453:8

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232:2 272:6

323:20 325:6

we'll 7:14,14 66:8

67:10 68:2 71:17

72:20 74:8 82:1

88:11 102:2

149:11 155:7

194:17 195:19

201:19 224:4

235:8,8 244:10

287:16 300:3

377:13 390:21,21

391:5 408:2

420:15 426:17,19

434:1,21 472:20

485:12 489:2

494:22

we're 4:15 6:15,22

7:7,12,15 11:13

11:13,18 15:18

16:9,15 18:5,8

27:15 29:6 30:4

31:15 33:15 43:8

44:13 51:20,21

64:11 65:7,21

66:18 68:11 69:3

71:16 74:9 80:9

83:12 84:2,11

86:10 88:13 94:17

106:17 113:18

115:20 127:16

129:3 136:14

146:5 148:4,20

151:21 152:5

154:16,19 155:14

161:10 176:2,21

179:20 181:4

182:13 183:22

194:1 201:17

202:7 203:9 205:9

209:13 224:4,5

241:16 245:4,6,18

246:18 269:10

285:3,6,17 286:16

295:6 299:14

309:10 313:18

315:12 317:4

320:17 326:16,19

327:22 331:11,20

343:1,1,13 345:2

349:15 351:14

353:2,3 357:2

361:7 372:4,5,16

383:8,8 397:7

402:7 408:6

409:11 410:8

411:2,2 413:3,8

413:15,17 414:21

415:1,2 417:8,11

417:13 418:3

420:1 421:5,20

422:17 424:11

425:20 427:7

433:22 435:9

436:5 447:5

456:13 458:21

459:1 460:1,14

463:14 465:22

466:2,13,14

470:19 471:10,12

471:13,17,20

472:1 484:13

487:5,14 489:10

489:11,17,19

490:17,19,20

491:1 492:4,11

493:13,15 494:4

496:2,18,21

498:10 503:21

505:9 521:6

we've 8:6 21:5 29:8

30:7 31:9 66:14

68:6,8,15,17

69:15,15 81:12

86:13 106:11

111:10 115:18

147:11 151:8

154:18 161:9

182:17 184:13

203:14 204:10

232:7 246:2 253:9

254:1 256:16

287:4 297:12,17

297:20 298:5

310:21 342:4

345:18 365:22

371:19 389:19

390:18 391:8

393:17,21 402:6

402:16 410:9

415:6 416:1

418:21 426:14

435:19 453:17

485:5 492:17,18

495:10

whatsoever 97:7

483:1 506:10

wheat 142:21 460:2

whichever 235:11

482:1

whiff 240:9

white 106:5 178:7

239:14

whites 111:20

Whitmeyer 462:17

wholeheartedly

146:1 307:13

385:20

wholesome 145:12

wide 298:7 516:14
202-234-4433

Neal R. Gross & Co., Inc.

Page 591

518:13

widely 369:3

widespread 309:16

wife 122:1 221:1

223:13 243:14

393:15 441:12

483:7

wild 167:9 207:14

208:8 438:9

willing 27:2 68:5

230:2 372:4,6

446:12 498:10,20

511:1,5

Wilson 356:2 365:7

365:8,10,11,15

371:5,8 372:10,13

378:12 382:8

383:13,15,19

384:3

win 246:10 259:11

wind 148:15

windows 164:22

wine 90:19 106:12

106:19 107:20

108:2,15,17,19

109:1,2,11,16,22

110:8,9,12,17

111:5,6,15,18,19

112:2,6,19,22

113:1,7 114:13

115:1,3,9,11,14

156:22 157:4,11

157:12,16,20

158:5,18,22

159:22 160:2,9,18

161:15 162:11,15

163:14,22 259:5

259:11 260:8,10

260:11,18,19

261:6,10,13,22

262:2,7 273:19

300:14 301:2,6,17

302:10,22 303:7

303:10,12,21

304:6,8,18,19

305:2 451:8,12,13

451:15,17,18,22

wineries 114:12,21

160:21 259:13

winery 106:11

157:14 158:15

wines 109:5 110:5

111:3,11,12

113:10 157:22

158:3 258:20,21

259:3,7,13,14,17

261:10,20 302:9

302:15,17 303:14

303:15 305:16

306:1,4

wine-making 107:2

107:5,7 110:3,22

113:7 115:6,14

157:19 160:15

301:22

wing 136:9

winging 138:4

wings 291:13

409:15

winter 100:15

125:15

winters 97:15

wintertime 102:3

win/win 246:7

519:22

wire 231:13 232:11

Wisconsin 1:12

29:17 31:7 32:7

34:4,9 94:21

95:16 117:18

136:18 207:1

209:8 221:2 392:9

393:8 397:3,7

478:16

wisdom 242:10

wish 22:10 122:7

324:2 326:5,6

wishes 243:9

350:16

wishing 392:4

withdraw 238:6

withdrawn 101:12

Wittiman 215:8

Wolf 332:12 337:7

343:16 344:7

348:10 350:4,11

351:13

wonder 93:15

119:7 142:22

307:11

wondered 18:22

254:4

wonderful 128:16

164:22 165:6

166:8 397:10

472:14

wondering 135:21

179:2 287:15

355:9 412:9

wood 227:4 228:8

228:10 233:14

400:6,7

wooded 392:11

wooden 445:21

woodlands 510:16

wool 393:10

Woolick 396:10

word 10:13 39:7

40:17 78:13 92:5

100:2 140:20

143:21 147:2

174:2 179:12

305:19 394:14

417:21 426:3

436:14,15 488:14

words 136:2 146:21

281:12 283:3

318:14 325:18

356:11 407:22

408:1 417:20

479:17 499:5

work 7:10,13 27:13

32:16,19 36:3,12

37:19,21 38:11

51:1 52:21 63:12

64:21 69:13 94:13

95:20 97:3,11

98:1 100:18 121:6

121:19 122:3,20

123:8,22 125:19

131:19 133:12

137:3,8 138:6

148:9 149:10

154:5 159:1 164:2

172:1 226:15

230:12 237:20

240:20 241:1

259:19 263:14

297:21 320:22

325:9,10,12 338:9

343:21 350:7,13

358:2 365:18

377:7 379:5

390:13 411:20

414:20,22 423:7

429:5 430:17,22

431:2,5 434:6

437:6 450:20

477:8 481:17

483:15 491:21

492:1 493:21

494:22 498:21

499:15 509:20

514:20

workable 338:3

460:22

workbook 54:10

workbooks 55:16

55:17

worked 122:1

159:5 233:9

238:22 351:3,4,5

390:18 447:17

459:12 460:13

479:16 485:18

492:9,10

worker 131:13

300:8 420:18

working 5:18 14:22

18:5,15 20:3 27:3

37:19 58:18 65:16

94:16 102:19

131:6 149:5

151:15 158:11

179:16 183:10,10

207:3 238:5 252:7

252:9 288:19

289:12 300:8

315:13 335:19

346:1 356:4,19

357:21 359:10

361:6,12 362:8,12

362:21 402:7

477:18 478:4

491:16 493:15

505:6

workload 236:5

works 61:8 223:10

384:10 483:7

worksheet 357:13

worksheets 54:13

361:9,11

world 29:21 95:17

97:10 112:8,15

233:19 234:1

245:19 314:10

449:18 459:5

487:13 520:22

worldwide 234:3

379:1

world's 344:18

worms 167:9

417:11

worn 156:8

worried 286:12

424:15 482:20

worry 21:19 256:11

worth 107:15 132:4

217:20 407:22

408:1 426:8

449:16

wouldn't 16:19

17:2 130:10,12

133:16 150:17

206:2 284:5 390:9

449:18 457:15

wrap 67:11 83:17

112:13 201:12

311:21 361:8

wrap-arounds

152:8

write 10:17 402:9

414:2,4 455:2

writer 107:10

write-up 158:4
202-234-4433

Neal R. Gross & Co., Inc.

Page 592

writing 307:1

written 14:5 22:13

26:19 36:19 45:13

62:9 239:18

292:13,16 387:16

486:16 511:11

512:19 515:1

wrong 112:21

133:7 205:21

241:14 465:7

wrote 26:6 352:1

386:1 402:18

WSDA 199:10,19

200:4

Wyard 306:15,16

312:17 313:6,9

314:17,21 315:5,7

315:15,20 316:12

350:2 356:1 357:8

358:3 364:21

365:5

Y

ya 374:21

yank 459:17

yard 211:16 409:3

410:10

year 14:21 20:18

53:13 73:7,10

100:5 102:2 107:4

115:5 127:9 132:3

143:4,8 204:6

210:2 217:18

218:13 230:18

248:6 270:18,18

292:3 333:1 381:3

391:8 409:7,16

411:22 412:16

414:14 444:13

449:13 457:7

482:3 483:4,6

500:16 501:5

years 9:3 20:19

21:1 22:20 27:13

29:10 30:9 31:10

36:6 54:2 57:7,19

59:2 66:9,14

68:16 72:17 73:8

101:11 102:17

106:12 109:3,20

110:12 115:6

131:7 133:9

144:18 153:8

156:7,11,21 157:3

158:8 160:12

184:2 199:12

200:7 214:19

218:17 223:14

224:12 227:16

241:7 246:11

248:3,3 253:1,10

256:17 257:8,17

259:10 260:5

262:9 289:11

294:14,19 295:1

300:8 303:13

341:19 347:10

348:15 351:3,6

356:5 357:4

362:20 378:15,17

378:18 379:7

380:10 381:8,13

392:19 393:15

397:14 417:14

420:1 434:7

436:20 444:8

452:21,22 454:6

460:4 478:4 479:3

479:7 485:18

487:11 491:22

492:22 497:21

514:4,12 515:19

516:3 520:3

year's 106:1 158:2

year-round 450:16

yeast 48:11,15

62:12 161:12

308:5,11,13,14,16

308:18,20 309:7

375:20 377:3

518:12

yesterday 5:8

20:16 21:6 31:22

49:8 50:9 103:1

120:11 176:17

238:8 263:8

322:18 353:19

374:16 385:3

424:22

yesterday's 26:5

169:17

yield 56:18,19

101:14 282:22

501:1 502:3

yields 379:19 506:2

506:17

yogurt 266:5 305:2

yolk 103:20

York 258:22 259:8

483:8,19

young 181:14,15,15

289:21 290:2

308:1 394:5

Z

zeal 25:17 373:17

Zealand 65:11

zein 466:4,15

zero 279:1,1 374:14

Zimmer 403:13

408:3,5 412:6,10

412:19 413:22

478:9,11

zone 212:7,8,13,14

510:15,20 511:3

511:19 512:6,9,17

Zurosh 111:2

$

$2.3 487:12

$500,000 218:12

$7.5 217:17

0

04 382:5

06 359:4

09 359:17

1

1 58:21 82:14 89:21

141:5 182:14

363:14 374:5

1st 69:18

1,000 68:17 270:13

270:13 290:14

408:8

1,100 290:12

468:13

1,200 217:21

1,300 469:2

1,500 23:1 58:22

59:1

1,655 391:12

1.3.1 92:12

1.8 207:13 208:18

209:5

1:45 244:10,15

1:52 245:2

10 65:19 101:13

112:4 155:3,7

158:8 160:12

481:15 483:2,21

10,000 65:12 99:19

100:22 102:19

115:5

10-week 103:4

10:49 155:11

100 25:13 26:15

77:13 78:7 100:5

110:12 111:14,17

119:10,15 150:17

150:19,19 151:4,6

151:8,11 153:11

215:9 238:10,18

241:15,18,20

242:2,6,7,8,9,18

242:20 246:1

259:4 260:8,12,16

261:3 271:9 278:7

304:17,17 306:5,5

479:13

100,000 167:15

442:8

101 358:17

101B 172:12

101(b) 312:18,19

332:18

101.9 311:15 312:1

312:4,7

101.9(c)(8) 311:15

104-point 316:7

104.2 311:8

104.20 17:8 171:9

177:19 311:5,14

312:4,9 313:18,21

316:2

105 216:10 418:20

419:8 422:10

425:1 428:2

107 216:15

11 401:12

11,000 139:3 450:9

11:11 155:12

118,000 447:21

119 160:13

12 164:21 264:19

291:10 479:4

12:44 244:14

120 234:19 235:1,3

481:4 483:1

13 308:9

13,000 448:6

14 22:20 58:22 59:2

82:13 107:21

422:15 506:11

1400s 108:15

145 503:22

1472 108:15

1487 108:22

1495 108:17

1497 108:19,22

15 65:20 101:13

155:8 218:2 279:9

279:14,15 291:5,6

291:8 397:13

433:6 481:15

500:7

156-year-old

378:21

16 237:2 351:6

17 131:7 188:15

18,000 65:11

180 237:3

189 495:10

1960 110:17

1971 344:10
202-234-4433

Neal R. Gross & Co., Inc.

Page 593

1975 156:11 485:17

1976 485:20

1978 485:22

1986 288:21

1990 159:10

1992 514:7

1993 311:7

1995 16:10 170:19

172:9 188:17,20

249:14,20

1996 22:3

1997 64:12

2

2 89:22 141:9 269:2

269:6 295:3

2nd 309:9

2,000 96:20 281:11

317:6 321:22

2,200 277:6 280:17

281:8

2:00 22:18

20 36:6 91:22 195:5

223:14 291:21

292:2,5 303:13

351:3 391:16

397:13 433:6

469:7 478:3

483:18

200 25:13

200,000 65:8

2000 171:3 172:9

510:6

2001 207:17

2002 167:4 226:2

226:12,15 233:12

2004 308:6 366:6

381:20 382:6,10

463:3,16,19

464:11

2005 357:20 361:3

2006 320:8 463:7

463:11

2006/2007 34:17

2007 34:17 60:17

60:17 69:22

376:14 463:14

2008 376:14 497:5

514:13

2009 65:18 90:7

160:7 362:7

2010 1:8 7:22 9:18

89:1 90:19 93:18

93:22 309:9

483:10

2012 26:10 65:5,6

65:22 180:11

184:1 248:11,16

2013 69:18 70:12

72:14,16,17 246:6

246:19 515:11

520:12

2015 92:15

205.101(b) 310:8

310:13

205.105 387:21

205.238(c)(2)

319:12

205.239 124:7

205.239(a)(1)

225:18

205.272(b)(1)

388:12

205.300 144:5

205.603 222:20

205.605 499:20

205.605(a) 22:12

205.606 188:15

21 17:8 138:22

171:9 311:5

313:20 500:7

2118 162:22

22 259:10

23 180:1

230 514:4

238 238:21 338:17

238(c)(2) 83:18

402:8

239(c)(2) 398:16

24 93:1 179:22

216:1 289:11

401:11 409:9

478:12

2424 1:11

244 3:18

245 3:20

25 92:15 99:20

100:21 210:9

291:16,18 294:14

469:2

25(b) 93:4

25,000 65:10

157:14

250 167:21

250,000 447:20

27 1:8

28 217:9,9

280 514:4

3

3 45:16 90:1 280:13

316:7 363:14

3,200 165:4

3,300 165:4

3.5 198:17

3.75 160:5,8

3:30 343:3

3:31 343:6

3:45 343:3

3:50 343:7

30 23:1 50:6 67:16

67:21 77:15

106:12 149:18

152:18 167:12

195:8,10,13

234:18 300:8

410:17 420:1

444:7 445:1 481:1

481:1 483:1 485:3

493:12

30,000 445:20

30/120 485:3

300 46:15 214:14

482:21

3120 234:7

3126 481:14

32 436:20

34 460:3

35 156:10 259:12

393:15 478:15

350 53:11

36 479:3

37,500 265:10

4

4 3:13 279:16,18

280:6 338:1

381:22 382:4

383:2,6 463:4,5

463:15,17 464:11

4B 463:10

4(a) 378:16 380:5,5

381:13

4(b) 368:16

4)b 380:5

4,000 452:3

4/20 359:17

40 290:11,11 397:4

408:5

41 65:18

45 173:2 237:11,12

237:17 244:9

450 167:17

47 513:4

5

5 133:15

5,000 29:7 32:2

67:20

5.8 277:18

5:00 4:21

5:15 433:2

5:18 433:9

5:20 433:2,2

5:30 166:3 433:3

5:31 433:10

50 29:8 75:13 132:3

217:16 218:10

221:1,17 392:19

468:14

50,000 442:4,8

50.24 436:14

500 109:3,20

157:13

5014 309:8

521 3:22

55 65:22 409:12

6

6 82:14

6,000 451:9

6,600 164:20

6.8 279:16

6.99 269:6

6:30 167:2

6:59 521:8

60,000 445:1

60-day 209:22

601 197:12,14

205:13,13 502:15

508:1

601(j) 197:16

601(j)(7) 198:13

603 84:10,12

398:19

605 205:12 346:21

502:12 507:22

605(a) 23:17 25:14

48:20 503:8

605(b) 48:20

606 25:14 58:1

60:18,21 61:3,8

69:6 246:10,16

247:3,16 346:19

346:21 453:17

63 168:1

65.17 373:22

7

7 3:16 82:14 269:5

269:6

70 153:11 154:5,8

260:19,20,22

295:2 479:14

70s 514:6

72,000 66:2,3

72-hour 216:2

75 132:3

770 290:12 468:13

8

8,000 97:5 107:4

115:4

8,320 385:22

8:00 1:10

8:06 4:2

80,000 376:2
202-234-4433

Neal R. Gross & Co., Inc.

Page 594

80.5 167:15

836 121:12

9

9,400 115:6

9:00 4:21

9:15 74:7

9:27 85:16

9:42 85:17

90 237:9,17 408:9

448:20

90s 95:13 97:1

133:10 411:5,11

90/120 479:7

900 408:8

900,000 447:16

95 18:7 139:16,17

140:2 150:15,16

150:19,21,22

151:8,11 153:11

154:8 308:20

95.5 479:13

96.2 167:19

97 493:7

99 159:21 376:1

99.9 271:13

999 270:13
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 

595

National Organic Standards Board

US Department of Agriculture

10-27-10

Madison, Wisconsin