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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)

 + + + + +

 MONDAY

 APRIL 9, 2013

 + + + + +

 The National Organic Standards

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

Portland & Executive Tower, 921 Southwest 6th

Avenue, Portland, Oregon, Mac Stone,

Chairperson, presiding.

MEMBERS PRESENT

MAC STONE, Chairperson

HAROLD AUSTIN

CARMELA BECK

COLEHOUR BONDERA

JOSEPH DICKSON

TRACY FAVRE

JAY FELDMAN

JOHN FOSTER

WENDY FULWIDER 

NICHOLAS MARAVELL

JEAN RICHARDSON

ZEA SONNABEND

JENNIFER TAYLOR

FRANCIS THICKE

CALVIN WALKER
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STAFF PRESENT

MILES McEVOY, Deputy Administrator, National 

 Organic Program

MICHELLE ARSENAULT, Advisory Board Specialist

MELISSA BAILEY, Director, Standards Division,

 National Organic Program

LISA BRINES, Standards Division, National 

 Organic Program
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 TABLE OF CONTENTS

Call to Order

 By Mac Stone . . . . . . . . . . . . .4

Secretary's Report

 By Dr. Calvin Walker . . . . . . . . 24

National Organic Program Update

 By Miles McEvoy . . . . . . . . . . . 25

Open Public Comment . . . . . . . . . . . 67

Materials Subcommittee

 By Zea Sonnabend . . . . . . . . . . 284

Public Comments Related to 

Materials Subcommittee . . . . . . . . . . 304

GMO ad hoc Subcommittee 

 By Dr. Jennifer Taylor . . . . . . . 320

Public Comments Related to 

GMO AD HOC Subcommittee . . . . . . . . . 337

Adjournment . . . . . . . . . . . . . . . .397
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1 P-R-O-C-E-E-D-I-N-G-S

2 8:01 a.m.

3 CHAIRPERSON STONE: I'd like to

4 have everyone's attention. I'd like to go

5 ahead and get the spring meeting of the NOSB

6 in order. We have a very aggressive agenda,

7 so we're going to be quite diligent at trying

8 to stay on time out of respect for those of

9 you with public comment. We want to get as

10 much as we can from you as we go forward.

11 First, I want to thank the Board

12 for the opportunity to serve as a chair. It's

13 very rewarding to have the opportunity to such

14 diligent and dynamic brain trusts that we work

15 with. I thank the audience and thank all of

16 you all for taking your time and your hard17 earned money to be here. It's very important,

18 your written comments, your interest and

19 attention to detail. We take it very

20 seriously. 

21 Since the written comment period

22 closed, this group of people has had a lot of
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1 very intense conversation based upon your

2 all's input. And, again, we look forward to

3 public in-person input, both from the podium

4 and in the hallway and at dinner, etcetera. 

5 So we highly value your all's input.

6 Remind you to please turn your

7 cell phones off, including Board members. We

8 do have a policy. Cell phones that go off get

9 to buy the first round, depending on how many

10 rounds there are. 

11 So at this time, we have one new

12 Board member, Francis Thicke, over here. But

13 I think Colehour will start to my left. If

14 you introduce yourself, a little bit about

15 your background, what committees you serve on,

16 and we'll work around the table. 

17 MEMBER BONDERA: Okay. Thank you

18 very much, Mac, and thank you all of you being

19 here to help us move forward. My name is

20 Colehour Bondera. I am a very small-scale

21 farmer in the state of Hawaii. I am not at

22 work right now because that's my work is
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1 farming. 

2 So I serve on -- I was going to

3 give a number, and I can't recall the number,

4 so I'll just list them. I serve on the

5 Livestock Subcommittee. I am chair of the

6 Policy Development Subcommittee. And I serve

7 on the Crop Subcommittee, as well as the Ad

8 Hoc GMO Subcommittee. And I think that that's 

9 that. Thank you. 

10 MEMBER FAVRE: My name is Tracy

11 Favre. I am currently chair of the Livestock

12 Subcommittee. I also serve on Materials and

13 Handling Committees and the CACS Subcommittee. 

14 I spent 18 years as an environmental engineer

15 and, most recently, the last four years, in

16 sustainable ag, training farmers on

17 sustainable management practices. And I'm

18 happy to be here. 

19 MEMBER BECK: Good morning. My

20 name is Carmela Beck, and I work at Driscoll

21 Strawberries Associates based out of

22 Watsonville, California. I've been there the
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1 past six years. I manage the organic

2 certification program for our independent

3 growers. I sit on the Crops, the Handling,

4 and the Compliance, Accreditation, and

5 Certification Subcommittees. And it's also a

6 pleasure to be here. Thank you. 

7 MEMBER SONNABEND: Good morning. 

8 My name is Zea Sonnabend from Watsonville,

9 California. I am in the scientist seat. I

10 work for California Certified Organic Farmers

11 as a policy specialist and a farm inspector

12 for California's certification services. I

13 have a small farm, Fruitilicious Farm, where

14 we grow apples and other fruit. And I serve

15 on the review panel and I'm one of the co16 founders of Organic Materials Review

17 Institute.

18 MEMBER FELDMAN: Good morning. 

19 I'm Jay Feldman. I serve on the Crops,

20 Materials, Policy Development, Ad Hoc GMO, and

21 the Inerts Working Group. I'm the executive

22 director of Beyond Pesticides in Washington
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1 D.C. I've been doing that since 1981, where

2 we work with farmers, consumers,

3 environmentalists to reverse some of the

4 environmental and public health problems we

5 suffer from in chemical intensive agriculture,

6 such as autism, learning disabilities,

7 intersexed fish, cancer, hormone disruption,

8 and a whole host of environmental

9 contamination issues related to water quality

10 and food safety. So we have an intense and I

11 personally have an intense desire to grow

12 organic with public trust and integrity to

13 ensure that organic becomes the mainstream

14 form of agriculture in this country. Thank

15 you. 

16 MEMBER RICHARDSON: Good morning. 

17 I'm Jean Richardson from Vermont. I'm a

18 consumer public policy representative. I

19 serve on Accreditation, Livestock, GMO Ad Hoc,

20 GMO Vaccine Working Group, and Handling. I am

21 an organic maple syrup producer, and we're

22 boiling, probably right now as we speak, and
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1 I'm missing out on that, but my kids are doing

2 it. I've farmed a whole range of animals

3 organically in the past. Again, my kids are

4 doing that now. And I'm an organic inspector.

5 MEMBER DIXON: Good morning. My

6 name is Joe Dixon, and I am from Austin,

7 Texas. I occupy the retailers seat on the

8 Board. I am currently the quality standards

9 coordinator at Whole Foods Market. I work as

10 part of a group there that sets the company

11 standards on the products we sell and works on

12 issues of food policy and food integrity and

13 organic certification. I serve on the

14 Livestock Committee, the Materials

15 Subcommittee, the Handling Subcommittee, and

16 the Compliance, Accreditation, and

17 Certification Committee. 

18 MR. FOSTER: My name is John

19 Foster. I'm just starting my fourth year on

20 the Board here. I'm in one of the two handler

21 positions. I live in Santa Cruz, California. 

22 I'm the director of compliance for quality
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1 food safety and organic integrity at

2 Earthbound Farm. I chair the Handling

3 Committee. I'm on Crops, CACS, Policy,

4 Executive. I think that's it. As usual,

5 very, very happy to be here and happy to take

6 part in a great process.

7 CHAIRPERSON STONE: My name is Mac

8 Stone on the certifier seat. Currently,

9 again, honored to be Chair of the Board. I

10 farm with my wife and her family organic in

11 Kentucky, serve on CACS and Livestock this

12 term. 

13 MEMBER WALKER: Good morning. My

14 name is Calvin Walker. I'm a native of

15 Louisiana. I serve on the Certification,

16 Policy, Livestock, Materials, and GMO Ad Hoc. 

17 My real job is program leader for animal

18 science, plant science, and agriculture

19 economics at Southern University in Baton

20 Rouge. And I have a host of other interests

21 recently, dealing with oil and gas and land

22 development. Thank you. 
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1 MEMBER FULWIDER: I am Wendy

2 Fulwider, and I am on the Board as a producer. 

3 I am currently on the Livestock and Materials

4 Committees. I work at Crop Cooperative as

5 their animal care specialist. I own a

6 certified organic farm in Wisconsin, and this

7 fall my son will be an organic dairy producer. 

8 Thank you. 

9 MEMBER AUSTIN: Good morning. My

10 name is Harold Austin. I'm the director of

11 orchard administration with Zirkle Fruit

12 Company, a grower. We produce apples, pears,

13 cherries, blueberries, wine grapes, both

14 conventionally and 42 percent of our total

15 production now is transitioned and is

16 certified as organic in Eastern Washington. 

17 And I serve also on Washington State

18 Department of Ag's Organic Advisory Board. 

19 I'm the Vice Chair of the Handling Committee. 

20 I sit on the CACS Committee, and I'm also on

21 the Crops Committee, as well. 

22 MEMBER TAYLOR: Good morning. I'm
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1 Jennifer Taylor from Florida A&M University. 

2 I'm from Tallahassee, Florida, and I am

3 coordinator of small farm programs at Florida

4 A&M University. I serve on the Materials

5 Committee as Vice Chair, the Policy

6 Development Committee, and I am Chair of the

7 GMO Ad Hoc Subcommittee. I represent public

8 interest and consumer interest on the Board. 

9 MEMBER MARAVELL: My name is Nick

10 Maravell. I'm a producer representative. For

11 over three decades, I've been an organic

12 farmer: crops, livestock, farm processing,

13 etcetera. I serve on the Crops Committee, the

14 Livestock Committee, the Handling Committee,

15 and the Policy Committee, and the Ad Hoc

16 Committee or the Ad Hoc -- I don't know. 

17 Whatever it is. The GMO Vaccine Committee,

18 vaccines made with excluded methods, working

19 group.

20 MEMBER THICKE: I'm Francis

21 Thicke. I'm an organic grass-based dairy

22 farmer from Iowa. We process our milk on the
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1 farm and market it all locally. I'm also a

2 soil scientist by training, and I worked at

3 USDA in Washington in the past as a national

4 program leader for soil science for the

5 extension service. I'm on the Crops Committee

6 and the Livestock and the GMO Ad Hoc, and I

7 serve on the environmental position here on

8 the Board. 

9 CHAIRPERSON STONE: All right. 

10 Thank you very much. If we move on around,

11 and, Miles, just introduce yourself and work

12 through the program here.

13 MR. MCEVOY: Good morning. Miles

14 McEvoy, deputy administrator for USDA's

15 National Organic Program. It's great to be

16 here. I just want to recognize all the

17 service, the countless hours that the Board

18 has put in over the last six months to come up

19 with these proposals. The work that the Board

20 does is really essential to the success of the

21 organic industry and organic agriculture, and

22 you guys deserve a lot of praise for the work
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1 that you've done. Thanks. 

2 MS. BAILEY: Good morning,

3 everybody. My name is Melissa Bailey. I

4 serve as director for the Standards Division

5 at the National Organic Program at USDA. 

6 Great to be here. Glad to see everybody's

7 faces again. Our work in the Standards

8 Division, we work with all of the Board

9 members on their issues. In particular, I've

10 worked with Nick and Jean on the Vaccines Made

11 with Excluded Methods Working Group, as well

12 as on the GM Ad Hoc Committee. But myself and

13 the whole Standards team interfaces with these

14 folks on a daily basis on all of their

15 subcommittee calls, so, hopefully, that's been

16 helpful. 

17 The Standards Division is also

18 responsible for all the rulemaking work that

19 goes on, much of the guidance development, and

20 things related to that. So I look forward to

21 a great meeting. 

22 DR. BRINES: Good morning. My
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1 name is Lisa Brines. I also work in the

2 Standards Division of the National Organic

3 Program as the national list manager. I also

4 work closely with members of the Board,

5 particularly the Materials Subcommittee and

6 also the Inerts Working Group. Thanks.

7 MS. ARSENAULT: Good morning. My

8 name is Michelle Arsenault. I'm in charge of

9 all the logistics for the Board. I'm the

10 Advisory Board specialist. If you have any

11 questions, please come ask me. And I've been

12 in this position just over a year now. I just

13 celebrated my year anniversary, and I want to

14 reiterate what I said at the last meeting that

15 this is the hardest working bunch of people

16 I've ever worked with, very dedicated, very

17 passionate. I talk to them more than I talk

18 to my family. We have weekly conference

19 calls, many weekly conference calls, and they

20 call in from vacation, they call in from their

21 offices, they call in while they're on the

22 road traveling to do inspections, they call in
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1 from every bridge in Louisiana. And so it's

2 a great group of people. I love my job. And

3 welcome. I hope we have a good meeting.

4 CHAIRPERSON STONE: Thank you. 

5 And Michelle does way more than that. She

6 keeps us with so much on our behalf so that we

7 can concentrate on the issue at hand and the

8 mechanics. We depend on her so very much, not

9 just logistics of the meetings but the

10 documents and the work plan, et cetera. So,

11 Michelle, I want to give a real shout out to

12 you and appreciate so much all the work that

13 you do.

14 I know there are several former

15 Board members in the audience. If you would

16 raise your hand and stand so others may see

17 you. I just want to appreciate all that

18 you've done to make our job what it is. We

19 want to honor the work that you've done

20 getting us to this point. So thank you all

21 for being here, and I'm sure each of us will

22 lean on you at some point in the next few days
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1 for advice.

2 At this time, I've asked Jean if

3 she would say a note, say a word, kind of set

4 the tone for this spring meeting. Jean? 

5 MEMBER RICHARDSON: Mike asked me

6 to find some sort of quotation that would set

7 the tone for the meeting, as he said. So I

8 found a short "Prayer for Spring" by Robert

9 Frost, who was a farmer and a poet laureate in

10 Vermont. "Oh, give us pleasure in the flowers

11 today and give us not to think so far away as

12 the uncertain harvest. Keep us here all

13 simply in the springing of the year. Give us

14 pleasure in the orchard white, like nothing

15 else by day, like ghosts by night. And make

16 us happy in the happy bees, the swarm dilating

17 round the perfect trees. And make us happy in

18 the darting bird that suddenly above the bees

19 is heard, the meteor that thrusts in with

20 needle bill and off a blossom in mid air

21 stands still."

22 CHAIRPERSON STONE: Thank you,
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1 Jean. That was very nice. So work through a

2 little logistics here we wrestled with. We've

3 gone to a three-day meeting. There's some

4 budgetary considerations in that decision. We

5 have an extremely tight schedule. Michelle

6 worked with Executive Committee and

7 individuals and changed it, hourly it seemed

8 like, a couple of weeks ago. 

9 So, again, we want to respect

10 everyone's time. We want to have time for

11 open and lively debate and discussion. So

12 just be considerate when it's coming to the

13 podium, et cetera, and the Board members are

14 going to respect that, as well. 

15 We did address some special

16 requests because of people's travel schedules,

17 etcetera. So, again, I want to thank Michelle

18 and the Board members. Because we value your

19 input, we did make those special

20 considerations to give each of you all

21 opportunity to address the Board. 

22 We have the agenda before us. I
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1 ask the Board members is there any amendments

2 or adjustments to the agenda that you

3 recommend? Seeing none, I'll take that as

4 approval of the agenda. 

5 So this is our opportunity --

6 working with this Board, we often disagree

7 without being disagreeable. And I think it's

8 really a valuable sort of approach that we

9 have. We're very passionate about our views. 

10 So I just want to remind us, as a group, that

11 we may not have full agreement in the voting

12 process, but I would hope that we go away with

13 100-percent acceptance of the decisions that

14 are made here and advance the industry in a

15 united front. I think it can be very

16 valuable.

17 As far as the public comment, in

18 order to get Michelle, we had 150 and some odd

19 people to sign up. We worked it through. So

20 the Board made a decision that last meeting we

21 went to a four-minute public presentation, and

22 we had three minutes, I think, for questions. 
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1 This agenda is based on five minutes per

2 person, but we left the presentation at four

3 minutes because hearing you all is what's

4 important. 

5 So the Board is going to be

6 sitting on their hands a little bit in the

7 questioning. If you don't get a question,

8 it's not that we didn't appreciate or want to

9 follow-up with you. We're sort of managing

10 the time so that everyone will have access.

11 We just wanted you to know the

12 Board unanimously felt like the four-minute

13 presentation to give you all more time than us

14 to ask questions. So we're a little anxious

15 about how that's going to work, so we're sort

16 of, we'll work through that. We're willing to

17 stay a little longer if we need to to work

18 through all of the decision-making that we

19 have before us.

20 If you weren't here in the fall,

21 Michelle has found us the stoplight. So when

22 you come to the podium, you have four minutes. 
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1 When you see the little yellow light, then it

2 goes to red. I ask you to respect the red

3 light so that you can see -- the yellow light

4 will let you know that you better finish up

5 out of respect to your fellow audience members

6 to have their same four minutes.

7 In the vein of continuous

8 improvement, which is the overarching aspect

9 of the Organic Program -- yes, ma'am? 

10 MS. ARSENAULT: I just want to say

11 one thing about when the red light goes off

12 there's also a very loud obnoxious beep, so

13 you'll know. 

14 CHAIRPERSON STONE: And Michelle

15 is sitting right next to you, by the way. In

16 the vein of continuous improvement, this

17 agenda, this Board is drilling down further

18 for those Board members that came before us

19 and made some very tough decisions. Now we're

20 in a position at this stage of maturity, we're 

21 in our 11th year, I guess, Miles, as a

22 program, that we're drilling down a little
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1 deeper. So how we go about further refining

2 the process and the products that we produce,

3 just glad to have the opportunity in how we do

4 that with the times and restraints that hinder

5 us all in doing what we exactly would like to

6 do.

7 There's been some public comment

8 and constant debate among the Board members,

9 if you will, on this declaration of interest. 

10 Each of us, as we went around, we declared

11 what group we represent. So there's an

12 inherent interest that we have. There's not

13 an inherent conflict of interest. There's an

14 inherent interest that we bring to our

15 position at the Board. 

16 So the Board discusses this when

17 we develop our work plan, which we will post

18 on Thursday, be further refined in committee

19 a little bit. But we want you to know very

20 transparently this is what our work plan is. 

21 Each subcommittee works with the subcommittee

22 chair, works with Executive Committee if they
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1 declare a certain interest or potential

2 conflict. So we, as a board, discuss this and

3 come to an agreement of where an individual

4 Board member stands on a given material or a

5 given discussion.

6 We also have, because we're a FACA

7 board under the USDA, have strict

8 administrative policy that we work under. And

9 the program sort of has oversight to that and

10 can help guide us if there's some debate in

11 our decision-making as a board. I just wanted

12 you to know that the Board makes its own

13 decision and the program has our back, so to

14 speak.

15 Miles will talk in a few minutes

16 about a Sound and Sensible. Again, as the

17 program matures into its 11th year, we are

18 looking at ways to be welcoming and inviting

19 and make sure we gain as many new operations,

20 handling and farming operations. So I think

21 you'll be excited about some of the work that

22 not just the folks at the table but Miles has
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1 a staff of about 30 people in D.C. and around

2 the country that just work equally as hard as

3 Michelle does in their respective areas and,

4 again, making this a more inviting program for

5 all of us because of their hard work. 

6 At this time, I'll ask Calvin, as

7 Secretary, we need to approve or accept the

8 minutes of the previous two meetings. 

9 MEMBER WALKER: Thank you, Mac. 

10 First, we'll do a little housecleaning and we

11 will ask the Board to approve the May of 2012

12 transcript of our biannual meeting in New

13 Mexico, as well as the voting record. And I

14 believe we'll do this by voice vote, as

15 opposed to an individual vote, if that's okay

16 with everyone. 

17 CHAIRPERSON STONE: So you all

18 received those transcripts. Is there any

19 clarifications? Okay. All in favor, say aye.

20 (Chorus of ayes.)

21 MEMBER WALKER: The next one will

22 be the October 2012 Providence, Rhode Island
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1 transcript and voting record. 

2 CHAIRPERSON STONE: Any

3 clarifications, questions? All in favor, say

4 aye.

5 (Chorus of ayes.)

6 CHAIRPERSON STONE: Very good. 

7 Thank you. Good. Thank you, Calvin. So,

8 last, I just want to make sure, some of you

9 may not be able to stay until Thursday but to

10 let everyone know that I'll be fortunate to be

11 hosting this meeting in the land of the last

12 two national championship basketball teams in

13 Louisville in the fall. So welcome you to,

14 invite you to Louisville in October. It's a

15 beautiful time to be there, so we look forward

16 to hosting the meeting in Louisville in

17 October. 

18 With that, I'll turn it over to

19 Miles. Thank you, Miles. 

20 MR. MCEVOY: All right. Just

21 getting set up here. Okay. We're going to

22 start with a celebration of Portland here,
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1 just to get everybody in the right mood. We

2 have a little clip from the Portlandia series

3 here. It's both a celebration of Portlandia

4 and the very difficult decisions that you have

5 to do here at the NOSB. So let's let it roll

6 here. 

7 (Whereupon, the following video

8 was presented.)

9 FEMALE SPEAKER 1: Thank you for

10 buying me that bag the other day.

11 MALE SPEAKER: Come on. It's more

12 for me than you.

13 FEMALE SPEAKER 1: God, you have

14 beautiful eyes.

15 MALE SPEAKER: Everyone tells me

16 that.

17 FEMALE SPEAKER 1: I'm the only

18 one that told you that.

19 MALE SPEAKER: No, I don't mean,

20 like, in a flirting way. But people, when I

21 was kid, like, you've got great eyes, and it's

22 like I'm just a guy.
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1 FEMALE SPEAKER 1: You're my guy.

2 MALE SPEAKER: I am your guy.

3 FEMALE SPEAKER 2: Hey, guys.

4 FEMALE SPEAKER 1: Hello.

5 MALE SPEAKER: Hi, hello.

6 FEMALE SPEAKER 2: My name is

7 Dana. I'll be taking care of you today. If

8 you have any questions about the menu, please

9 let me know.

10 FEMALE SPEAKER 1: I guess I do

11 have a question about the chicken. If you

12 could just tell us a little bit more about it.

13 FEMALE SPEAKER 2: The chicken is

14 a heritage breed, woodland-raised chicken

15 that's been fed a diet of sheep's milk, soy,

16 and hazelnuts.

17 MALE SPEAKER: This is local?

18 FEMALE SPEAKER 2: Yes,

19 absolutely.

20 MALE SPEAKER: I'm going to ask

21 you just one more time: and it's local?

22 FEMALE SPEAKER 2: It is.
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1 FEMALE SPEAKER 1: Is that USDA

2 organic or Oregon organic or Portland organic?

3 FEMALE SPEAKER 2: It's just all

4 across the board organic.

5 MALE SPEAKER: Hazelnuts? Those

6 are local?

7 FEMALE SPEAKER 1: How big is the

8 area where the chickens are able to roam free?

9 MALE SPEAKER: I'm sorry to

10 interrupt. I have exactly the same question.

11 FEMALE SPEAKER 2: Four acres. 

12 Give me just a second. I'll be right back,

13 okay?

14 FEMALE SPEAKER 2: Okay. 

15 FEMALE SPEAKER 1: We're doing the

16 right thing.

17 MALE SPEAKER: I'm too apologetic.

18 FEMALE SPEAKER 1: You are.

19 MALE SPEAKER: I drove way too

20 slow here today, didn't I?

21 FEMALE SPEAKER 1: No.

22 MALE SPEAKER: I am so weird at
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1 the gas pedal. The thing that just moves the

2 whole vehicle forward and I --

3 FEMALE SPEAKER 2: All right. So

4 here is the chicken you'll be enjoying

5 tonight.

6 MALE SPEAKER: This is fantastic.

7 FEMALE SPEAKER 2: Absolutely. 

8 His name was Collin. Here are his papers,

9 okay?

10 MALE SPEAKER: This is great. He

11 looks like a happy little guy who runs around. 

12 A lot of friends, other chickens as friends,

13 putting his little wing around another one,

14 kind of, like, palling around?

15 FEMALE SPEAKER 2: I don't know

16 that I can speak to that level of intimate

17 knowledge about him. They do a lot to make

18 sure that their chickens are very happy.

19 FEMALE SPEAKER 1: When you say

20 "they," I mean, who are these people raising

21 Collin?

22 FEMALE SPEAKER 2: It's a farm
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1 that's located about 30 miles south of

2 Portland.

3 MALE SPEAKER: And, and, and, and,

4 and, and you feel like you have a good

5 relationship with this farm?

6 FEMALE SPEAKER 2: We do.

7 MALE SPEAKER: But it's not some

8 guy on a yacht who lives in Miami and --

9 FEMALE SPEAKER 2: Oh, goodness,

10 no.

11 MALE SPEAKER: - who's just saying

12 that he's organic?

13 FEMALE SPEAKER 1: It just tears

14 at the core of my being the idea of someone

15 just cashing in on a trend, like organic.

16 FEMALE SPEAKER 2: No. I know the

17 type. No.

18 MALE SPEAKER: I'll tell you what. 

19 We're going to go check it out, if you don't

20 mind, just if you could just hold our seats. 

21 Yes, we'll be right back. We just want to

22 make sure.
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1 FEMALE SPEAKER 1: Thank you so

2 much Dana.

3 FEMALE SPEAKER 2: Sure, sure.

4 (Whereupon, the video presentation

5 was ended.)

6 MR. MCEVOY: Okay. Welcome to

7 Portland. Okay. So as usual, there's a lot

8 to talk about, and the theme of this is Sound

9 and Sensible, but I'm going to give an update

10 on a number of things going on at the USDA

11 National Organic Program in response to some

12 of the things that we've been doing to

13 implement the National Organic Standards Board

14 recommendations.

15 First of all, I'd like to start

16 with why organic, why are we all here? 

17 There's lots of important reasons to support

18 organic agriculture: environmentally-sound

19 farming systems, biodiversity, less toxic

20 inputs. I was in the orchards yesterday and

21 remembering when I was young and would pick

22 fruit in the fall in the orchards. At that
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1 point, with a young family, there were, I

2 think, two organic orchards in Washington

3 state. And so, of course, we weren't working

4 on the organic ones. We were working on the

5 conventional ones, and they would spray

6 things. And at that young age, I didn't know

7 what the hell they were spraying, but it

8 certainly made me very uncomfortable, having

9 two young children in the orchard. And the

10 growth in organic agriculture has just been

11 great to reduce the amount of toxic pesticides

12 that have been used on so many acres around

13 the country, especially in apple production. 

14 So it's really a testament to the good work of

15 the organic agriculture community. 

16 Animal welfare, another really

17 important concept in organics that's part of

18 the standards. And then the economic

19 development opportunities, the rural

20 development. There's 500,000 jobs in organic

21 agriculture in the U.S. and more and more

22 every year, lots of opportunity for young and
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1 beginning farmers to get into organic

2 agriculture.

3 Next, why is certification

4 important? So this is the keystone of the

5 whole process, to make sure that those organic

6 claims are verified. Certification allows the

7 use of the USDA organic seal in that organic

8 claim. It empowers those consumers to choose

9 between production methods. So by identifying

10 organic, they can, by the label, they can

11 choose the production methods that they

12 support. It's also a gateway to various USDA

13 services in terms of crop insurance and EQIP

14 funding. It verifies that products meet

15 national organic standards; protects consumers

16 to make sure that when they buy organic they

17 are getting organically-produced and processed

18 products, no matter if it's grown locally or

19 coming in from overseas; and it establishes a

20 level playing field for farmers, processors,

21 and marketers so that they have a fair

22 competition.
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1 So there's been ten years, a

2 little over ten years of USDA Organic Program. 

3 We currently have 85 accredited certifying

4 agents, 25,000 certified operations across 133

5 countries, so it's a global program, lots of

6 farmers involved, not just in the U.S. but

7 across the globe, to supply products in the

8 organic arena. It's a lot of work for the

9 certifiers and the accreditation agencies and

10 everyone to oversee since it has that global

11 scope. Thirty-one billion dollars in U.S.

12 organic sales in 2011, and tens of thousands

13 of inspections, reviews, and certification

14 decisions that are made every year, so lots of

15 judgments, lots of determinations are made by

16 certifying agents on the farms, on the

17 processors, on the whole process.

18 Just a little bit about the NOP

19 budget. For fiscal year 2013, we have a 5.1

20 percent reduction from fiscal year '12. So

21 everybody in D.C. and the federal government

22 is undergoing some very difficult budget
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1 times, so that is difficult for us, as well. 

2 We have about one NOP staff person to oversee

3 about $1 billion in sales, so it's a pretty

4 good return on investment. But it's a lot to

5 do with a very small staff.

6 With the non-passage of the farm

7 bill, there's no national organic

8 certification cost share program for this

9 year. That's kind of a bummer. We have

10 strained resources. And what our question is

11 at the National Organic Program is how do we

12 maintain and support a sustainable program and

13 staff? In the whole spirit of organic

14 agriculture, we also have to take care of the

15 people that are involved in doing the work. 

16 And I have an amazing staff that make me look

17 good that do a lot of work on behalf of

18 organic agriculture, but they have an

19 incredible workload. They work very long

20 hours and you've really got to be careful to

21 take care of them, to retain them, and stay

22 away from burnout and have realistic
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1 expectations of what we can accomplish.

2 All right. On to National Organic

3 Standards Boards, some feedback or progress

4 reports on implementation of our

5 recommendations and some other matters. First

6 of all, on nanotechnology, in October 2010,

7 the NOSB recommended, made a recommendation on

8 engineered nano materials. We responded to

9 the NOSB that we understand that the NOSB

10 considers that nano materials to be synthetic

11 and that they're prohibited under the organic

12 regulations. In December 2010, we responded

13 to the recommendation and said that it would

14 be difficult to identify and verify the

15 absence of nano materials in organic products

16 and that NOP needed more information about how

17 nano materials are defined, regulated, and

18 used in agricultural products.

19 So we have been involved in a

20 number of efforts to respond to the

21 recommendations. Some of the things that

22 we've done based on this recommendation, in
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1 April of 2011 we began participating in the

2 White House Emerging Technologies Interagency

3 Policy Coordination Committee. That's quite

4 an acronym there, ETIPC. That reviews

5 policies and provides to other agencies, like

6 FDA and EPA, on nanotechnology issues as they

7 relate to organic regulations.

8 In November, we briefed these

9 representatives that serve on the ETIPC on the

10 NOSB recommendation on nano materials, and we

11 requested information from them, including any

12 definitions that are currently being used that

13 we could synthesize to inform the Board on the

14 activities on nano materials and

15 nanotechnology at the federal level. We're

16 currently synthesizing that information and

17 will be providing an overview, a summary of

18 that, to the Board later this year. 

19 Conflict of interest that Mac

20 mentioned. Just recently, on March 29th, we

21 sent a memo to the Board on conflict of

22 interest guidelines memo. It addresses how to
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1 recognize and report conflicts of interest. 

2 It reaffirms that NOSB members are

3 representatives, that they're appointed to

4 speak for the interest of a particular group. 

5 So that's the whole way that the Board has

6 been set up is to have representatives that

7 have interests. You're supposed to have

8 interests, and you're supposed to

9 representative those interests as you work on

10 the Board.

11 The memo provides guidelines and

12 examples of standards of conduct and

13 procedures for assessing and declaring

14 conflicts. In terms of standards of conflict,

15 it outlines some of the various expectations

16 that the Board members don't accept improper

17 gifts, that you don't use your Board

18 appointments for private gain, that you use

19 government property and time properly, that

20 you don't engage in partisan political

21 activities while you're engaged in Board

22 activities.
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1 In terms of acceptable interests

2 versus conflicts of interest, you have

3 interests, there are acceptable interests. An

4 interest of a Board member that's acceptable

5 is one that is done on behalf of a represented

6 group and the member receives no

7 disproportionate benefit. That's the real key

8 here is this concept of disproportionate

9 benefit.

10 A conflict of interest is where a

11 member of the Board would have an interest

12 that directly and disproportionately benefits

13 the member, could impair the objectivity in

14 representing the group's interests, or could

15 create an unfair competitive advantage. So

16 the memo goes into some detail on that.

17 The procedure on conflict of

18 interest is NOSB members identify interests on

19 the various proposals that they're working on. 

20 Those interests that directly and

21 disproportionately benefit a member lead to

22 recusal from voting on that proposal at the
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1 meeting. The recusals will be announced at

2 the meeting at each subcommittee session, so

3 this will be covered during the course of the

4 meeting at the beginning of each subcommittee

5 session.

6 And in terms of just an overview

7 of the interests that have been represented to

8 the program, there's no expectation for any

9 recusals on the current proposals that are in

10 front of the Board for this meeting. They

11 have interests but no disproportionate

12 interests, and they are expected to represent

13 their interest groups.

14 The Board also has a public

15 communications proposal that would establish

16 a year-round public communication tool so the

17 public can submit comments to the NOSB and the

18 NOP at any time of the year. The NOP supports

19 this proposal as a tool for encouraging

20 openness and transparency. If the proposal

21 passes, we will identify an appropriate tool

22 and develop an implementation plan to launch
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1 it. And would plan and launch that public

2 communications mechanism closely. We will

3 coordinate closely with the Board if you pass

4 that proposal.

5 Moving on to aquaculture. We have

6 a team that's working on developing a proposed

7 rule on aquaculture. It's under development. 

8 They are currently working on the explanatory

9 text, how we are addressing the NOSB

10 recommendation, the intent of the regulation,

11 how it will be implemented and enforced, and 

12 it's a complicated process. So it's still

13 going to take a while before we have a

14 proposed rule that's published. First, we

15 have to finish the work, and then it has to go

16 through clearance. And because of the many

17 agencies that are involved in aquaculture, the

18 interagency clearance could take some time. 

19 We are hoping to have a proposed aquaculture

20 rule out by the end of the year, but you know

21 how things go. Sometimes it takes longer than

22 we think.
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1 There's been a lot of new guidance

2 and policies that have come out over the last

3 six months. We have a new guidance on the use

4 of kelp in organic livestock feed. Kelp is on

5 205.606. It's identified as an agricultural

6 ingredient that must be organic, unless it's

7 not available in organic form. And so the new

8 guidance says that kelp in livestock feed must

9 be certified organic after March 4th, 2014. 

10 We have new guidance on seeds,

11 annual seedlings and planting stock in organic

12 crop production. This is partially

13 implementing NOSB recommendations on organic

14 seeds and commercial availability of organic

15 seeds. It describes equivalent variety and

16 commercial availability requirements, and it

17 outlines substances and types of treatments

18 that are allowed and what needs to be verified

19 by the certifying agent.

20 We also have new guidance on

21 evaluating allowed ingredients in sources of

22 vitamins and minerals in livestock feed. It
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1 clarifies the permitted ingredients in

2 livestock feed, addresses how to review feed

3 supplements and additives for compliance.

4 We have a new policy memo on cell

5 fusion techniques that are used in seed

6 production. It clarifies which techniques

7 used in seed fusion are considered an excluded

8 method and prohibited, and that policy memo is

9 consistent with the view of cell fusion in

10 organic agriculture that Canada, the European

11 commission, and Codex have, as well.

12 We have just recently published

13 draft guidance for comment, so this is open

14 for public comment, both on classification

15 materials and materials for organic crop

16 production. These are, especially the

17 classification materials, is an NOSB series of

18 recommendations that we're now putting into

19 guidance. That's in three parts. There's the

20 draft guidance on classification of materials

21 itself and then two decision trees, one

22 synthetic/non-synthetic and one
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1 agricultural/non-agricultural decision tree. 

2 So we look forward to all the public's

3 comments on the classification of materials.

4 We also have draft guidance

5 published on materials for organic crop

6 production, which has an overview of materials

7 for organic crop production that are allowed

8 and then prohibited materials. This is,

9 basically, analogous to the OMRI generic

10 materials list, and we'll be working on

11 additional materials for organic livestock

12 production in the future.

13 Comments are due by June 3rd. And

14 this particular draft guidance is addressed

15 for NOSB recommendations on classification. 

16 We also have new instructions on

17 responding to results from pesticide residue

18 testing. In January, we provided initial

19 overview of this at the annual certifier

20 training, and we published this new

21 instruction on March 4th. The goal is to

22 ensure certifiers interpret and respond to
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1 pesticide residue testing results in a

2 consistent manner and facilitate compliance

3 with the new residue testing rule that was

4 effective on January 1st.

5 We also have a report that was

6 just issued on biotech test methods. Last

7 year, the OIG recommended that NOP conduct a

8 study of testing methods that may be used to

9 detect the presence of genetically-modified

10 materials in organic livestock feed. So this

11 report summarizes the current guidance that is

12 available to certifiers and producers

13 regarding the sampling and testing for GM

14 material. It describes testing methods that

15 are currently used to test organic livestock

16 feed products for the presence of GM, and it

17 discusses sampling methods that can be used to

18 back up that testing technology. So this is

19 a very good resource for certifiers to use if

20 they're doing GM testing as part of their

21 residue testing program.

22 We also have a new report on a
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1 modernized organic database. We currently

2 post a searchable list of certified organic

3 operations once a year. A more modernized

4 system is needed to provide up-to-date

5 information about certified organic operations

6 across the supply chain. This would help for

7 a lot of different reasons, for better access

8 to information, better marketing information,

9 but also for compliance and enforcement to

10 understand who's doing what.

11 The needs assessment and business

12 requirements analysis report describes the

13 primary needs that would guide the technology

14 design and development efforts for a

15 modernized certified organic operations

16 database. So it really outlines the specifics

17 of what we need in this modernized database. 

18 It's a great report. The only problem is that

19 we can't move on this particular project

20 unless we get funding for doing this work. It

21 would cost money that we do not have. But

22 there's great information there.
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1 Just wanted to briefly go over our

2 request for the NOSB to review other

3 ingredients. We requested that the NOSB

4 clarify what other ingredients are allowed in

5 non-agricultural substances that are listed

6 under 205.605.

7 The NOSB, in our memo to the

8 Board, the NOSB needs to develop a

9 comprehensive recommendation on other

10 ingredients in 205.605 substances. This is

11 what we requested the Board to do in November

12 2011. 

13 In the meantime, the NOSB should

14 include references to other ingredients in the

15 background on their recommendations. Any

16 recommended restrictions should be part of the

17 recommended annotation.

18 And then clarification from the

19 NOSB regarding the allowance or restriction of

20 other ingredients will provide consistency to

21 the organic trade, consumers, and certifiers,

22 as the NOP codifies these recommendations into 
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1 regulations. So we really appreciate the work

2 that's done on other ingredients and look

3 forward to the discussions on that particular

4 topic, as we work towards clarifying what

5 other ingredients, ancillary substances, are

6 allowed in processed organic food products

7 under 605 and 606. 

8 We are going to formalize a memo

9 to the Board on the National List petition

10 guidelines and procedures. The current

11 petition process was finalized in 2007. It

12 was a Federal Register notice. And then

13 there's also the petition process that's in

14 the National Organics Standards Board Policy

15 and Procedures Manual.

16 What we're requesting the Board to

17 do is to look at the annotation changes and

18 removals and to revise that to ensure that

19 there's sufficient information is provided,

20 that the petition process in the Policies and

21 Procedures Manual is updated to reflect

22 current practices, because it's not currently
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1 aligned with current practices. We're

2 requesting that the petition process should be

3 revised so that confidential business

4 information is not accepted as part of the

5 petition and that the petition process should

6 be updated to ensure timely technical report

7 requests and approval of those technical

8 reports. 

9 So we've sent this information to

10 the Board. We'll be following it up with an

11 official memo that will go on to the

12 correspondence page on the NOP website in the

13 near future. 

14 Just a little update on the

15 Organic Literacy Initiative, which was

16 launched in September of 2012. This was the

17 initiative to connect organic producers and

18 handlers with USDA programs. There's a lot of

19 USDA programs that support organic

20 agriculture. The NOP is just one of many. We

21 have an organic 101 and 201 training module to

22 explain the basics of organics. And as of
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1 March 2013, over 10,000 USDA employees have

2 completed the training. So this is a really

3 great outreach tool that we've implemented,

4 really trying to get field offices around the

5 country to better understand organic

6 agriculture so that they can support the

7 continued success and growth of organic

8 agriculture.

9 Okay. So a lot of things, we've

10 gotten a lot of things done, and we have a few

11 more things that we have to do. So in terms

12 of focus areas for the somewhat near future,

13 National List rulemaking. We have Sunset

14 2013. We'll have a proposed and final rule

15 out very shortly. We have a sodium nitrate

16 proposed rule that will be out this year. 

17 That's past due, as you all know. The sodium

18 nitrate sunsetted or expired in October of

19 last year, and so we're behind on that

20 particular rulemaking docket. We have a new

21 listings proposed rule that will be coming out

22 shortly.
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1 In terms of practice standards,

2 we're working on origin of livestock, pet

3 food, aquaculture, and apiculture. And

4 Melissa assures me that all four of these will

5 be out later this year. No, but we've

6 actually made a lot of progress on all four of

7 these practices standards, and there's a good

8 chance that they could be out later this year. 

9 Yes. And she says, "I think so." At least

10 some of them is what she said. Okay. 

11 Other focus areas: guidance

12 documents; grower groups; inspector

13 qualifications; handling unpackaged organic

14 products which is an NOSB recommendation that

15 we're working on implementing; biodiversity;

16 and materials for organic livestock

17 production. Other focus areas are continuing

18 to verify international trade partnerships;

19 increasing international market access, in

20 particular we're looking at an equivalency

21 arrangement with Japan; and reducing the

22 certification burden on diversified direct
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1 marketing operations, which I'm going to talk

2 about with the Sound and Sensible part.

3 So let's just move right into

4 Sound and Sensible: How to Maintain Organic

5 Integrity in a Sound and Sensible manner. So

6 we've been working on this now since, really

7 I think the real starting point was when

8 Bonnie from MOSA was the last speaker at the

9 Providence NOSB meeting, and she's retiring

10 from certification work, going back to being

11 an organic farmer, and just is overwhelmed by

12 the paperwork that she has to fill out to

13 maintain her certification. So it was a very

14 compelling argument that maybe we need to re15 look at this whole certification process to

16 make sure that we're focusing on the right

17 parts, verifying organic production but doing

18 it in a way that's not overly burdensome to

19 operators.

20 So the current landscape. We have

21 ten years of implementation of the National

22 Organic Program. We've really created a very
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1 complex regulatory scheme. It's a very strict

2 process-based oversight from farm to market. 

3 Lots of different elements are components and

4 can make it very complicated and burdensome to

5 operators to comply with.

6 Some of the issues. An

7 inconsistent certification process. We noted

8 this during our accreditation audits. That's

9 gotten better over the last few years, but

10 there's still not complete consistency between

11 certifiers. Maybe some of that is good. 

12 There's a focus on record keeping and a

13 corresponding burden. The expense of

14 certification. That's not just the direct

15 expenses of the fees, but it's also the time

16 involved in maintaining the records and being

17 inspected. And we also know that there are

18 many farms that comply with the organic

19 standards, but they avoid certification for

20 various reasons. They don't need it for their

21 marketing purposes. They try to do work22 arounds. But there are many farms that comply 
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1 with the basic requirements but avoid getting

2 certified.

3 So what we're trying to do is move

4 it to a more sound and sensible process. So

5 we have this little chart here where we're

6 trying to stay out of the red. We kind of

7 describe our current state as the blue in the

8 upper left where we have a good process, but

9 it's a bit burdensome and paperwork-intensive. 

10 It addresses all the factors involved in

11 organic integrity, but it really needs some

12 streamlining. But what we want to do is avoid

13 going into the red. We don't want to

14 streamline the process and lose integrity, so

15 we're looking to move to the right, to the

16 green, an efficient certification process that

17 focuses on the key elements to preserve

18 organic integrity. Okay. It sounds good.

19 So the goal is to make organic

20 certification affordable, accessible, and

21 attainable for all operations. What we mean

22 by affordable is reasonable fees for all sizes
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1 of operations and reasonable compliance costs

2 because it's not the direct costs, it's the

3 other costs, as well. Accessible to

4 certifiers and technical assistants so that

5 those things are available locally. In some

6 areas of the country, there's great resources

7 available. In other parts of the country, not

8 so much. And then attainable so that

9 operators can understand what the standards

10 are. If they understand it, they're more

11 likely to be able to comply. Using plain

12 language with reasonable record-keeping

13 requirements.

14 So we have some current

15 initiatives that we have been working with. 

16 We have a business process survey working with

17 Vela Environmental, that they're looking at

18 some of the key certification barriers for

19 small businesses and identifying ways to

20 reduce the paperwork burden. The NOSB is

21 working on this with their Continuous

22 Improvement Initiative, how to certify the
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1 process rather than the paperwork. There's

2 been good discussion from the certifiers

3 group. And then we've got many different

4 ideas from certifying agents to help us work

5 towards a more sound and sensible process.

6 We've come up with sound and

7 sensible principles. We'd like the Board to

8 take a look at these sound and sensible

9 principles and look to see is this a way that

10 we should move forward on certification and

11 the whole organic certification process.

12 So those principles include five

13 things: efficient processes, eliminating the

14 bureaucratic processes that do not contribute

15 to organic integrity. We want to keep those

16 processes that do lead to organic integrity

17 but eliminate those bureaocratic processes

18 that do not contribute to integrity. 

19 Streamlining the record-keeping to ensure that

20 records support organic integrity and are not

21 a barrier to farms and businesses to

22 maintaining compliance. We don't want to make
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1 it so complex that people can't comply. 

2 Having practical plans that support simple

3 organic system plans that capture organic

4 practices. Fair and focused enforcement. 

5 Focus our enforcement efforts on willful

6 egregious violations and handle minor

7 violations in a way that leads to compliance. 

8 Publicize how enforcement protects the organic

9 market. And then integrity first, so maybe

10 that should be number one, but focusing on

11 factors that impact organic integrity the

12 most, building consumer confidence that

13 organic products meet defined standards from

14 farm to market.

15 So those are the principles that

16 we've been working with at the program level,

17 and it really has changed the way that we make

18 decisions on enforcement cases and in our

19 accreditation process. 

20 So one of the things that we've

21 done so far is, on the penalty matrix, we got

22 a lot of feedback from certifiers about the
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1 penalty matrix. We took another look at the

2 penalty matrix, and we saw that it was really

3 record-keeping focused. We published it last

4 September to provide guidance to certifiers on

5 penalties for various types of violations. It

6 was done in the spirit of progressive

7 corrective action, but it does overly focus on

8 paperwork.

9 So in the spirit of sound and

10 sensible, we are reworking or revising the

11 penalty matrix. And we have archived the

12 penalty matrix, taken it off of the active

13 list, and will update that penalty matrix in

14 the future when we finish the revisions.

15 The second thing that we're doing

16 is retraining our auditors. The auditors are

17 the ones that go out and audit the certifying

18 agents to determine that they're meeting the

19 accreditation and certification criteria. 

20 We've noted that there's some variability in

21 terms of how auditors have done the audits

22 over the last few years. So we have a week
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1 long training in early May for all NOP

2 auditors, both the ones that work out of the

3 grading and verification division and the ones

4 that work directly for the National Organic

5 Program.

6 Some of the topics that we'll be

7 covering are organic system plans, updates,

8 and notification; what is an adequate record;

9 how can certifiers and inspectors provide

10 technical assistance; five steps to

11 certification; what are the requirements

12 around organic certificates; and grower

13 groups; as well as many other topics. 

14 We're also working on some new and

15 revised instructions. We have new

16 instructions on technical assistance that was

17 just published yesterday. We're working on a

18 new instruction for organic system plans,

19 organic system plan updates and notifications,

20 and then also on performance evaluations and

21 program reviews. And then revisions to the

22 penalty matrix, five steps to certification,
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1 organic certificates, and records. So lots of

2 things going on in this realm of accreditation

3 and certification and more resources for

4 certifiers.

5 In terms of the technical

6 assistance, in 205.501(a)(8), it requires

7 certifiers to provide sufficient information

8 to operations to enable them to comply with

9 the regulations. So certifiers are compelled

10 by the regulations to provide information to

11 farmers, producers, and handlers about the

12 regulations. They're supposed to answer

13 questions, provide help, basically, to the

14 operation so that they can comply. 

15 On the other hand, 501(a)(11)(4)

16 prohibits inspectors from consulting. So what

17 we did in this technical assistance

18 instruction is try to make that distinction. 

19 Yes, you have to provide information, you have

20 to educate the operations, you have to answer

21 questions. But you can't provide them with

22 specific advice to overcome barriers to
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1 certification. 

2 So we clarify that in the

3 technical instruction. We'll be deepening

4 that understanding of that instruction with

5 webinars in the future. The instruction does

6 provide some examples.

7 So this tries to make the

8 distinction that technical assistance is broad

9 in general information, educational in form,

10 and it's available to everyone, including the

11 general public, whereas consulting is specific

12 advice directed to an individual operation and

13 not publically available. So technical

14 assistance is allowed and encouraged. 

15 Consulting is not allowed by a certifier or an

16 inspector.

17 We also are working on new

18 instructions on organic system plans, organic

19 system plan updates, and notification. We are

20 distinguishing between organic system plan

21 updates and notifications. So an organic

22 system plan is something that an organic
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1 operator, producer, and handler needs to have

2 to get their certification started. On an

3 annual basis, once a year, they need to update

4 that plan to keep it current. 

5 And then they're also required to

6 notify the certifier for specific situations

7 but only for specific information. In the

8 case of pesticide drift, they have to

9 immediately notify the certifier. For the

10 application of a prohibited substance, they

11 have to immediately notify the certifier. And

12 then there's this other part that says any

13 change that would affect compliance. 

14 And so in this new instruction,

15 what we will do is to go into more detail of

16 what are those types of changes that would

17 affect compliance that require immediate

18 notification versus those things that don't

19 require immediate notification that you just

20 update at your next annual update and trying

21 to reduce that burden on the certified

22 operation. So only things that are really
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1 important need to be notified.

2 Okay. So, overall, the key

3 message is to certifiers or that certifying

4 agents must ensure organic integrity while

5 setting sensible limits on paperwork. They

6 need to obtain enough information to verify

7 compliance but to minimize the amount of

8 documentation required for certification. So

9 it's that balancing act of doing enough but

10 not too much.

11 But they still, we still want to

12 reemphasize that they have to do enough. I

13 mean, one of the things that we find during

14 accreditation audits is that some certifiers

15 are not doing enough and they need to up their

16 game a little bit. So it's not just that they

17 have to reduce the record-keeping

18 requirements. They have to meet that sound

19 principle to start with.

20 So, in summary, sound and

21 sensible, we say that certification should be

22 sound, verifying and enforcing compliance, and
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1 taking action on non-compliances. Certifiers

2 must take action on non-compliances when there

3 are things that need to be improved that are

4 violations. Those things need to be

5 addressed. But it also needs to be done in a

6 sensible way, reasonable records that verify

7 compliance and educating clients on what the

8 requirements are.

9 And then also, in this whole

10 concept of sound and sensible, we're

11 recommending to the Board that NOSB

12 recommendations should embrace this concept,

13 that your recommendations should be sound,

14 maintaining and upholding organic principles

15 of biodiversity, continuous improvement,

16 biological pest management, soil building, all

17 those various principles of organic. But they

18 also should be sensible, really reasonable for

19 producers and handlers so that they can

20 actually be successful in organic agriculture

21 and the recommendations that you make are not

22 overly burdensome on the organic operators. 
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1 No undue burdens on small businesses. That's

2 something that we, as a program, always have

3 to do in our rulemaking is make sure that we

4 don't have any undue burdens on small

5 businesses. So really think about that as

6 you're working on your recommendations and

7 that they're implementable -- I think that's

8 a word, implementable -- and enforceable so

9 that we can actually enforce the

10 recommendations that you put forward.

11 Okay. So thank you very much, and

12 any questions or comments? 

13 CHAIRPERSON STONE: Any questions

14 for Miles? Zea?

15 (Off mic comments.)

16 MR. MCEVOY: Yes, it's on our

17 website. We can send you the link. 

18 MEMBER SONNABEND: And what?

19 MR. MCEVOY: We can send you the

20 link for that.

21 CHAIRPERSON STONE: All right. 

22 Any other questions for Miles? Thank you,
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1 Miles. And on behalf of my brothers and

2 sisters in the certification world, I think,

3 often, people do not appreciate how diligent

4 and how much effort individual staff people at

5 the certification agencies do to verify the

6 integrity of all of their clients. And this

7 Sound and Sensible is a way for them to be

8 more relaxed and helpful in maintaining that

9 without, with maintaining the regulation but

10 also in a way that is very user friendly and

11 welcoming. So we appreciate all the work the

12 Program has put into working through the

13 accreditation of them and helping them become

14 comfortable with a more sound and sensible

15 process. So thank you very much.

16 Okay. We're going to jump right

17 into the public comment period. Michelle,

18 again, we have the -- I see the green light.

19 She has to restart it, the timing. There will

20 be the on-deck circle, which will be kind of

21 over Michelle's right shoulder there.

22 So first up we have Mr. Will
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1 Fantle, and Don Finley is on deck.

2 MR. FANTLE: All right. My name

3 is Will Fantle. I'm the co-director of the

4 Cornucopia Institute. I've got some sad news. 

5 We're now experiencing a net loss of organic

6 farmers in this country in certain parts of

7 this great nation of ours. The Rocky Mountain

8 states, the Midwest, USDA numbers indicated a

9 decline in organic farmers last year.

10 Ethical organic producers,

11 generally family farmers, cannot compete with

12 massive imports of dubious pedigree from

13 China, India, and former Soviet Bloc

14 countries. Ethical farmers can't compete with

15 large-scale fraud and factory farms with

16 upwards of 10,000 cows or a million laying

17 hens. This is why consumers, in part, have

18 switched to organics for, to try to avoid

19 these types of things. 

20 Cornucopia continues to be

21 concerned with improprieties in the execution

22 of the Organic Foods Production Act of 1990,
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1 known as OFPA. For example, identities of

2 authors in technical reviews are being kept

3 secret, contrary to the rule in credible

4 scientific publications. In a recent crop of

5 TRs, still our staff was able to identify one

6 scientist who authored the TR, and I wish I

7 was making this up, and also wrote the

8 petition for the corporation involved. 

9 Pretending to enforce conflict of

10 interest oversight while letting companies

11 aggressively lobby to ed or retain materials

12 on the National List and allowing employees of

13 these very same corporations who sit on this

14 board to vote in favor of the interest of

15 their corporate employers is a betrayal of

16 ethics in this industry. There's no shame in

17 acknowledging a conflict of interest and

18 recusing yourself to preserve the integrity of

19 this process that we're all part of.

20 The NOP needs to go back to -- the

21 next slide, please. The NOP needs to go back

22 to letting the NOSB set its agenda. Here's
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1 the law. This is what OFPA says. It's quite

2 clear. The staff director, in other words Mr.

3 McEvoy's position, is codified in law to be

4 appointed by not the Secretary of Agriculture

5 but by the NOSB itself. This should be

6 followed. It's, perhaps, quite likely that

7 Mr. McEvoy would still occupy the position

8 he's in. He's capable and he understands the

9 ins and outs of organics, but the NOSB should

10 be his boss and they should be setting the

11 agenda for this board.

12 Priorities for new materials that

13 industry wants, like aquaculture, might no

14 longer be Board priorities. Instead, the

15 attention of this board might very well be

16 focused on the review of inert ingredients or

17 animal welfare standards for poultry and other

18 livestock.

19 If this was the case, maybe major

20 league accusations of fraud, investigations

21 still languishing since 2010, would be handled

22 on an expeditious basis because the staff
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1 director would serve at the pleasure of the

2 NOSB and the activities of the NOP would be

3 directly accountable to this board.

4 Case in point. I want to draw

5 your attention to a complaint that we have

6 filed with a large egg-laying operation in

7 California. Two years ago this was filed. 

8 It's still languishing. The poultry operation

9 freely acknowledges that the birds have no

10 access to the outdoors and look at how they're

11 selling their eggs. 

12 Two final points. The pre-meeting

13 agenda of the NOSB needs to be public. Don't

14 try to cut days out of the public agenda. And

15 we want to commend, finally, the current NOSB

16 for materially improved oversight of synthetic

17 materials that took place at the last meeting. 

18 Thank you. 

19 CHAIRPERSON STONE: Thank you,

20 Will. Are there any questions for Will? All

21 right. Thank you. We've received your

22 written comments. They're very well done as
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1 well. Thank you very much.

2 Don Finley is on and Cam Wilson on

3 deck. Don? Is Don here? So Cam Wilson is

4 up, I guess. Thank you much. Which puts

5 Steve Walker on deck. 

6 MR. WILSON: My name is Cam Wilson

7 from the company Neudorff, and I'm here to

8 talk about inerts. Dear NOSB, we ask for a

9 clear schedule outlining when each inerts

10 group will be reviewed so resources can be

11 properly planned. Small companies like

12 Neudorff work on set budgets each year, as do

13 you. And without enough lead time,

14 petitioning inerts becomes a serious financial

15 burden to us. We are very concerned about

16 these costs. We cannot afford the same cost,

17 like large companies that have recently

18 entered the organic pesticide market. When

19 will this schedule be available? 

20 We ask for a clear, simple to

21 understand criteria as to how inerts will be

22 evaluated, allowed, or disallowed. The
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1 evaluation should be based on exposure to

2 humans, animals, and the environment, and

3 based on typical usage levels, not the pure

4 substance. Do you agree?

5 If reformulating of our products

6 is required, we need at least three to five

7 years for the development and EPA approval

8 process. We ask for the evaluation to be done

9 by experts in chemical toxicology evaluation,

10 as they have the most experience in this area

11 and whose opinion is currently used by the

12 EPA. Is this the plan?

13 Finally, we'd like the NOSB to

14 consider that the evaluation of the inerts,

15 the petition, and the attendance of meetings

16 will be a financial burden to smaller

17 companies like Neudorff and will ultimately

18 put the destiny of organic farming in the

19 hands of big ag. Is this fair for our company

20 to carry the cost to petition and defend an

21 inert when it can be used by any company for

22 formulating purposes? Please consider
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1 subsidizing an evaluation process. Without

2 your support, U.S. organic farmers may be left

3 with fewer ways to control pests, which will

4 put them at an unfair advantage to imported

5 organic food. Thank you. Any questions?

6 CHAIRPERSON STONE: Thank you,

7 Cam. Any questions? Good. Zea?

8 MEMBER SONNABEND: Not a question

9 as much as a comment, and you'll hear our

10 presentation on this, I believe, on Thursday

11 if you'll stay. You will not be required to

12 petition for individual inerts. There will be

13 a Federal Register Notice where you can turn

14 in your inerts to the Department, if they're

15 not already on the published list but it will

16 not be the same requirements as a full

17 petition.

18 MR. WILSON: Okay. Thanks very

19 much, Zea. Anyone else? Okay. 

20 CHAIRPERSON STONE: All right. 

21 Thank you, Cam.

22 MR. WILSON: Thank you very much.
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1 CHAIRPERSON STONE: Steve Walker

2 and Lianna Hoodes on deck. 

3 MR. WALKER: Good morning. I'm

4 Steve Walker. I'm here representing MOSA. 

5 We're an accredited certifier of about 1,500

6 operations, primarily in the upper Midwest. 

7 We've submitted written comments addressing

8 nine meeting agenda items. I'm going to try

9 to give summaries on our thoughts on all of

10 those here, and then I'd like to tie them

11 together with a word.

12 First, the Materials Subcommittee

13 items. MOSA supports the limited scope

14 technical reviews proposal as a sound,

15 sensible, and efficient approach to review

16 work. Checking threshold issues for deal

17 breakers is a wise use of resources. 

18 We also suggest that criteria be

19 considered for similar limited scope reviews

20 for petitions for National List Sections 605

21 and 606. That might involve citing other

22 parts of OFPA, Sections 6517.
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1 Regarding confidential business

2 information in petitions, MOSA supports

3 recommendation number two that CBI be allowed

4 but with clear stakeholder responsibilities. 

5 Also, when the NOSB reviews CBI, any resulting

6 recommendation must be transparent enough so

7 certifiers know how to rule on our subsequent

8 brand name product reviews.

9 We also suggest that any

10 confidentiality agreements have clear

11 parameters and an organized maintenance system

12 to avoid liabilities. And we believe

13 clarification is needed for defining

14 production aids as used in OFPA 6517. Such

15 clarification should give examples of what's

16 covered and what's not covered by the

17 production aids term. 

18 In the GMO Ad Hoc Subcommittee

19 discussion documents on GMOs and seed purity

20 and on excluded methods terminology, we find

21 logistical barriers to certifiers' ability to

22 verify non-GMO status. These include a
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1 rapidly-changing technological landscape, lack

2 of disclosure regarding methods used, the

3 expertise required to distinguish between

4 excluded methods types and inability to gather

5 information from back in supply chains. It's

6 not currently clear whether it's possible to

7 establish a method for ensuring genetic

8 purity. We think current NOSB research

9 priorities should consider adding exploration

10 of seed GM issues.

11 In the Vaccine Working Group's

12 interim report, we see similar challenges with

13 changing technology, lack of disclosure, and

14 verifying supply chains. Any expectation of

15 verifying vaccines made with excluded methods

16 will need a clear and practical framework of

17 how to determine compliance. Also, even with

18 a stricter rule regarding GM vaccine use,

19 exceptions may be needed for critical vaccines

20 that are only available from GM sources. 

21 We don't usually comment on

22 position materials, but we did comment on
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1 oxytetracycline. We recommend consideration

2 of grower input and extending the date beyond

3 2016 to allow enough time for the development

4 of equivalent fire blight control

5 alternatives. Most producers agree that this

6 material is against the spirit of organics,

7 and we find its use is rare but still critical

8 in maintaining the economic viability of the

9 U.S. organic tree fruit market.

10 MOSA supports the Handling

11 Subcommittee proposal on other ingredients. 

12 We find this to be clear, enforceable, sound,

13 and sensible. Our comments echo those put

14 forth by the Accredited Certifiers

15 Association. The proposal's definition of

16 other ingredients is helpful in framing the

17 discussion. Any NOP instruction or guidance

18 should include a similar clear definition.

19 And, last, we also support the

20 CACS proposal on calculating percentages. It

21 brings clarity to our work and gets into some

22 finer details than have been presented in NOP
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1 training materials. 

2 Lots of comments here, but I think

3 there's a bow that ties them altogether. The

4 word is balance. It's our perennial

5 challenge. We must balance consumer

6 expectation of a strong standard with

7 practical, sensible, and achievable

8 verification that keeps organic operators in

9 mind. 

10 CHAIRPERSON STONE: Very good

11 timing. Appreciate everyone's respect to

12 that. Questions for Steve, a certifier? All

13 right. Thank you very much. I'm sure people

14 will discuss it with you as we move through

15 the week. Thanks, Steve. Lianna Hoodes and

16 Tatiani Molini is on deck. 

17 MS. HOODES: Good morning. I'm

18 Lianna Hoodes with the National Organic

19 Coalition. NOC is a national alliance of

20 organizations working to assure that organic

21 integrity is maintained, consumers' confidence

22 is preserved, and that policies are fair,
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1 equitable, and encourage diversity of

2 participation and access.

3 Our coalition brings together

4 differing interests that all have a stake in

5 the future of organic: the farmer growing the

6 food in the regulated system, the consumer

7 buying organic because it represents specific

8 values that they want to purchase, the

9 businesses that get those agricultural

10 products to the marketplace, and

11 environmentalists who see organic as the

12 alternative, providing a clean and healthy

13 environment.

14 That push to meet consumer

15 expectations can be both a gift and a curse. 

16 Success of this label in the marketplace has

17 helped to bring major gains in moving our food

18 system towards health and sustainability, yet

19 it can be an issue when the expectation of

20 purity and natural meets the reality and

21 practice of farming and the fact that a

22 wholistic systems approach is about process,
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1 not about the final product.

2 But we can lay claim to the food

3 system that is constantly working to get

4 health, environment, and sustainability

5 better. It's often your job, as the NOSB, to

6 bridge that divide and bring transparency to

7 the face of the label, hashing out those

8 differences in the larger community, as well

9 as you hold the torch high to the public, both

10 to the organic consumers and those who aren't

11 buying organic. They know what organic is

12 from your statements.

13 So on your agenda, keep up the

14 momentum on reviewing inerts. Removing toxic

15 inerts from organic is exactly why we're about

16 continuous improvement.

17 Tetracycline. NOC remains neutral

18 on the issue of an extension of use, but we

19 have very strong concerns about the discussion

20 in the subcommittee recommendation because it

21 minimizes the concerns about antibiotic use in

22 organic and misses the point that no
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1 antibiotic use must be a central tenet of

2 organic production. This has, obviously,

3 struck a nerve throughout the community. 

4 There appears to be polarized positions:

5 farmer versus consumer pitched battle. 

6 We don't believe there's that much

7 disagreement. Some of the problems from the

8 marketing of organic products that have been

9 fairly specific in their claims that "organic

10 standards prohibit the use of pesticides,

11 antibiotics, and hormones." That's from a

12 label. Consumers have been shocked and

13 disappointed to hear that antibiotics were in

14 their organic. And truth be told, other

15 materials which were supposed to sunset have

16 just not been coming off the National List. 

17 So consumers want and need assurances that

18 antibiotics are absolutely coming off.

19 The farmers have an agricultural

20 problem. Until recently, there have been no

21 inputs, other than antibiotics, to combat fire

22 blight in apples and pears. The new tools are
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1 just a couple of years away from being usable

2 in all field conditions.

3 The message in the majority

4 recommendation implies that, while antibiotics

5 will eventually be out, the amounts used in

6 organic aren't really that bad. 

7 Unfortunately, in the larger science of

8 antibiotics in our food supply and

9 environment, quantity and residues are not the

10 issue. Any use of antibiotics creates some

11 resistance and end use is incompatible with

12 organic. The NOSB recommendation needs to

13 clearly lead the way with that message, lay

14 out an absolute expiration and lay out

15 specific oversight steps in a directed

16 annotation. Also, from the top, from NOP

17 down, how does that oversight work? 

18 I'm going to skip to other

19 ingredients. NOSB already has a policy for

20 all ingredients. They must be organic or they

21 must be on the National List, and they must be

22 reviewed using OFPA criteria. 
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1 Thank you very much for all of

2 your work, and we hope our comments have

3 helped you.

4 CHAIRPERSON STONE: Thank you,

5 Lianna. Appreciate that. Jay? 

6 MEMBER FELDMAN: Hey, Lianna. 

7 Thank you for your comments. How do you

8 respond to the argument that the program and

9 the NOSB would be overwhelmed if it had to

10 review all the other ingredients? 

11 MS. HOODES: That's difficult. I

12 watch you be overwhelmed. I mean, you have a

13 lot on deck. But, first of all, it's the law. 

14 And, secondly, I take a little lesson from

15 inerts. Is there a way, with inerts that look

16 like they were huge numbers and it's been

17 widdled down to what? A hundred twenty-five

18 or so. So through some more investigation of

19 other ingredients, are there ways to batch

20 them together in their review and make it more

21 manageable? I just don't see a legal way

22 around not reviewing every ingredient. 
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1 CHAIRPERSON STONE: Thank you. 

2 Yes, we're trying to figure that out, so

3 appreciate your input on that. Yes, Nick? 

4 MEMBER MARAVELL: Lianna, what

5 would -- let me give you the topic first. On

6 the issue of tetracycline, you made a

7 statement that you think that there should be

8 some recognition of a hard and fast ending

9 date. How do you see the NOSB expressing a

10 hard and fast ending date?

11 MS. HOODES: There are two pieces

12 of that. Specifically, on tetracycline, you

13 need to have an expiration date, either 2014

14 or some other. It needs to be firm. Can you

15 guarantee there aren't going to be antibiotics

16 from whatever that point forward is? Can you

17 guarantee that there isn't going to be another

18 petition? No. What you can do is make a

19 public statement that's very clear that takes

20 us into the future, that says that antibiotics

21 don't belong in organic because of the

22 principles of health and environment. And
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1 that's -- so in addition to your hard and fast

2 end time, you're stating, for organic, for all

3 time, that it just is not a part of organic. 

4 It's not a regulatory or a legal statement. 

5 It is a principle statement so that, when

6 other boards are faced with a petition, they

7 have really strong absolute guidance. They've

8 heard it from the community and they've heard

9 it from the Board.

10 CHAIRPERSON STONE: Great. Thank

11 you for that. Okay. Tatiani here? Not

12 seeing her. Deborah Gauthier? Gauthier? 

13 Deborah? No Deborah. If you get here, we'll

14 work you back in. Genevieve Perry? 

15 Genevieve? No. Going once, going twice. 

16 Piotr Swider? Piotr? Going, two, three. 

17 Denna Miller? These are signed up under the

18 citizen category. Good. We've got some time

19 for questions, I see. James Garcia? And if

20 there's some confusion, we'll work them back

21 in somehow. James Garcia? No? More

22 questions. Michelle Devlaeminck? 
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1 Michelle noticed that there was

2 some confusion on some sign-ups that, in her

3 email, she had some issues that we thought we

4 had worked through but apparently not so much. 

5 Jeanine Marshall? And they signed up for very

6 specific topics here. 

7 Carmen Artigus? Let me get

8 further down here. Kyla, Kyla Smith, you're

9 up. So Michelle will work if these people

10 show up. So if you think, if your sign-up

11 time was later in the day, you can readjust

12 your watch and get ready sooner, like 30

13 minutes sooner. Thanks, Kyla.

14 MS. SMITH: Okay. Good morning. 

15 My name is Kyla Smith. I'm the certification

16 program director for Pennsylvania Certified

17 Organic. PCO is an NOP-accredited non-profit

18 certifying agency that certifies about 700

19 operations in the Mid-Atlantic region. 

20 I'd like to comment on PCO's

21 support of the Crops Subcommittee's

22 recommendation to extend the expiration date
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1 of tetracycline to October 21st, 2016 to

2 ensure that enough research and education on

3 alternatives is available to organic apple and

4 pear producers. Most of the apple and pear

5 producers we certify either use this material

6 or have it on hand to use if models indicate

7 a severe infection is probable. 

8 Please consider the following

9 points as you deliberate tetracycline. 

10 Research has been underway at the request of

11 NOSB and NOP, but proven alternative practices

12 are not yet available for producers in all

13 geographic regions. The Board must consider

14 that even after alternatives are demonstrated

15 to be effective, it will take additional time

16 for producers to be educated on the

17 alternatives and for the alternatives to

18 become commercially available.

19 Researchers and educators will not

20 have time to complete these steps by a 2014

21 expiration date, as supported by the minority

22 position, and will even be a challenge to
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1 accomplish by 2016. A more realistic time

2 line to end the use of antibiotics in organic

3 apple and pear production would be 2017, which

4 would allow current research projects and

5 field testing to culminate and for this

6 knowledge to disseminated to producers in

7 order to be implemented in true on-farm

8 situations.

9 The sunset process established in

10 the Organic Foods Production Act seemed to be

11 appropriate in 1990 and has continued to work

12 for more than 20 years. When materials are

13 taken out of this process, especially before

14 there are commercially-viable alternatives for

15 producers, it creates unnecessary burdens on

16 stakeholders across the organic community.

17 PCO supports the resolution

18 presented by the subcommittee that commits the

19 organic community to phase out this material,

20 provided that the step-down is in a gradual

21 fashion and allows operators to transition

22 their production practices to use alternative
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1 methods to controlling fire blight. The use

2 of tetracycline as a disease-control material

3 is already controlled by the regulations. 

4 Certifiers are ensuring that antibiotics are

5 only used when other methods in the organic

6 system plans are ineffective. We will

7 continue to uphold these regulations while

8 encouraging more alternatives are tested by

9 producers as they become available until the

10 phase-out is fully implemented.

11 I would also like to provide some

12 comments regarding the Handling Subcommittee's

13 recommendation on other ingredients. PCO

14 strongly supports this recommendation. We

15 would like to reiterate the importance for

16 including prohibitions and/or other

17 restrictions on other ingredients in the

18 annotation or have this included in guidance

19 from the NOP, such as what's provided in the

20 recent draft guidance published by the NOP

21 regarding materials for organic crop

22 production. This would allow consistency and
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1 efficiency among certifiers, as we would be

2 able to look to the regulations for guidance

3 from the NOP, as opposed to digging through

4 previous TRs and/or NOSB recommendations in

5 order to find these other ingredients. 

6 Additionally, we'd like to

7 encourage the other ingredients be annotated

8 categorically. This will also lead to

9 consistency among certifiers and other

10 material review organizations which will see

11 the gamut of these other ingredients in

12 reviewing brand name materials.

13 Lastly, we support the segregation

14 of non-food substances onto their own list. 

15 These non-food substances do not make up any

16 part of the composition of the organic food

17 product and, in the case of several of these

18 materials, do not ever come into contact with

19 food. It would be logical to review these

20 materials according to baseline criteria that

21 are relevant to their use. 

22 Thank you so much for all of your
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1 time and hard work.

2 CHAIRPERSON STONE: Thank you,

3 Kyla. Questions? Yes, Jay? 

4 MEMBER FELDMAN: Thank you for

5 your comments. Has PCO evaluated the

6 potential adverse effects of using antibiotics

7 in apple and pear production? 

8 MS. SMITH: Meaning? 

9 MEMBER FELDMAN: Well, your

10 testimony is about the need. That's what I

11 heard mostly. Have you guys looked at --

12 MS. SMITH: How many producers

13 would leave? 

14 MEMBER FELDMAN: Well, the adverse

15 effects on public health possibly of the

16 chemicals used.

17 MS. SMITH: We believe that there

18 is, yes, certainly a public health issue in

19 using antibiotics. We don't believe that it

20 is aligned with organic principles. But we

21 believe that, you know, you can't just, as Liz

22 discussed at the NOC meeting yesterday,
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1 somebody is trying to learn how to walk, rip

2 the crutches right out of them before they

3 have, you know, viable alternatives to help

4 them. 

5 MEMBER FELDMAN: Even given the

6 history of the NOSB as it attempts to remove

7 the material over the last decade?

8 MS. SMITH: Yes.

9 MEMBER FELDMAN: Thank you. 

10 CHAIRPERSON STONE: Nick? 

11 MEMBER MARAVELL: Kyla, the PCO,

12 Pennsylvania Certified Organic, certifies a

13 lot of operators in Pennsylvania and the

14 surrounding areas. Do you have any

15 information on, roughly, how many apple and

16 pear growers you have? And then my second

17 question is are you aware of what the current

18 status is of research that would be

19 appropriate to your region of the country with

20 regard to control of fire blight in apple and

21 pear production?

22 MS. SMITH: Sure. We certify only
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1 15, so we have a small pony in the race. I

2 don't know how much research has been done. 

3 I think most of it has been done in the West

4 Coast. I do know that one grower that we

5 certify is a research test plot at Penn State,

6 but I'm not familiar with the research that

7 they have, you know, done so far on their test

8 plot. 

9 CHAIRPERSON STONE: Great. Thank

10 you, Kayla. Oh, Joe, thank you. 

11 MEMBER DIXON: Of your 15 apple

12 and pear growers, do you have a sense from

13 that community, if we were to keep the 2014

14 deadline, what would their response be? 

15 MS. SMITH: I'd say a third of

16 them have indicated that they would go out

17 automatically. Most have indicated that it

18 would depend on the year and, if it was a bad

19 year, then they would likely decide to go out

20 of organic production because they would want

21 to save their orchard. I have a quote from

22 one of our growers, when asked if he would
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1 continue with his organic production, and he

2 said, "Yes, but I may eventually go out of

3 business. Since I only plan to grow certified

4 organic, my trees would probably die. When

5 the correct weather conditions occurred during

6 bloom, the disease would build in the orchard

7 until, eventually, all the trees would be

8 dead."

9 CHAIRPERSON STONE: Thank you,

10 Kyla. You'll be here the rest of the week for

11 comment? 

12 MS. SMITH: Yes, sir. 

13 CHAIRPERSON STONE: Thank you very

14 much. Okay. Jake, you're up. And let me run

15 through the list that have not signed in. So,

16 Gwendolyn, you might get your notes ready. Is

17 Ineska Antolos here? Virginia Clinton? These

18 next few people didn't sign in that registered

19 that they were here. Debra Sanders? Brian

20 Baker? Very good, Brian. Nancy Parham? 

21 Okay. So, Brian, you're up and Gwendolyn

22 after that. I mean, Brian, you're on deck and
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1 Gwendolyn after that. Thank you. Jake, thank

2 you. 

3 MR. LEWIN: All right. Thank you. 

4 My name is Jake Lewin. I'm the chief

5 certification officer for CCOF Certification

6 Services. We certify more than 2,500

7 operations to the NOP standards. That's more

8 than any other certifier in the world. We

9 appreciate the efforts and dedication of the

10 NOSB, particularly the CACS and the NOP, to

11 both develop reasonable policies and also

12 address unnecessary barriers to certification

13 and paperwork issues.

14 We strongly encourage the NOSB to

15 support the NOP's Sound and Sensible

16 Initiative and to integrate its principles and

17 approach in your work. Sound and Sensible can

18 and does apply to NOSB recommendations. 

19 Please continually ask yourself if what you're

20 proposing is affordable, accessible, and

21 attainable.

22 Perfect examples of balancing
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1 competing needs are both the CACS items on

2 percentage calculations and other ingredients. 

3 These are great starts towards reasonable

4 standards that protect organic label while not

5 binding ourselves, certifiers and the Program

6 or operations, in unattainable paperwork

7 hurdles. The percentage calculation document

8 is very reasonable. 

9 The most onerous suggestions in

10 the previous other ingredients proposal have

11 been removed. This makes the approach

12 reasonable and achievable at the regulatory

13 practices and certification levels. By

14 comparison, the approach in situation with

15 tetracycline is the opposite. 

16 To be clear, we support the

17 elimination of antibiotics in organic

18 production. We support the majority position

19 to extend the expiration date not because it

20 makes sense but because it's the best bad

21 option. 

22 A more reasonable deadline that
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1 respects the length of time to actually farm

2 apples and develop and register alternatives,

3 particularly in California, is far more

4 appropriate. Specifically, any material, such

5 as Previsto, which achieves EPA registration,

6 will have to go through a long registration

7 process in California. We fear this time line

8 does not support that.

9 At a more fundamental level, we

10 ask the NOSB to respect the sunset process and

11 review materials and appropriate time frames. 

12 Constant and irregular expiration dates are

13 disruptive to us as a community and create

14 ongoing conflict. 

15 Further, artificial deadlines

16 created without regard to the science or

17 agronomic realities is creating mistrust in

18 the community and apathy among the farm

19 community. We need look no further than the

20 eloquent comments submitted by Jim Koan of

21 Almar Orchards. In it, he expresses the

22 frustration with the Board and the process. 
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1 We believe that many, if not most, of our

2 growers feel that the process is a political

3 circus that is ignoring them and, therefore,

4 they're not making their voices heard. That

5 is not a recipe for engagement, much less

6 continued organic certification. 

7 As a certifier, we depend on

8 strong standards, clear rules, and reasonable

9 processes. The current approach is frequently

10 not delivering this. 

11 The NOP's 2013 Certified Entities

12 List just came out and shows that organic

13 operations in the U.S. grew by only about 25

14 operations. The list basically went from

15 17,000 to 17,025. This stagnation is a

16 serious issue and a result we've never seen

17 before. Implementing policies and processes

18 that don't reverse this trend are a real

19 problem, and we would ask you to consider this

20 and to approach these situations in a

21 different manner so that this trend can be

22 reversed. Thank you. 
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1 CHAIRPERSON STONE: Thank you,

2 Jay. Questions? John? 

3 MEMBER FOSTER: So do you feel,

4 back to the sound and sensible thing, do you

5 feel like those kinds of impediments that

6 sound and sensible practices are trying to

7 address, do you feel like that is the main

8 driver of slower numbers, 17,000 to 17,025, or

9 what other factor, what other features are

10 there that are driving that in your

11 certification experience? 

12 MR. LEWIN: In our experience,

13 when economics are easy, many barriers can be

14 overcome fairly easily. When economics are

15 tight, when times are hard, additional

16 barriers, additional barriers around cost,

17 around paperwork, around process, around

18 regulatory process become insurmountable far

19 more easily. And from my perspective, a lot

20 of the barriers that were tolerated before

21 become intolerable as the economic situation

22 becomes tougher for operations. Essentially,
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1 things we've done in the past don't work as

2 well when things are tighter. 

3 CHAIRPERSON STONE: Nick? 

4 MEMBER MARAVELL: Yes, Jake. I'm

5 going to pose, essentially, the same question

6 to you that I did to Kayla. What are,

7 roughly, the numbers of apple and pear growers

8 you have in your universe, which is an

9 extensive universe? And if you could comment

10 on where you see the status and the level of

11 research support to provide alternative

12 methods and materials to control fire flight.

13 MR. LEWIN: Well, with regard to

14 the numbers, we certify 142 apple growers, 69

15 pear growers, 25 Asian pear growers,

16 representing about 2,280 acres of pome fruit. 

17 So significant number of operations, primarily

18 in western states.

19 With regards to the research, the

20 victory here is that everybody, the community,

21 there's some consensus about removal of these

22 materials and, finally, the research is being
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1 done. A tremendous amount of excellent

2 research is being done and research dollars

3 have finally come in. Unfortunately, the time

4 lines for research and commercialization of

5 viable alternatives which may even benefit

6 conventional production simply don't operate

7 on the time lines being proposed by this

8 board. 

9 MEMBER MARAVELL: And so what is

10 your suggestion as an appropriate time line,

11 if you can make such a suggestion? 

12 MR. LEWIN: At least respect the

13 normal sunset, normal sunset time lines. What

14 I would rather occur is to look at the results

15 of the research and the time lines for

16 commercialization and the Board to make that

17 decision. 

18 CHAIRPERSON STONE: Calvin? 

19 MEMBER WALKER: Jake, I believe

20 you probably have already answered it, but you

21 mentioned the best of a bad option. And my

22 question was what would you consider a best of
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1 a good option, but I think you probably just

2 answered it with Nick. 

3 MR. LEWIN: I would rather see a

4 date that you, as a board, can defend based on

5 the evidence, as opposed to a date that's

6 based on some kind of compromise. 

7 CHAIRPERSON STONE: Jean? 

8 MEMBER RICHARDSON: Jake, as one

9 of the consumer reps, I obviously have an

10 enormous concern that, by allowing the

11 tetracycline or antibiotic applications to go

12 forward, that there will be residues of

13 tetracycline in harvested fruit. So looking

14 at the risks and the benefits of continuing

15 the tetracycline, as opposed to eliminating it

16 right away, based on your work with CCOF, help

17 me to understand the risks and benefits of

18 following the recommendation the way the

19 majority is proposing it. 

20 MR. LEWIN: I am not intimately

21 familiar with the data on residues. It's my

22 understanding that these materials are
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1 generally applied during bloom, which, from my

2 way of thinking, would not lead to residues

3 typically. Similarly, certifiers have

4 tremendous latitude to do testing and could do

5 such testing if that was a concern. My

6 concern, actually, would be more around the

7 increased use of other materials and residues

8 from other materials on apples as a result of

9 these 2,200 acres going to conventional

10 production. 

11 MEMBER RICHARDSON: So let's just

12 assume, if I may, Mr. Chair, so let's assume

13 I'm going to choose between conventional

14 production with all the inputs that go in

15 there and the organic production which

16 includes the antibiotic. Do you have sort of

17 a sense of the risks and benefits to the

18 consumer consuming the inputs from the

19 conventional apples, as opposed to the limited

20 inputs, including tetracycline, to the --

21 MR. LEWIN: As a consumer myself,

22 I would rather purchase the organic apple and
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1 I would rather live next door to the organic

2 apple orchard, particularly considering that

3 antibiotics are used in conventional control

4 of fire blight. We're the ones that are going

5 to solve this over time for the industry as a

6 whole. 

7 CHAIRPERSON STONE: And Harold to

8 finish this out. 

9 MEMBER AUSTIN: Jake, thanks. 

10 With the grower base that you guys work with

11 and certify, the antibiotics that are used,

12 the tetracycline specifically, for fire blight

13 control, is this a prophylactic approach in

14 use of application that they're just, carte

15 blanche, using the material or what's the

16 basis that the applications are being used on? 

17 I mean, is every acre getting it, or is this

18 based off of the need and conditions? 

19 MR. LEWIN: Well, firstly, I've

20 been on very, very few operations that use

21 materials willy nilly. Materials are always

22 costly. They're always the last resort. No,
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1 certain commodities are more susceptible. 

2 Certain areas are slightly more susceptible. 

3 Certain weather patterns create -- to say that

4 we certify 2,200 acres of pome fruit is not to

5 say that 2,200 acres will receive tetracycline

6 applications. Some will during certain

7 conditions at certain times. It's simply not

8 a standard application measure. 

9 CHAIRPERSON STONE: Okay. Thanks,

10 Harold. Jake, thank you very much. 

11 MR. LEWIN: All right. Thank you

12 very much.

13 CHAIRPERSON STONE: And you'll be

14 here a few days, I'm sure. Brian Baker is up,

15 Gwendolyn on deck, and then Trudy Bialic after

16 Gwendolyn.

17 MR. BAKER: All right. Thank you. 

18 I'd like to comment on three areas, wearing

19 maybe three or four different hats. First, I

20 would like to speak on behalf of the

21 International Federation of Organic

22 Agriculture Movements regarding the use of
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1 excluded methods and seed purity. Second, I

2 would like to discuss the use of antibiotics

3 in organic production. And, third, I'd like

4 to make a general comment on the materials

5 review process.

6 IFOAM's mission is to lead and

7 unit the organic world. I'm speaking as a

8 standards committee member of IFOAM. IFOAM

9 views genetic engineering and the related

10 technologies as entirely incompatible with

11 organic principles. In response to the

12 February 6th discussion paper, we acknowledged

13 some gray areas, but there is a global

14 consensus emerging on these issues. And the

15 organic community feels there's no place for 

16 genetic engineering in organic production and

17 handling.

18 IFOAM proposes that the NOSB and

19 NOP define genetic engineering in a way that's

20 consistent with IFOAM, Codex Alimentarius, the

21 European Union, other recognized international

22 standards. So as we move forward, the USDA
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1 organic means the same thing. We're all on

2 the same page around the world.

3 The term "excluded methods" is

4 considered confusing jargon outside of the

5 United States. IFOAM respectfully requests

6 the NOSB recommend that the USDA adopt the

7 plain English term "generic engineering" to

8 describe the technologies make it clear what

9 is prohibited and that that definition should

10 be consistent with Codex, IFOAM, and the EU.

11 What is decided in the U.S. has

12 consequences throughout the world. Consistent

13 with the principle of care, IFOAM has taken a

14 precautionary approach as to the adoption of

15 novel biotechnologies. IFOAM asks the NOSB

16 and USDA do the same. To do otherwise risks

17 the credibility of the USDA organic label,

18 both domestically and in the global market. 

19 This holds true for the seed purity issue

20 where sourcing uncontaminated seed in certain

21 crops, particularly cotton, is a global issue.

22 On the tetracycline, this is
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1 speaking as an individual really, I was the

2 certifier representative when the petition was

3 submitted back in 1995 and have a long history

4 of this debate. Organic farmers throughout

5 the world, including in the Pacific Northwest

6 and British Columbia in the Northeast and

7 Ontario and Quebec are producing apples and

8 pears without the use of antibiotics in

9 similar climates under similar conditions. 

10 The alternatives exist and are being used

11 successfully outside the United States, so as

12 long as the antibiotics are allowed

13 manufacturers of alternatives are in a catch14 22. They're not going to ramp up production

15 and capacity to meet the market need unless

16 they're sure the market is there.

17 So when I was on the NOSB an doing

18 technical reviews in the 90s, the assumption

19 was that the sunset process would be more

20 robust and that, as organic continuously

21 improved, substances would come off as easily

22 as they went on. That's not proven to be the
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1 case. So as the NOSB should be aware, once

2 you put something on, it's real hard to get it

3 off.

4 Accelerated sunsets have a dubious

5 history, at best. You look at DL-Methionine. 

6 That has -- okay. 

7 CHAIRPERSON STONE: Good. Thank

8 you, Brian. Questions? Harold? 

9 MEMBER AUSTIN: Brian, thanks. 

10 You mentioned that, outside of the U.S.,

11 there's other products that are currently

12 being used and registered for use for fire

13 blight control. Could you name what those

14 are? 

15 MR. BAKER: Well, there's one,

16 Blossom Protect. It's aureobasidium

17 pullulans. That's being used in Austria and

18 Germany, other parts of the European Union,

19 and showing results comparable to what's being

20 achieved with antibiotics. That's one

21 example, but it's really an integrated

22 approach. There's no one silver bullet. It's
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1 sanitation. It's selection of resistant

2 varieties. It's long-term strategy. It's

3 relying on a number of different techniques

4 and not just relying on a single input. 

5 CHAIRPERSON STONE: Nick? 

6 MEMBER MARAVELL: Yes, Brian. I

7 appreciate your comments. You said that there

8 were apple and pear producers, East Coast,

9 Canada, West Coast, Midwest, that were able to

10 produce organic tree fruit without the use of

11 antibiotics. And then you also have admitted

12 that there are other producers who are,

13 indeed, using the antibiotics in organic

14 production. I'm just wondering if you have

15 enough knowledge or, you know, personal

16 observation to give us what you feel might be

17 some of the characteristics of the farms, or

18 the orchards, rather, that are not using the

19 antibiotic. Do they have a different

20 characteristic than the operations that are

21 using the antibiotic? 

22 MR. BAKER: Well, I mean, that's a
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1 good question. And the ones that are not

2 using antibiotics more often are outside of

3 the U.S., so they've never had that option to

4 rely upon. A lot of producers don't use

5 antibiotics as a general rule. They could be

6 -- I think it's somewhat scale dependent and

7 that there appears to be more with larger8 scale operations, less likely with small-scale

9 operations, less likely with operations where

10 apples and pears are not the main cash crop

11 but it's part of a system where they're

12 marketing more than tree fruit. Just casual

13 observations. I don't have hard statistics to

14 back that up. 

15 CHAIRPERSON STONE: John? 

16 MEMBER FOSTER: How are those

17 other materials reviewed in the EU, and what's

18 the relationship between the primary reviewer

19 and certifiers who approve them as part of

20 what's analogous, I assume, to an OSP?

21 MR. BAKER: Well, these are

22 considered microorganisms or biological
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1 controls. And on the European Union annex has

2 microbiological products similar to, for

3 example, bacillus thuringiensis or Beauveria

4 bassiana. So they fall into that same

5 category.

6 The certification agents and the

7 competent authorities, you know, evaluate

8 against the annex. Of course, the European

9 Union does not follow the same standard for

10 inert ingredients or formulated products that

11 is followed by the USDA organic program. So

12 there's -- yes, those generic products are

13 permitted. The formulated products follow.

14 CHAIRPERSON STONE: Jay? 

15 MEMBER FELDMAN: Brian, you talked

16 about incentivizing transition by sort of

17 suggesting that the Board sometimes has to

18 make difficult decisions that seem onerous or

19 potentially adversely affecting economic

20 position of a particular grower group. Are

21 there historical examples that might be

22 similar to this one in which the Board,
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1 because of public health reasons or because of

2 consumer concern reasons, sort of gets out in

3 front of where the industry would prefer to

4 go, given its reliance on a particular

5 material or process or practice?

6 MR. BAKER: Well, I mean, that's a

7 good one. As I said before, once substances

8 go on the National List, it's really difficult

9 to take them off. And the precedents, more

10 often, are the case where the NOSB has acted

11 with caution and has not put things on the

12 National List, forcing the producers to

13 develop alternatives. And I think that's been

14 true for, you know, you can go back and comb

15 through, for example, with treated seed and

16 the petitions to allow EBDC fungicides was

17 rejected: thyram, ziram. Organic farmers came

18 up with alternative treatments. The seed

19 industry came up with alternative treatments. 

20 There were, of course, seed companies and

21 certain commodities where seed was just

22 difficult to find untreated and it was an
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1 extra burden on those farmers. But,

2 eventually, the untreated seed and seed

3 treated with materials permitted by the USDA

4 organic program came to the market.

5 CHAIRPERSON STONE: Nick, if

6 you'll wrap this up.

7 MEMBER MARAVELL: Brian, I don't

8 know if you'll be able to address this, but,

9 in looking at the use of tetracycline, I'm

10 just wondering, in other countries, are there

11 back-up or emergency situations where an

12 organic producer would be permitted to use an

13 antibiotic, perhaps not being able to market

14 the resulting fruit as organic but being able

15 to maintain certification going forward into

16 a future year? Is there any, have you seen

17 any evidence of that type of provision in

18 other countries? 

19 MR. BAKER: Not really. I mean,

20 the countries where the fire blight pressure

21 is the heaviest, there really has not been

22 that turning to antibiotics. When there is a
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1 bad outbreak, it's more often they'll resort

2 to other bactericides, other fungicides. And,

3 again, the withdrawal from the market is

4 always an option. It's used much less as an

5 option. I think in Europe people tend to stay

6 in the organic certification longer because

7 it's much harder to move land in and out of

8 organic production under European Union

9 regulations, so they take a hit for a bad year

10 and then they come back the next after pruning

11 heavily and trying to get as much of the

12 infection out as possible. 

13 CHAIRPERSON STONE: Thank you very

14 much. Gwendolyn, we're going to take a break

15 after Gwendolyn. I wouldn't dare -- she's

16 been pacing back there. I wouldn't take the

17 break now. She's ready to go. So, Board

18 members, we don't want to get spoiled here. 

19 We found a little time and, obviously, I want

20 to run with the expertise at the podium. 

21 Gwendolyn? 

22 MS. WYARD: Great. Hello. My
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1 name is Gwendolyn Wyard, and I'm the

2 regulatory director of organic standards and

3 food safety for the Organic Trade Association,

4 representing over 6,000 members across 48

5 states. My comments today will address

6 oxytetracycline and other ingredients. You

7 have our written comments on six other topics,

8 as well as our two-page summary.

9 OTA agrees that antibiotics should

10 be completely phased out of organic

11 production, and we support all efforts to

12 develop effective alternatives. There are two

13 take-home messages we hope were effectively

14 delivered in our written comments. The first

15 is that the organic industry is acutely aware

16 of the concerns surrounding the use of

17 antibiotics, and I think we all agree for the

18 need for an alternative.

19 The crux of the issue is to get

20 from point A, which is now validated field

21 results of new alternative materials, to point

22 B, which is widespread availability and
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1 adoption by organic growers. There's too much

2 to lose if we can't adopt alternative

3 practices while retaining organic acreage.

4 Researchers and orchardists have

5 committed years of research into developing

6 alternatives, and efforts have recently

7 accelerated due to significant USDA funding. 

8 Excellent progress is being made, and the

9 prospect that we're actually within a three10 to five-year time frame of securing a non11 antibiotic program is monumental.

12 This brings me to my second take13 home message. The 2014 deadline falls short

14 of critical research that will validate newly

15 developed materials. And 2016 will likely cut

16 short the time needed for grower education and

17 experience. Many growers have not tried the

18 new and emerging alternatives and are

19 concerned about the risk of catastrophic

20 disease in the absence of proven alternatives. 

21 When faced with a high-risk fire blight

22 situation, growers will be forced to exit
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1 organic production. If we truly want to end

2 the use of antibiotics and retain organic

3 acreage, growers must have alternatives and

4 they must be confident that they will work. 

5 Otherwise, we'll effectively increase the use

6 of antibiotics, along with the use of other

7 pesticides, because of the loss of organic

8 acreage.

9 OTA supports a hard deadline of

10 2017 because, unlike 2016, it's tied to a

11 fact-based research-supported time frame. Of

12 course, we'll support a 2016 deadline over a

13 2014 deadline. But as a matter of principle,

14 we need to stop creating deadlines as a course

15 of political compromise. They do nothing but

16 set us up to fail.

17 The 2014 extension and now the

18 petition for another extension are not the

19 result of complacency. We were slow to start,

20 but researchers are now working as fast as

21 they can and they're turning out successful

22 results. It would be a travesty to
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1 prematurely pull the plug and set back such

2 great progress.

3 I'll conclude by saying that we

4 urge NOSB to give organic apple and pear

5 growers the time needed to trial and to

6 implement the new and emerging materials into

7 their existing preventative control systems. 

8 We have to look closely at the implications

9 and understand that we have an incredible

10 opportunity. If we can succeed with the

11 large-scale adoption of a non-antibiotic

12 program in organic orchards, conventional

13 orchards will also adopt these alternative

14 techniques. We're seeing it happen already. 

15 From our viewpoint, this is the road to truly

16 ending the use of antibiotics in all of

17 agriculture.

18 A few take-home messages from our

19 written comments on other ingredients. 

20 Historically, NOSB has reviewed other

21 ingredients contained within a substance and

22 they have addressed them through the use of
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1 annotations. We have not, however, had a

2 clear written policy or documented procedure,

3 and that has led to inconsistency at the NOSB

4 level and perhaps even more so at the ACA and

5 MRO level. Improvements are needed. 

6 Therefore, we generally support the Handling

7 Committee's proposal with a few minor

8 revisions, as suggested in our written

9 comments. 

10 And, finally, as stated in the

11 proposal, there are about 13 substances on 605

12 and 606 that require the use of other

13 ingredients. We have a great deal to learn,

14 and the review ahead of us will be challenging

15 and complex. But we believe it's manageable;

16 and with this policy and procedure in place,

17 we will take what is already the most rigorous

18 material review program in the world and make

19 it that much better. Thank you. 

20 CHAIRPERSON STONE: Thank you,

21 Gwendolyn. You're close, but Steve still has

22 you on the timing of the button there. So
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1 we're thinking of a prize for who gets it the

2 closest. You're second right now. 

3 MS. WYARD: Can I try again? 

4 CHAIRPERSON STONE: Questions for

5 Gwendolyn? John? 

6 MEMBER FOSTER: Could you kind of

7 capture quickly what differences you see now

8 versus when the original 2014 deadline was

9 set? 

10 MS. WYARD: Sure, yes. I think

11 the big difference between now and 2014 is the

12 progress in the development of alternative

13 materials. If growers have alternative

14 materials, then they will, in fact, use those

15 materials, but we've got to get -- 2014 was

16 not based on the availability of materials. 

17 As soon as that 2014 deadline was set, that

18 petition was in, we knew at the time we

19 couldn't meet that deadline because the

20 alternatives were not there. So that did, in

21 fact, you know, it lit a fire, and we've made

22 incredible progress and it's exciting to see
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1 what's out there. 

2 So I think the big difference is

3 that we really have these tools. They're new. 

4 There's one very critical one that hasn't been

5 registered yet. Hopefully, it will be

6 registered this year. But Blossom Protect was

7 just registered by EPA in 2012, so there's a

8 lot of growers out there that I think would be

9 absolutely willing to use these other

10 materials but they need to learn how to use

11 them. They need to be confident that they're

12 going to work. The risk is too great. It's

13 not, they're not going to decide to just risk

14 their orchards without knowing and being

15 confident that these materials work. 

16 MEMBER FOSTER: Okay. Thanks. 

17 And nice use of lit a fire. That's really

18 good. It's clever.

19 MS. WYARD: Thank you. It was for

20 you, John. 

21 CHAIRPERSON STONE: Nick? 

22 Gwendolyn, you're still up. Thanks. We've
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1 got a couple of questions yet. 

2 MEMBER MARAVELL: Gee, Gwen. I'd

3 like to ask two questions. One is you made

4 the statement that effective use of non5 antibiotic control of fire blight could spur

6 that practice in the conventional market. And

7 I was just wondering if that's based on

8 something solid? My impression, and I'll just

9 give you my impression, is that things like

10 alternative practices, non-antibiotic

11 practices, may, indeed, end up being more

12 expensive than antibiotic use. So I didn't

13 know if you had any information on that, and

14 then I'll ask my second question. 

15 MS. WYARD: I had the opportunity

16 to visit the trial orchards in Corvallis since

17 that's where I'm from. I visited with Ken

18 Johnson and walked the orchards, and he did

19 say that, you know, we're already seeing

20 conventional growers adopting the use of

21 Blossom Protect because antibiotics, that's

22 running them, that's their highest bill right
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1 now. And so they're looking for other

2 materials to supplement the use of the

3 antibiotics to get that cost down.

4 You know, when I started looking

5 into this about six months ago, you know,

6 there was no way that OTA would come up to a

7 podium and promote, request an extension for

8 antibiotics unless we were absolutely

9 confident that there was real progress being

10 made. So the experience that I went through

11 in working with Ken Johnson and discussing

12 this with David Granatstein was a really

13 amazing process, and one thing that I went

14 through, and you'll see, I handed around the

15 organic report, it ended up resulting, it

16 inspired a thematic publication that we put

17 together, the cover story being "Organic Tree

18 Fruit: A Success Story," because David told me

19 a couple of stories and, hopefully, David will

20 talk more about this tomorrow, but a couple of

21 specific stories where the adoption of

22 biological controls were adopted by the
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1 conventional where we did, in fact, see this

2 progression happen from adoption at the

3 organic front and adoption from the

4 conventional. 

5 So we're already seeing it happen

6 with Blossom Protect, I think Provista. 

7 You'll hear more about that product tomorrow. 

8 The combination of those two together, in

9 addition, of course, to all the other

10 cultural, biological, mechanical practices,

11 you know, I think it's a win/win situation. 

12 The costs, I think the costs and,

13 again, the panel, I appreciate that question

14 being asked to them as far as what the direct

15 cost is, but my understanding is that it can

16 be comparable or less, so it would be a no17 brainer because of the need, the desire. 

18 Change happens at the marketplace. Nobody

19 loves antibiotics. This request that we're

20 seeing here is going to happen across

21 conventional agriculture if we have those

22 materials available. I think that's the key.
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1 MEMBER MARAVELL: My second

2 question was you're advocating an extension

3 through 2017. That would be one year beyond

4 the current Committee recommendation. What

5 specifically would you see happening, in your

6 mind, during that additional year? 

7 MS. WYARD: Yes, I think that is

8 the critical year for grower outreach. The

9 OREI project will conclude in 2015. Compiling

10 the results of that project, looking at the

11 new materials, using the new model, putting

12 together, basically, a publication with those

13 results, and then also we're looking at

14 funding a grower publication extension

15 document that would go out to all the growers

16 showing them the results of the OREI project,

17 giving them the time to trial and implement

18 these new materials.

19 So I'd be the first to say that it

20 may take longer. We don't feel like there's

21 room for another extension because we have had

22 an extension and then another extension. I
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1 think it's unfortunate how that happened. I

2 think we do feel like there needs to be a hard

3 date to respond to consumers, but I think that

4 it's going to be doable for many. There will

5 be risks. Again, it's not a question of if,

6 it's when. 

7 There will be risks, there will be

8 loss. But I think that, in terms of the bell

9 curve and being able to shift as many

10 certified operators over as possible, I think

11 we can capture the most with a 2017 deadline. 

12 But the key with that one year, it doesn't

13 sound like much but I think it's a critical

14 year of grower outreach and education. 

15 CHAIRPERSON STONE: Jean? 

16 MEMBER RICHARDSON: Gwendolyn, I

17 think, I believe that it was about 1957 that

18 fire blight arrived in Europe and the

19 Europeans have a zero tolerance towards

20 antibiotics for controlling it. If they've

21 managed to control it for this length of time,

22 why can't we do without it in the Northwest? 
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1 MS. WYARD: Right. I hope you ask

2 that question to experts tomorrow, as well,

3 that can talk more about the differences, the

4 climate differences between Europe and the

5 United States because I don't have all that

6 background information. But, you know, we

7 have grown up with the use of tetracycline and

8 streptomycin. That's a key part of what's

9 going on. It's been allowed since the

10 implementation of 2002. It was allowed in the

11 private standards. So that's been a tool in

12 the toolbox, so we haven't learned to do it

13 otherwise. Now is our opportunity to learn to

14 do it in a different manner. We've always had

15 that material.

16 CHAIRPERSON STONE: Harold? 

17 MEMBER AUSTIN: Gwen, your bell

18 curve comment that you made just a moment ago

19 talking about the impact that the extension

20 would have going back out to 2017, what do you

21 feel with the various stakeholder groups that

22 you work with that are a part of OTA and that
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1 you come in contact with, what would the

2 impact be if we were to allow the existing

3 expiration date of 2014 stay in place, rather

4 than the proposal that we have, not going out

5 to `17 but the proposal we have at `16? What

6 would you see that variation or that impact

7 be, the difference between that, to the

8 organic stakeholders as a whole? 

9 MS. WYARD: Okay. I want to make

10 sure I understand this correctly. The

11 difference between a 2016 and a 2017 or the

12 2014? 

13 MEMBER AUSTIN: The `14. If we

14 were to allow the expiration date to take

15 place as it's on the books right now of

16 October 21st, 2014, rather than going to

17 either -- right now, I'm just looking at the

18 proposal, 2016.

19 MS. WYARD: So I'm not exactly

20 prepared with numbers, in terms of number of

21 acres and dollar costs, but I know that will

22 be presented. I think the difference, if 2014
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1 is the deadline, growers will not have

2 confidence in the use of the alternative

3 material. So going back to, you know, at

4 least speaking in the Northwest and

5 Washington, the survey that was conducted, 93

6 percent of those growers said that they would

7 exit organic production. So you can take 93

8 percent of growers, and then you can

9 extrapolate and figure out, you know, what the

10 market stats are for the amount of organic

11 produce or apples and pears that are coming

12 out of Washington. 

13 Ninety-three percent is huge. 

14 Ninety-three percent of the growers were to

15 exit organic certification, it speaks for

16 itself. 

17 MEMBER AUSTIN: A follow-up on

18 that. Would there be a disparency between the

19 commodities, between apples and pears? 

20 Because we have heard some indications that

21 the research has lagged a little bit on pear

22 production for the research for fire blight
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1 control versus what the inputs being put into

2 the apple. So would you see a difference in

3 the amount of acreage taken out or a

4 percentage of acreage taken out of pears

5 versus apples? 

6 MS. WYARD: I think so. I think

7 there's a real concern, and I appreciate you

8 bringing that up. I think we are

9 particularly, we talk a lot about the

10 Northwest because that's a lot of where the

11 research is being conducted, that's a lot of

12 where the information is coming out of. And

13 we talk a lot about apples and maybe not as

14 much about pears, at least in the discussions

15 that I've been hearing about. I don't think

16 that the pear growers, particularly pear

17 growers down in California, they are not as

18 aware of the new and emerging materials and

19 they are not going to have, necessarily, the

20 exposure in the timely fashion that we are in

21 the Northwest simply because of the outreach

22 that's already happening. I mean, I know that
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1 Ken Johnson and other researchers, they're

2 already out in the field, going out to all the

3 conferences. People are aware that these

4 materials are out there. They know this issue

5 is happening, but I don't think we can say the

6 same around the country. And I think that

7 there are conditions, particularly in

8 California for pears, where the materials that

9 we have available may not work as well for

10 pears as they do for apples.

11 CHAIRPERSON STONE: Jay, if you'd

12 wrap this up for us. 

13 MEMBER FELDMAN: I'll try. 

14 Thanks, Gwendolyn. As you know, the Board,

15 the NOSB has responsibility to balance not

16 only need, to address not only need but also

17 hazard and consumer expectations. In the

18 context of this decision-making, we're hearing

19 a lot of comments like yours that there is a

20 tremendous need out there, and I suspect

21 throughout the rest of this meeting we'll hear

22 that multiple, multiple times.
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1 I'm wondering, as a trade

2 association and given the interface that you

3 have with the consuming population, in light

4 of your mission to represent the growers and

5 the community producers, have you looked and

6 what have you concluded? Have you looked at

7 the literature on the urgency associated with

8 the bacterial resistance, and have you

9 considered the impact associated with consumer

10 expectation and impacts on long-term integrity

11 or perception of integrity on behalf of the

12 consumer population? And how have you

13 factored that into your positions, given that

14 your oral statements didn't address these two

15 issues, as far as I heard. I might have

16 missed it, but these two issues at all and I

17 didn't see it either in your public comments,

18 written comments, as well. So I appreciate

19 you addressing that. 

20 MS. WYARD: Thank you, Jay. Yes,

21 we absolutely share the concerns. We didn't

22 put anything in our comments because we really
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1 didn't want to spend any of our breath

2 defending or saying anything good about

3 antibiotics. We want to see their use end. 

4 And we believe that if we give the time

5 needed, which is not very much time, we will,

6 in fact, decrease the use of antibiotics,

7 where if we pull the plug too soon we will

8 increase the use of antibiotics because of the

9 number of growers that will exit organic

10 production and not only increase the use of

11 antibiotics but also pesticides. To say that

12 they can no longer be allowed in 2014 in

13 organic production is no guarantee that it's

14 going to decrease or end the use of

15 antibiotics because those growers may very

16 well, based on the data that we see, go to

17 conventional production.

18 So for, you know, to consider

19 where we're at right now, with such success on

20 the horizon, we hear, based on everything that

21 we're looking at, that this, that you have to

22 look at what you lose and what you gain. And
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1 we very well could increase the use of

2 antibiotics by putting a deadline at 2014. 

3 MEMBER FELDMAN: I appreciate that

4 perspective. I guess my concern, and this

5 goes to the other part of my question, the

6 consumer issue, is how do you measure, as a

7 trade association, the impact on overall

8 public perception of the integrity of organic

9 and what it stands for and what the label

10 means and future growth of the market, given

11 public perception of our resistance perhaps or

12 perceived resistance to seriously address the

13 urgency of the public health issue that we're

14 facing now, not next year, not two years,

15 three years, or four years but right now? 

16 MS. WYARD: Yes, yes, that is a

17 tough situation, and it's unfortunate that we

18 are where we're at, that there has been so

19 much public media about these extensions

20 because there's misinformation about why these

21 extensions have occurred. I think that's why

22 we -- I can see where keeping it in the sunset
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1 cycle would be preferred, but we also see the

2 concerns in how that hasn't necessarily

3 happened. The reason we are committed to 2016

4 - 2017 as a deadline because we absolutely

5 hear and see the concern from the consumers

6 and we have to commit to that deadline. 

7 MEMBER FELDMAN: Thank you. 

8 CHAIRPERSON STONE: Thanks,

9 Gwendolyn. 

10 MS. WYARD: Yes, thank you very

11 much. 

12 CHAIRPERSON STONE: So, Board

13 members, the gavel will fall at 10:30 to

14 restart this session. And, Trudy Bialic, if

15 you will also be ready at 10:30. Thank you. 

16 (Whereupon, the above-entitled

17 matter went off the record at 10:18 a.m. and

18 resumed at 10:30 a.m.)

19 CHAIRPERSON STONE: Can the Board

20 members take their seats? We gained a little

21 time in the schedule, but we want to use the

22 extra time. I know the networking and talking
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1 amongst yourselves is a critical part of this

2 process, but, out of respect, I'd like to get

3 back in session. 

4 So a couple of comments. We're

5 running about 45 minutes ahead, so if you're

6 signed up for public comment you can kind of

7 scootch it up about 45 minutes or so. We may,

8 in fact, if we can maintain that leeway, we

9 may, in fact, adjust the agenda a little bit

10 at this point. I want to ask if two people

11 that are signed up for policy comments

12 tomorrow morning -- excuse me. Let me scroll

13 down here. Is Theo Woods here? Theo. And

14 I'll wait until after lunch and give him time

15 to get in here. 

16 So we're about 45 minutes ahead

17 right now, but we may use that up this

18 afternoon. And if you're speaking, if you're

19 signed up to speak with Michelle, there is a

20 sign-up sheet outside that we can verify that

21 you are, in fact, here, made the trip to be

22 here. That might help us with scheduling. 
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1 And we may, in fact, use 15 minutes of this

2 for an extra 15 minutes for lunch because it

3 is hard for everybody to get out and back and

4 get back in on time.

5 So with that, we're back in

6 session, and we have Trudy with PCC. And let

7 me see who's on deck, Trudy, before you get

8 started. Excuse me. Pat Kane, you're on

9 deck. No, Trudy, you're up. Pat Kane is

10 getting nervous getting ready. And Michelle

11 is not here -- you got it, Lisa? Thank you. 

12 Okay, Trudy. 

13 MS. BIALIC: Ready to go? 

14 CHAIRPERSON STONE: Yes, ma'am.

15 MS. BIALIC: Thank you very much

16 for the opportunity to be here and comment. 

17 My name is Trudy Bialic. I am the director of

18 public affairs for PCC Natural Markets. We're

19 a retailer in Seattle. I'm not going to

20 restate the written comments that we

21 submitted, but I do want to comment in general

22 about concerns over what is perceived or
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1 appears to be a growing allowance for

2 synthetics.

3 On behalf of the 49,000 people who

4 own our stores, we realize that it is very

5 challenging for you to review every material. 

6 But shoppers, especially long-time organic

7 shoppers, are concerned about the synthetics

8 already allowed. Remember back at the point

9 of the Harvey lawsuit in 2005 there were only

10 38, and right now we're at over 200.

11 And many shoppers are just finding

12 out about DHA and carrageenan, and they're

13 puzzled, they're confused, and they want to

14 know how it was that NOSB approved them. 

15 We've had to post signage about DHA, and now

16 our nutrition educators say some shoppers are

17 reporting improvements in their

18 gastrointestinal disorders after they stopped

19 eating foods with carrageenan. It's not

20 proof. It's anecdotal. But after reading the

21 available research, customers and even my

22 bosses at my company are asking how it was
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1 that NOSB approved these.

2 In fact, I believe it was every

3 consumer organization argued against DHA and

4 carrageenan at the time, against the

5 allowances. But NOSB sided with industry, and

6 that's a perception that carried over, I

7 think, from even with the poultry standards on

8 the space allocations.

9 So that brings me to my request by

10 the Handling Committee for comments on other

11 ingredients. We did a survey in 2011, and we

12 resubmitted that to you, where we found that

13 organic shoppers expect all ingredients,

14 including ingredients of ingredients, to be

15 organic or on the National List. And that's

16 why we support option D, no ingredient of any

17 kind should be in organic food unless it is

18 organic or on the National List. Nothing in

19 OFPA distinguishes between ingredients in

20 other ingredients.

21 As far as tetracycline, which I

22 recognize is not a synthetic, but as far as
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1 tetracycline and tree fruit goes, I do want to

2 say that I assumed incorrectly that the

3 consumer empathy for challenges faced by

4 organic farmers would trump concerns about

5 antibiotics, the support for farmers being so

6 high as it is. But I was wrong.

7 I talked with countless shoppers,

8 and all but one of them said antibiotics do

9 not belong in organic food period. Their

10 views did not change when given the arguments

11 for an extension. 

12 After talking with our primary

13 apple and pear growers, we had no choice but

14 to change our company position. So now we

15 oppose any extension for tetracycline. We

16 just have to go where our constituents'

17 interests take us. We have to go where the

18 information takes us. Thank you very much.

19 CHAIRPERSON STONE: Thank you,

20 Trudy. Questions for Trudy? Calvin? 

21 MEMBER WALKER: Could you share

22 with us your survey? Could you share with us
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1 your survey and how it was done and some of

2 the conclusions again? 

3 MS. BIALIC: Well, the methodology

4 is included in the report itself. We surveyed

5 almost 1,500 shoppers. We did it through

6 online and through, as I recall, through

7 print, as well. The results were pretty clear

8 and conclusive. There was just no other way

9 of concluding, but the consumer does not want

10 additives and they don't want synthetic

11 additives of any kind. Basically, they

12 believe that organic foods have inherent

13 healthy values as they are. They don't need

14 anything extra to be healthy. 

15 CHAIRPERSON STONE: And thank you. 

16 They are very detailed in her written comments

17 so appreciate that. We can refer to -- one

18 more. Joe? 

19 MEMBER DIXON: Hi, Trudy. Thank

20 you. So you said you talked a lot recently

21 with consumers about concerns about

22 antibiotics in tree fruit. Can you walk us
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1 through sort of the methodology and the

2 questions you used in those conversations? 

3 MS. BIALIC: Mostly, I would say

4 it was through being in the stores. We were,

5 I was in stores. I took phone calls. I

6 actually did it through outreach, through

7 being at some of the stores, set up tables and

8 just actually greeted people when they were

9 coming in. 

10 It's been over, really over the

11 last couple of months, but it began probably

12 two years ago when I first heard about it. It

13 was on a quiet level. We didn't talk much

14 about it but until the last couple of months. 

15 CHAIRPERSON STONE: Thank you,

16 Trudy. 

17 MS. BIALIC: Thank you. 

18 CHAIRPERSON STONE: Pat Kane is

19 up. Micah Frye is on deck. Is Micah here? 

20 Not seeing Micah, so that puts Amha Belay on

21 deck. 

22 MS. KANE: I would like to thank
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1 the Board for this opportunity to provide

2 these comments. I'm Pat Kane. I'm the

3 coordinator of the Accredited Certifiers

4 Association. We did submit written comments

5 on several proposals, and I'm just going to

6 summarize our comments here but also urge you

7 to review our written comments.

8 Regarding the auxiliary and other

9 ingredients -- dear, where'd it go -- we were

10 supportive of the Subcommittee proposal and

11 request that the Board adopt this proposal. 

12 We do suggest that the NOSB recommend to the

13 National Organic Program that any instruction

14 or final guidance contain a clear definition

15 of other ingredients, as this is not contained

16 in the regulation.

17 The first three paragraphs of the

18 Subcommittee definition should be included in

19 any instruction or final guidance. Sorry. 

20 I'm having trouble here. Oh, dear. 

21 ACA agrees with the concept of

22 transition period for operators to bring their
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1 products into compliance to prevent the

2 destruction of markets. We also believe that

3 moving cleaners, sanitizers, and

4 disinfectants, and other non-food substances,

5 such as the boiler additives, to their own

6 dedicated section of the National List will

7 provide clarity that these materials are not

8 ingredients. So we did provide some wording

9 in our written comments about that.

10 Regarding the tetracycline

11 petition material proposal, we believe the

12 entire organic community is committed to

13 developing and implementing a non-antibiotic

14 approach to controlling fire blight in apple

15 and pear production. ACA supports the

16 Subcommittee's acknowledgment that any

17 expiration date for oxytetracycline must allow

18 time for research on alternatives to draw the

19 conclusions and for those alternatives to go

20 through the process to become commercially

21 available in the marketplace. 

22 We support the new expiration date
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1 of October 21, 2016. If effective control

2 tools are not available and fire blight

3 threatens the viability of an orchard, despite

4 preventative efforts, ACA believes that

5 farmers will prioritize their agricultural

6 livelihood over retaining organic

7 certification and access to the organic

8 market. By allowing this time, the

9 Subcommittee will ensure growers have adequate

10 tools to remain in organic production and

11 provide consumers access to organic products. 

12 We also support the Subcommittee

13 resolution pertaining to the commitment to a

14 phase-out of the material while asking

15 certifiers to include in organic system plans

16 an annual increase in the extent and/or number

17 of alternative practices and materials that

18 are trial for controlling fire blight. As

19 certifiers, we will do our part to move the

20 resolution forward, and throughout the two21 year extension the use of oxytetracycline will

22 continue to be highly regulated. 
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1 We note that producers may only

2 apply synthetic materials when physical,

3 biological, and cultural practices are not

4 effective, provided conditions are documented

5 and approved in the organic system plan. The

6 certification process effectively verifies

7 that growers are following their plan and

8 operating in compliance with organic

9 requirements.

10 Phasing out antibiotics offers the

11 opportunity for the NOSB to engage in lead

12 agricultural experts, growers, and consumers

13 in a public-private effort to cooperatively

14 strengthen the organic label from farm to

15 table. Thank you very much. I apologize for

16 the --

17 CHAIRPERSON STONE: Thank you,

18 Pat. Question, Jay? 

19 MEMBER FELDMAN: Thanks, Pat. I

20 have a question for you. 

21 CHAIRPERSON STONE: Question, Pat.

22 MEMBER FELDMAN: Thanks. You've
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1 mentioned the organic systems plan both in

2 your written and oral comments. I'm curious

3 as to whether, within those plans, there are

4 any model fire blight-resistant strategies

5 that are viewed as programmatic? In other

6 words, programs that the community of

7 certifiers and inspectors believes are

8 preventive in nature, that are specific, and

9 should be incorporated into every organic

10 systems plan where fire blight may be a

11 threat. Is there such a plan or model

12 programmatic language that is incorporated

13 across the board uniformly in all organic

14 systems plans? 

15 MS. KANE: I would doubt that at

16 this point. I would believe that that's

17 something that could be worked on, but it's up

18 to the grower to tell the certifier what the

19 plan is. I mean, you can answer, you can put

20 questions in there, and they can respond to

21 that. 

22 MEMBER FELDMAN: And so, as a
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1 result, we can expect that there's wide

2 variability in the degree to which preventive

3 measures are adopted in various areas, various

4 farms or range of farms?

5 MS. KANE: Currently?

6 MEMBER FELDMAN: Currently.

7 MS. KANE: I would suspect there

8 is, yes. 

9 MEMBER FELDMAN: Okay, thank you. 

10 CHAIRPERSON STONE: Zea? 

11 MEMBER SONNABEND: Thank you, Pat. 

12 Did the ACA talk about how workable they think

13 the other ingredients proposal is in terms of

14 being able to take NOSB deliberations into the

15 field as certifiers?

16 MS. KANE: Yes, we did. It was my

17 glitch that I did not cover that here. We

18 supported the other ingredients

19 recommendation. We thought that the

20 individual other ingredients do not need to be

21 on the National List, but we did want them

22 included on the review checklist so that there
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1 was some means of identifying what had been

2 looked at. So, yes, they thought it was

3 workable. 

4 CHAIRPERSON STONE: Thank you,

5 Pat. Amha Belay is up. Theresa Griffith? Is

6 Theresa here? Is on deck. Amha? 

7 MR. BELAY: Thank you for the

8 opportunity to provide our comment. The

9 comment will be on organic spirulina

10 production. My name is Amha Belay, and I'm

11 senior vice president and chief technology

12 officer of Earthrise Nutritionals, and I'm

13 here representing two companies: Cyanotech

14 Corporation based in Hawaii and Earthrise

15 Nutritionals based in California, the only two

16 past and present producers of spirulina.

17 It will be remembered that

18 Cyanotech Corporation and Earthrise

19 Nutritionals produce organic spirulina until

20 2005, following the regulations of the land21 based crop production. The two companies

22 stopped production due to the limitation of
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1 the use of Chilean nitrate to only 20 percent

2 of total input.

3 The two companies have now

4 researched and considered the use of

5 alternative organic nutrients and may wish to

6 resume organic production. However, the

7 status of organic spirulina production and

8 certification and the current regulations for

9 crop production has been put into question by

10 NOSB to the extent that separate regulations

11 and aquaculture regulation and/or soilless

12 crop production regulations have been

13 considered and are against being considered. 

14 A 2008 document by the NOSB

15 describes that, "The Crops Committee of the

16 NOSB is gathering information and discussing

17 the formation of a recommendation to the NOP

18 for rulemaking on the subject of soilless

19 growing systems in organic production." 

20 Spirulina is among three categories of

21 production considered under a soilless organic

22 production. However, the document has raised
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1 several questions, as described in the full

2 2008 report. It is also noted that the NOSB

3 was asking opinions of certifiers about this

4 issue for possible rulemaking. 

5 It, therefore, appears that there

6 is no regulation regarding organic spirulina

7 production at the moment. Since there is

8 organic spirulina imported into the United

9 States and sold as USDA organic and with USDA

10 logo, the question arises as to what

11 regulation is applied to organic spirulina

12 certification of imported products currently

13 and for those who may wish to produce organic

14 spirulina in the USA, such as Cyanotech

15 Corporation and Earthrise Nutritionals. 

16 The answers to these questions by

17 the NOP are pertinent to our future growth and

18 development as spirulina companies in the USA. 

19 We would like to have a clear guideline on

20 this matter in order to plan our business

21 strategy on solid grounds with respect and

22 respecting, following the appropriate
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1 regulations. 

2 We eagerly await for a response. 

3 Thank you very much. 

4 CHAIRPERSON STONE: Thank you,

5 sir. Are there any questions? All right. 

6 Thank you very much. 

7 MR. BELAY: Thank you. 

8 CHAIRPERSON STONE: While Theresa

9 is getting ready, Bob Durst, you're on deck. 

10 And just so you'll know, Michelle is out

11 trying to pick the lock on the cover over the

12 thermostat so she can warm it up in here. 

13 Okay. Thank you. 

14 MS. GRIFFITH: Okay. My name is

15 Theresa Griffith. I am the president of

16 Somebody Cares, an international relief

17 organization which assists people with chronic

18 illness, autism, and ADHD. This song

19 represents what we have seen and known to be

20 true.

21 (Whereupon, a song was performed

22 by the commenter.)
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1 CHAIRPERSON STONE: Thank you very

2 much. Very good. Bob, you going to top that

3 one, buddy? And Natasha Gallegos is up next.

4 MR. DURST: I just wanted to make

5 a couple of comments based on the antibiotic

6 scenario that's going down here. As a

7 consumer, what I see as a real concern on

8 their part is the use of antibiotics primarily

9 in the livestock industry where there's a lot

10 of carryover and a possible health risk of

11 antibiotic resistance showing up in food, the

12 food supply, etcetera, that leads to human

13 health risk. I don't see that same risk

14 showing up at all in the use of tetracycline

15 in an orchard situation. 

16 So the loss that's been mentioned

17 of organic orchards and production of organic

18 apples and pears, et cetera, which would be at

19 risk by restricting something used for fire

20 blight control is a real concern to me,

21 whereas I think the consumer perception of

22 antibiotic use just doesn't relate and
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1 translate into its use in an orchard where it

2 does in the livestock production. So I'd like

3 to see it extended and see that consumers can

4 still get organic apples and pears without

5 having orchards taken out because of fire

6 blight. Thanks. 

7 CHAIRPERSON STONE: Thanks, Bob. 

8 Question? Jean? 

9 MEMBER RICHARDSON: So, obviously,

10 I'm concerned about residues of antibiotics

11 possibly in harvested fruit, and you said you

12 just don't see that as a problem. Do you have

13 any scientific data to support your statement?

14 MR. DURST: No, I certainly don't

15 have any data along those lines, and I'm not

16 sure that anybody does. But being a food

17 scientist and having a lot of knowledge of

18 this sort of thing in general, the timing

19 between when antibiotics or tetracycline is

20 used for fire blight control in the harvesting

21 of apples is such a long time difference that

22 I can't imagine that there's residue concerns
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1 that would lead to health concerns of any

2 kind. 

3 CHAIRPERSON STONE: Okay. Jay? 

4 MEMBER FELDMAN: Thanks, Bob. I

5 want to follow-up on Jean's comment because

6 we're hoping to have a scientific discussion

7 here. As you know, we're informed, as a

8 board, by technical review documents that are

9 supplied to the Board in its deliberations. 

10 Have you had a chance to review the technical

11 review document for tetracycline? 

12 MR. DURST: I have not. I'm

13 sorry. 

14 MEMBER FELDMAN: Okay. If you do,

15 you have a couple of days, it would be helpful

16 for you to review the documents on the AMS NOP

17 website because there is, there are studies in

18 there that show resistant bacteria. Whether

19 it's commensal bacteria or human pathogen

20 doesn't matter. It's the question of lateral

21 gene transfer that eventually makes its way as

22 resistant genes into human pathogens, which is
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1 what the Infectious Disease Society of America

2 is concerned about as a public health crisis,

3 as an extreme public health crisis. 

4 So you, as a scientist, it would

5 be helpful if you were to look at that

6 documentation, as well as the Schnabel and

7 Jones citation that's in the TR that shows

8 resistant bacteria in the fields where these

9 materials are used. In addition to that, of

10 course, the American Academy of Microbiology

11 is extremely concerned, as a professional

12 society, about the use of antibiotics in

13 crops, as well as in animal production. If

14 you talk to infectious disease docs, they say

15 by the time you see the problem it's too late.

16 So I guess knowing what you know

17 as a scientist, it would be helpful to get

18 your assessment based on reading the

19 scientific literature. But, also, I'm

20 interested in whether you view the organic

21 statute, given the science, what is known,

22 what is uncertain, what we understand is
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1 scientific effects or process, how you apply

2 that in a preventive or precautionary way and

3 how we should apply that under the Organic

4 Foods Production Act. What is your assessment

5 of our duty as a board to try to prevent

6 problems up-front, given scientific

7 uncertainty in balance with what we know about

8 mechanisms that are at play here? 

9 MR. DURST: Off the cuff, and it

10 really is just that, and, again, I don't have

11 the data to back it up, is that the amount of

12 resistance that one would find and the

13 transmission routes that one would experience

14 from field crops and orchard crops is

15 significantly different than it is in the

16 livestock realm where we know that there's

17 antibiotic resistance cropping up and they're

18 leading to human pathogens. So, again,

19 without having read the literature that you

20 suggested, which I will go back and do, I just

21 don't see that as a major concern or as a

22 significant factor as it is in the livestock
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1 side of things. 

2 CHAIRPERSON STONE: Zea? 

3 MEMBER SONNABEND: Hi, Bob. 

4 Wearing your consumer hat that you came up

5 here with, have you talked with other

6 consumers or what's your sense of how many of

7 your fellow consumers might agree with your

8 opinion? 

9 MR. DURST: Quite a number of them

10 have. Because I wear that hat, a lot of

11 people come to me and ask questions about what

12 I think about various organic things, and even

13 animal scientists and livestock people that I

14 work with at the university have said that

15 they're concerned about it from that

16 standpoint but they just don't, they don't get

17 why there's a problem with it in the crop side

18 of things. So my sense is that it's sort of

19 misdirected concern on the consumers' part

20 that they're equating antibiotic use in

21 livestock and antibiotic use in crops and

22 saying they're one in the same when the
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1 concerns are really significantly different

2 and the risks are significantly different. 

3 CHAIRPERSON STONE: Thanks, Bob. 

4 And Natasha Gallegos, are you here? Not

5 seeing Natasha. Sommer Gard? Sommer Gard? 

6 Okay. Lynn Huffman? Lynn? Yelena Korchman?

7 Yelena? Albert Strauss? And let me see who's

8 on deck before you start, Albert. Gabriella

9 Nunez? Is Gabriella here? What about Erik

10 Paul? Like I said, we had some confusion

11 about a week or two ago. Laura Reed? Okay. 

12 Judith Reedy? No Judith. Amy Wachspress? 

13 Okay. We're looking at moving up some of

14 tomorrow's agenda to today to give us more

15 time tomorrow. Kathie Weinmann, Weinmann? 

16 Jennifer Wilcox? Michelle could tell that

17 something was going on here. Jessica Zern? 

18 Jessica? And we know Terry Shistar is here,

19 so it looks like, Terry, you're on deck. 

20 Okay. There you go.

21 MR. STRAUSS: Okay. Thank you for

22 the opportunity to speak today. My name is
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1 Albert Strauss. I'm an organic farmer from

2 Northern California, and I'm also the founder

3 of Strauss Family Creamery. We produce

4 certified organic dairy products, including

5 milk, yogurt, butter, ice cream, sour cream,

6 and Greek yogurt. And we distribute in the

7 Western United States. My dairy farm in

8 Marshall was the first certified organic dairy

9 farm west of the Mississippi River, and my

10 creamery was the first 100-percent certified

11 organic creamery in the United States. 

12 In 2006, I found my certified

13 organic corn was contaminated with GMOs by up

14 to six percent. In the following two years,

15 I implemented a GMO testing program at our

16 dairies and the creamery to keep GMOs out of

17 our processes and products. In 2010, the

18 creamery and our dairy farms because the first

19 to achieve non-GMO project verification. 

20 I'm here to talk about the threat

21 of GMO contamination to organic crops and the

22 importance of non-GMO verification in the
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1 organic industry. GMO contamination is

2 occurring in organic crops. A study from the

3 Organic Trade Association in 2011, which I

4 display, found that more than 30 percent of

5 certified organic corn was contaminated and 11

6 percent of that exceeded the EU threshold of

7 0.9 percent.

8 This puts organic dairy farms like

9 mine at risk. It is increasingly difficult to

10 source certified organic feed for my cows, and

11 the prices are continuously rising. The

12 deregulation of genetically-modified alfalfa

13 has added to this problem. The supply of

14 organic feed will only decrease as GMO

15 contamination increases.

16 Our consumers expect our products

17 to be non-GMO. We want to make sure that we

18 want -- excuse me. We want to make sure that

19 what we eat is free of GMOs. I believe that

20 non-GMO verification is essential.

21 Organic practices don't allow for

22 the use of GMOs, and the organic seal should
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1 reflect that. I believe that organic

2 certification is the gold standard, and it

3 should include non-GMO verification. I,

4 therefore, suggest that we have a meaningful

5 threshold for GMO contamination that is

6 defined and implemented in the National

7 Organic Program and the National Organic

8 Program requires a testing and verification

9 standard for GMOs.

10 On a different subject, I also

11 want to urge the NOP to make the certification

12 processes easier for farmers. The burden of

13 all the paperwork is tremendous and very time

14 consuming. If there is a way in which we can

15 make the process simpler and more efficient,

16 I, as a farmer, would very much appreciate it. 

17 Thank you. 

18 CHAIRPERSON STONE: Thank you. Is

19 there questions? Francis? 

20 MEMBER THICKE: Thank you, Albert. 

21 Do you have any suggestions on the threshold

22 limit for GMOs in organic and also the testing
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1 procedures that would be required or

2 frequency?

3 MR. STRAUSS: Well, for feed or

4 for seed, I mean, I think that, as long as we

5 get a testing and verification program in

6 place, the thresholds can start higher and you

7 can tighten them over time. And you have to

8 start with a program. You can't start -- if

9 you get stuck on thresholds or rejection, you

10 know, if you have to reject a load if it's

11 over a threshold, I think you get diverted

12 away from the goal of eliminating GMOs from

13 our food supply.

14 MEMBER THICKE: Would you think,

15 though, that testing, routine testing of feed

16 would be necessary or seed only perhaps?

17 MR. STRAUSS: I think everything.

18 MEMBER THICKE: Everything.

19 MR. STRAUSS: There is all these

20 points of risk. Seed, feed, ingredients in

21 products all need to be tested and verified 

22 and have strict analysis on each of them. It
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1 could be started with a strip test, but I

2 think we need to start somewhere and get it

3 implemented. And it should be under the

4 organic program.

5 CHAIRPERSON STONE: Jean?

6 MEMBER RICHARDSON: Mr. Strauss, I

7 know you weren't testifying on GMO vaccines

8 for cattle, but I wonder if you would, as a

9 dairy farmer, you would have some opinion or

10 explain to us how you verify that none of the

11 vaccines that you give to your dairy cattle

12 have GMO in the vaccines? 

13 MR. STRAUSS: We contact each of

14 the manufacturers and get a letter stating how

15 they manufacture their vaccines and to verify

16 they're not from genetically modified, derived

17 from genetic modification. 

18 MEMBER RICHARDSON: And does that

19 work well for you? So you get written

20 documentation to support non-GMO?

21 MR. STRAUSS: Yes.

22 MEMBER RICHARDSON: Yes. Thank
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1 you. 

2 CHAIRPERSON STONE: Nick? 

3 MEMBER MARAVELL: Jean asked my

4 question. 

5 CHAIRPERSON STONE: And Jay? 

6 MEMBER FELDMAN: Thank you. 

7 Thanks for being here. I'm interested if you

8 have any thoughts on GMO contamination

9 prevention and, as we, as a board, try to

10 communicate the views of the organic community

11 to the Secretary of Agriculture, what we

12 should be saying, as a board, relative to

13 prevention of contamination?

14 MR. STRAUSS: So what I think the

15 OTA study showed is, I didn't show all the

16 slides in the whole study, but, once you test

17 and verify a required testing and verification

18 from your suppliers, the contamination level

19 went dramatically down. The corn actually

20 preserved and organic that was tested was only

21 at, I think, 11 percent contamination level

22 above the 0.1 percent, compared to organic
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1 that wasn't tested, you know, at the 30

2 percent.

3 So just requiring a testing

4 regiment reduced the GMO contamination. I

5 think there's unintentional -- people aren't

6 paying attention to GMOs if they're not

7 required to. Does that make sense? 

8 MEMBER FELDMAN: Yes, it does. 

9 I'm interested, though, further down the chain

10 where we have co-existence, say, you know, out

11 in the fields, in terms of production of

12 genetically-engineered crops and conventional

13 organic crops that are not GMO. How we

14 protect the purity of the crop, do you think

15 about that as an advocate for changes in

16 practices that go beyond the scope of this

17 board, certainly, but affect our ability, at

18 the end of the day, to deliver a product to

19 you as, you know, as a user of feed, how we

20 can assure the delivery of a product that is

21 free of GMO contamination? 

22 MR. STRAUSS: I think all the seed
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1 has to be tested and verified. I don't think

2 there's any way around it. 

3 CHAIRPERSON STONE: All right. 

4 Thank you. Okay. Terry is up. David Moore,

5 David Moore here? Okay. David Moore is on

6 deck. 

7 MS. SHISTAR: My name is Terry

8 Shistar, and I'm on the Board of Directors of

9 Beyond Pesticides. This slide shows some of

10 our current and former board members. We have

11 a long history of involvement with organic

12 production. Our roots are in the problems of

13 agriculture, from poisoning of farm workers to

14 contaminated food, soil, air, and water. We

15 have promoted organic production and the

16 organic model in non-production situations as

17 a solution to pollution.

18 If you visit our website, you'll

19 see a section called eating with a conscience. 

20 It's there because, for us, organic production

21 is not only about good, safe food, it's about

22 saving the Earth and those who live there. 
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1 I'm going to talk about restoring

2 the public's expectations of organic. We've

3 submitted comments on most of the issues

4 before the Board, but I'll focus on three

5 today: tetracycline, inert ingredients, and

6 other ingredients.

7 The public has a strong

8 expectation that antibiotics are not used in

9 organic production. This may be a

10 misconception, but it's one promoted by the

11 organic producers and even the USDA. There

12 are reasons that the public does not want

13 antibiotics used on organic apples, just as we

14 don't want carcinogens used on them. These

15 reasons are based on science and personal

16 experience.

17 The science was presented to you

18 in the minority position of the tetracycline

19 report. My personal experience includes a

20 strep infection that failed to respond to a

21 couple of antibiotics, as well as several

22 bouts of my son's ear infections that required
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1 more than one antibiotic. I'm sure all of you

2 have had similar or worse experiences.

3 We were disappointed with the

4 report of the majority of the Crops

5 Subcommittee. It reflects the same kind of

6 blind denial as when conventional apple

7 growers denied, and some still deny, the

8 science concerning alar. We would like to

9 prevent a public revolt against organic apples

10 and organic food in general, similar to the

11 alar rebellion that was so costly to apple

12 growers.

13 From the growers' perspective,

14 there will never be a right time to end the

15 use of antibiotics. There will always be

16 another silver bullet on the horizon, another

17 reason to postpone the decision for another

18 two years. The decision to eliminate them has

19 been put off for too many years. The only

20 decision you can make that will restore the

21 public's expectations is to uphold the 2014

22 expiration date.
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1 As you all know by now, so-called

2 inert ingredients in pesticide products are

3 not biologically or chemically inert. In

4 fact, because OFPA criteria have been applied

5 to active ingredients, these additives,

6 especially those formerly on List 4B, are

7 probably the most toxic ingredients in the

8 pesticide products used in organic production.

9 We congratulate the Board for

10 undertaking the project and reviewing these

11 mostly secret ingredients, and we urge you to

12 start immediately on the review to restore the

13 expectation that hazardous chemicals are not

14 used in organic production.

15 So-called other ingredients, also

16 known as ingredients within ingredients in

17 processed organic foods, did not meet the

18 public expectations, which can be simply

19 stated all ingredients of a product labeled

20 organic must be either organic or on the

21 National List for that purpose. The public

22 has a right to this expectation because it is
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1 a law. In place of this very clear policy,

2 the Handling Subcommittee proposes to make

3 distinctions that are not in OFPA but to allow

4 ingredients that do not meet OFPA criteria and

5 to ignore existing law, all, apparently, in

6 order to codify mistakes that have been in the

7 past, that have been made in the past.

8 Again, the Board needs to take

9 action to restore public expectations of

10 organic food. Public expectations are what

11 caused people to buy organic food. You cannot

12 ignore what the public expects without

13 destroying the market for organic food for

14 those of us, and for those of us who place our

15 faith in organic production to heal the Earth,

16 the destruction of the organic brand would be

17 tragic. Thank you. 

18 CHAIRPERSON STONE: Very good. 

19 Steve, she got you on that one, buddy. 

20 Questions? Okay. Thank you very much, Terry. 

21 Thank you for your written comments, as well. 

22 We've got David Moore is up and Harriet Behar
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1 on deck. 

2 MR. MOORE: All right. Good

3 afternoon or good morning. I'm David Moore. 

4 I'm a California pest control advisor and

5 qualified applicator and I work for Neudorff. 

6 For over a year now, I've been speaking to

7 agronomists, organic growers, and extension

8 farm advisors about the issues of organic weed

9 management, and I hear one answer and that is

10 we need more tools.

11 There's already a powerful

12 environmentally favorable and allowed material

13 that should be among those tools, and that

14 material is soap. The environment and

15 toxicological advantages of soap pesticides

16 are very well known and, yet, their use for

17 weed control is illogically and capriciously

18 restricted on food crops.

19 I'm sure you all know the language

20 of OFPA. Soaps are explicitly in OFPA as

21 allowed synthetic materials. If that's not

22 original intent, I don't know what is.
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1 Support for lifting the

2 restrictions on herbicidal soaps for food

3 crops comes from growers of all stripes

4 because all growers have problems with weeds. 

5 But weed control is the most significant

6 challenge facing not just organic agriculture

7 but all agriculture. It's been an article of

8 faith for many years and, yet, the flimsiest

9 of logic keeps this material from growers of

10 food crops. 

11 Organic regulation prides itself

12 on being a process standard, not a product

13 standard. But the restriction on soaps stands

14 in the way of better process.

15 I won't try to detail the many

16 reasons why herbicidal soaps are consistent

17 with sustainable organic production systems. 

18 I'm here to encourage each of you to consider

19 this for yourself. Ask somebody from the NRCS

20 about destructive forces of tillage and

21 cultivation, especially the concept of tillage

22 erosion. Ask someone from EPA about soaps as
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1 pesticides and read the soap salt registration

2 eligibility document and the fact sheet. 

3 Ask the soil scientists about how

4 cultivation affects soil organic matter and

5 ask a certifier about how they enforce the

6 soil fertility standard and about what's

7 happening to the soil organic matter on the

8 farms they certify. Ask a hydrologist how

9 much clean, sweet water we have in the arid

10 West to give to weeds that compete with drops. 

11 Ask an orchardist or a vineyard manager what

12 they most need to become or remain organic. 

13 Ask David Granatstein about what happens to

14 orchard soils under plastic mulch for years,

15 and ask Carol Dawson about the challenges of

16 managing weeds by flaming.

17 Ask John Foster, Zea Sonnabend, or

18 Carmela Beck what they hear from growers in

19 and around the Salinas Valley. Ask a

20 vegetable grower how much diesel they burn

21 pulling cultivator rigs through their fields

22 and how many hours of hoeing it takes to bring
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1 a leafy greens crop to market. Ask a farm

2 worker how much he or she likes hoeing weeds

3 or running a two-stroke weed eater all day. 

4 Presumably, those of you all that

5 are not farmers yourselves know your organic

6 farmer. Ask your organic farmer what he or

7 she needs for weed control. Ask your organic

8 farmer how they like competing with a foreign

9 grower that can have weeds pulled or hoed for

10 a few dollars a day. And then ask yourself if

11 it's worth reconsidering this annotation. 

12 Thank you very much.

13 CHAIRPERSON STONE: Very good. 

14 Questions? Harold? 

15 MEMBER AUSTIN: With your

16 description of what the soap material would be

17 competing with as far as the hoeing, the

18 flaming, the other, what would your opinion be

19 the impact of the inclusion of soap as an

20 allowed substance to sustainability to

21 reduction of the carbon footprint, the

22 benefits that it would bring to organic in
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1 general? 

2 MR. MOORE: I don't have hard data,

3 but we know that growers spend a lot of energy

4 cultivating. We know that cultivation requires

5 a lot of energy. Flaming, as I understand it,

6 is fairly propane-intensive, so it has a

7 fairly large carbon footprint. And you can

8 certainly pull a spray rig on wheels through

9 an orchard or a vineyard with a lot less

10 horsepower than you need to pull a disk or

11 harem. 

12 MEMBER AUSTIN: With the research

13 that you guys have done with the material, are

14 there any perceived negative impacts that you

15 could tell us that would be of concern to all

16 of us, as organic farmers? 

17 MR. MOORE: EPA loves soaps as

18 pesticides. The registration eligibility

19 evaluation from 1992, all 300 pages of it,

20 exciting reading, gets into a lot of detail

21 about why they like soaps so much. It talks

22 about environmental half lives as short as 24
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1 hours, about the fact that the fatty acid

2 chain on a soap molecule is essentially food

3 to almost any living thing, and it's

4 biologically broken down very rapidly. 

5 I think the only negative that

6 we've encountered so far is the fact that

7 there's a warning label on most of the

8 concentrates because of the potential for

9 temporary eye damage. 

10 CHAIRPERSON STONE: Thank you very

11 much. So Harriet is up, and is Steven Shore

12 here? Steven? What about Bozena Cverckova,

13 if I'm saying it close enough? Ryan Stewart? 

14 Ryan? So Michael Sligh? All right. Harriet?

15 MS. BEHAR: I am Harriet Behar with

16 MOSES, and we educate, inspire, and empower

17 farmers to thrive in a sustainable and organic

18 system of agriculture, and we envision a world

19 where all agriculture will be organic and

20 sustainable. I want to say thanks to the NOP

21 for working on the apiculture standards. I'm

22 probably one of the few people who say that. 
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1 And I want to also say that I support the full

2 review of other ingredients to the OFPA

3 criteria.

4 I'd also like to say, for the

5 vaccines used under excluded methods, that I

6 really would like the NOSB to expedite the

7 process in providing farmers the tools they

8 need to verify that their vaccines are not

9 GMO. This is kind of a travesty that right

10 now we have this non-compliance occurring in

11 the world of organic livestock production, so

12 I encourage you work as quickly as possible. 

13 I'm concerned that the market for non-GMO

14 vaccines, that the people who make those non15 GMO vaccines need to know that there's a

16 market out there, and the longer we wait and

17 don't provide them with a market, that the

18 vaccines for livestock will move more and more

19 towards GMOs. 

20 On antibiotics, I don't feel that

21 there has been an urgency felt by the organic

22 tree fruit community until now, that they
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1 really need to be working towards finding

2 another solution. They have matured with the

3 use of these materials, unlike livestock

4 which, from the very beginning, didn't have

5 antibiotics and became, as they grew they

6 learned all those alternatives. I think that

7 -- so I support a 2016 extension, but I would

8 like there to be guidance given by the NOP

9 through their program manual to really spell

10 out all those alternatives.

11 I'd also like to make it clear

12 that our pest control hierarchy includes the

13 use of materials that, at times, there's a

14 problem that, no matter what you do in

15 practices, I support the systems-based

16 approach very strongly, but the use of

17 materials is part of that systems-based

18 approach. And so as you look at all of the

19 materials that you review, I think it's

20 important that you look at the risks involved

21 and the problems that a systems-based approach

22 might not be able to solve, and that's when
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1 those materials are important.

2 Look at what's happening in

3 Europe. What they use instead is copper. And

4 so you need to be comparing materials to

5 materials when you're looking at the pest

6 control hierarchy and whether or not to put

7 things on the National List. And we all know

8 that copper is a problematic material.

9 Another thing, too, in my

10 experience, when growers leave organic

11 production, they don't tend to come back. And

12 so we don't want to lose this production. We

13 want to keep these people, whether they're in

14 organic with their soul and their heart or

15 just there for the economic benefits. We want

16 to see organic production remain in organic. 

17 I believe antibiotics problematic from a

18 systems approach because they do get

19 resistant. So human health is an issue, but

20 I'm also looking at the farmer side. It's a

21 problematic material from the beginning. 

22 So I just encourage you to give
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1 the growers a little bit more time. I think

2 they know the urgency now, but don't, I don't

3 want to see it continually extended. Thank

4 you. 

5 CHAIRPERSON STONE: Thanks,

6 Harriet. Jean? 

7 MEMBER RICHARDSON: Harriet, can

8 you help me with the antibiotics in Europe,

9 the information that you have on that? You

10 said that they've obviously had the fire

11 blight problem for a long time and they've

12 been addressing it with certain forms of

13 copper. As I understand it, the present forms

14 that are being used are different from those

15 that were used in the past in terms of the

16 type of copper, and their rate of accumulation

17 is not the same as it was in earlier kinds of

18 products that were being used. Do you have

19 any sort of factual data that would help me to

20 better understand how they deal with it in

21 Europe? 

22 MS. BEHAR: My understanding is
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1 that the use of copper to control fire blight

2 is very heavily regulated because they've had

3 issues with copper buildup in the soil. So

4 they've started to regulate that use of the

5 copper, so that's where I see the problem. If

6 they've had to come in because it's been used

7 so heavily, just as you have with your use of

8 copper have had to, over time, make it more

9 restrictive because of the dangers of the

10 buildup, because copper is an element that is

11 not going to go anywhere. It's not going to

12 break down any further.

13 So as far a lot of data, no, but I

14 just know what the European Union is doing in

15 the control of the use of copper because

16 they've seen it to be a problem. 

17 MEMBER RICHARDSON: So is copper

18 the primary way in which they're dealing with

19 fire blight in Europe, or are there other

20 products that are being used in an integrative

21 approach? 

22 MS. BEHAR: I think there's an
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1 integrated approach, but when things get

2 serious they come in with the big guns, which

3 is copper.

4 CHAIRPERSON STONE: Jay? 

5 MEMBER FELDMAN: Thanks, Harriet. 

6 You know we all love organic farmers, and

7 organic consumers are an integral piece of the

8 growth of the organic industry and the fact

9 theat organic consumers dig deeper in their

10 pockets against proclamations of the safety of

11 the conventional food supply by regulators and

12 other agencies. You know that there's

13 tremendous support for organic production and

14 its growth on a consumer side, so I hope

15 that's clear. I know it's clear to you, to

16 everybody else here, as well. 

17 However, you also know and have

18 followed the regulatory process for a very

19 long time. And I wonder if you could address

20 the fear that I have that extending, adding an

21 extension to an extension to an extension

22 results in another extension. And what
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1 assurance can this board have that, at the end

2 of another two-year period, that we or the

3 future board will, in fact, uphold that

4 extension? Is there any evidence? Point us to

5 some evidence where that has happened in a

6 timely fashion, especially given the urgency

7 that we, at least I and some many others feel

8 about the public health threat that we're

9 facing here and the urgency associated with

10 that.

11 I'm really searching for that

12 assurance because I'm fearful that the

13 consumer community will see this as just

14 dragging its feet, government, USDA overtaken

15 by grower interest, disrespectful of consumer

16 investment in a sector of food production that

17 they have invested their families' resources

18 into. I'm fearful that we will be undermining

19 that trust and faith. So help me out here

20 with assurances that we get to an endpoint. 

21 MS. BEHAR: Well, I can't make any

22 assurances that anybody will never bring
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1 forward another petition in the future. But

2 as I said, I think that the National Organic

3 Program should put out guidance as soon as

4 possible, considering the centrist position

5 that NOC had put forward listing all of the

6 various systems and other materials that could

7 be used and really having that be up-front and

8 putting the growers' feet to the fire in the

9 two extra years that they are really working

10 on all those other alternatives so that it

11 shows the urgency that they need to be moving

12 forward. I don't feel that their feet have

13 been to the fire until now, and so we really

14 are going to hold them to that that, during

15 that two-year period, they are using all of

16 those tools, experimenting with all of those

17 tools, and moving towards the time when they

18 know that antibiotic is going to be gone.

19 And so that's where I feel we're

20 giving them that urgency and having that very

21 strong guidance from the NOP that not only do

22 they try one, two things that, when the
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1 inspector comes, the question is, you know,

2 your spacing is very tight here when you're

3 doing new plantings, are you giving more

4 space, you know, because that's part of the

5 issue is having a very tight planting, that

6 there's not enough air circulation. 

7 All of these things I don't think

8 have been pushed as hard as they could have

9 been at the certification level and have

10 really been shown to the growers that they

11 should be doing all of these things. And

12 their feet will be in the fire when they know

13 that in two years, 2016, it will be gone.

14 MEMBER FELDMAN: A quick follow15 up. Is there precedent for that kind of NOP

16 guidance holding feet to the fire on practices

17 and performance?

18 MS. BEHAR: Well, I mean, guidance

19 does not have the force of regulation. That's

20 understood by all. But when it's transparent

21 and out there saying this is what we are

22 telling the certifiers to do when they are
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1 looking over the organic system plan, I think

2 it does give the growers more impetus to

3 follow through. Rather than just saying

4 cultural, biological, and physical controls,

5 you're actually giving them some of those

6 tools spelled out and it gives the certifiers

7 more direction in what they're looking for

8 when a producer is using the antibiotic for

9 fire blight. 

10 CHAIRPERSON STONE: Nick? 

11 MEMBER MARAVELL: Harriet, I know

12 you've worked with an awful lot of farmers. 

13 What do you feel are the most effective ways

14 to communicate a change in practice to the

15 farming community? And do we, are we in a

16 situation now where that's possible? 

17 MS. BEHAR: Well, I think, to the

18 organic farming community, there's many of

19 them who go to conferences and they get

20 newsletters. But really it's when that

21 inspector comes to the farm, and they're

22 concerned about continuing their organic
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1 certification. So if they had a guidance

2 document with them when they came with the

3 National Organic Program seal on the top

4 saying have you gone through these various

5 protocols, cultural, biological, mechanical,

6 physical, I think that would really show them

7 that, whoa, here's this, it's got the NOP seal

8 on this, this is what I should be doing.

9 They all really, at this point,

10 have read the rule. But when that inspector

11 shows up or they get a direction from their

12 certifier, they all are looking at that. I

13 can't guarantee they're all reading our

14 newsletter or they're all going, you know,

15 their members of the NOP. That is not as

16 transparent as when they are having that

17 direct visit and their annual certification. 

18 That's when they're paying attention. 

19 CHAIRPERSON STONE: Harold? 

20 MEMBER AUSTIN: Harriet, during

21 your presentation, you mentioned that part of

22 the control process would be integrated past
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1 management and control practices. We received

2 a written comment that stated that integrated

3 pest management had no basis for belonging in

4 organic production program at all. What's

5 your interpretation of that? To me, it would

6 appear that the basic fundamental beliefs of

7 what organic really stands for would be that

8 integrated control process using the

9 variation, the various tools that the growers

10 typically would apply, whether it's fire

11 blight control or other. Could you explain

12 your comment and what you feel that that

13 integrated pest management approach to an

14 organic farm systems plan means to the organic

15 grower? 

16 MS. BEHAR: I was referring more to

17 the, not integrated pest management but to the

18 pest control hierarchy that's in our

19 regulation, which is that you start with

20 mechanical, physical, and cultural controls. 

21 When those are not effective, you move to

22 natural products, biological products. When
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1 that is not effective, then you have the use

2 of the synthetics that are on the National

3 List.

4 But to say that producers only

5 have those top two tools and the last one of

6 the synthetics is not part of that hierarchy

7 is really not looking at it holistically and

8 that that last synthetic piece is part of it. 

9 It is our last resort, but it is still part of

10 the whole system. 

11 And so when you are reviewing

12 products, materials to put on the National

13 List, I think you need to look at the

14 effectiveness of the first two and how strong

15 is the need for that last synthetic that would

16 be the last resort. And we always want to be

17 encouraging that systems-based approach, but

18 in integrated pest management, in the

19 conventional world, really has, it doesn't

20 really fit with organic because it's mostly

21 based in the lessening of the use of toxic

22 materials, not really looking at a systems-
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1 based approach for control. It's just, you

2 know, transitioning from one toxic material to

3 something less toxic. 

4 MEMBER AUSTIN: But if we were to

5 apply that terminology to organic, organic

6 systems plan, and using the integrated control

7 process and starting at the control points

8 that you just laid out, wouldn't that systems

9 approach then apply, though? I mean, isn't

10 that exactly what an organic systems plan

11 really represents is we are going to start at

12 that lower level and work our way up and use

13 that synthetic material only as that last

14 resort? 

15 MS. BEHAR: Correct, yes. And

16 that's why I want to have the National Organic

17 Program give a little bit more direction on

18 what those first two items in the hierarchy

19 really spell it out for people that these are

20 all the tools they should be using, not just

21 we did a little blossom thinning and it didn't

22 work or, you know, whatever it might be, we
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1 monitored and we had to use it. I mean, what

2 are they doing in a long-term system in their

3 orchards to lessen the effect fire blight has? 

4 Rootstocks, varieties, I mean, these are all

5 things that they should be working on,

6 including working with the consumer base to

7 accept those less problematic varieties in the

8 marketplace, too. I mean, they have responded

9 to consumer demand for the Pink Ladies and the

10 Fujis and the Galas that are, that tend to be

11 more problematic when there's fire blight. 

12 But I think they should have been working and

13 need to be working on promoting those

14 varieties that don't need the use of

15 oxytetracycline. 

16 CHAIRPERSON STONE: Colehour, if

17 you'll wrap this up for us. 

18 MEMBER BONDERA: Yes, I'm going to

19 try to wrap it up with a very specific

20 question, but I just want a little bit more

21 information based on, I guess, mixed messages

22 that I'm getting and something that you
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1 commented on, which is relating planting

2 spacing of trees to the need for antibiotics. 

3 And I think, on our tour, my understanding

4 was, and it's not very deep so I need help

5 here, my understanding was that bees are the

6 way that this is moved around between the

7 trees and, therefore, to a large degree, the

8 spacing between the trees is not really a big

9 factor. But your comment suggested that you

10 think that the spacing of the trees, from a

11 systems plan, is a factor related to the need

12 for antibiotics, in some way or another. I'd

13 like you to comment further on that part of

14 what you said. Thank you. 

15 MS. BEHAR: Well, that's just one

16 of the tools. And when you have that high

17 humidity environment, anything that you can do

18 to move, you know, have more airflow, I think,

19 could be one of the items in a larger toolbox

20 of things that you're doing. Pruning, you

21 know, also provides that airflow, that sort of

22 thing. You know, interspersing in the blocks,
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1 you know, not having monocultures of very

2 susceptible varieties altogether. I mean,

3 there's a lot of different strategies that the

4 producers can use. 

5 CHAIRPERSON STONE: Thank you,

6 Harriet. So Michael Sligh will be the last

7 presenter before lunch. We are ahead of

8 schedule. We're going to evaluate how we

9 adjust tomorrow's schedule. I'll remind the

10 Board that we were able to have a little

11 latitude today, but we may not have this

12 luxury tomorrow. But some of the folks, we're

13 in the after lunch aspect, so some of these

14 people may be getting here at lunch. So

15 that's why we'll break a little early and then

16 come back on time at one. So Michael? 

17 MR. SLIGH: Good morning. I am

18 Michael Sligh with the Rural Advancement

19 Foundation International. I'm a founding

20 member of this body and also an organic farmer

21 since the 1970s. I wanted to start by, well,

22 Miles is not here, but I wanted to really
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1 thank him and encourage this urgent action

2 towards sound and sensible certification. 

3 This is very timely, very welcomed, and

4 looking forward to that making a big

5 difference in the paperwork burden on organic

6 farms and operations. So thank you for that,

7 and we can help with that in any way you need

8 help with.

9 On the other topic, I think that

10 we had a pre-NOSB meeting yesterday. We had

11 a very productive and high-quality

12 conversation about this issue of antibiotic

13 use in tree fruit and the conundrum that we

14 find ourselves in and how we got here. We

15 found very broad cross-sector support that we

16 should remove antibiotics out of the remaining

17 area of organic production. 

18 We also recognize that it is not

19 productive to use scare tactics or distorting

20 information that would lead people to believe

21 that organic fruit is full of antibiotic

22 residue. But we also found it equally
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1 damaging that no one here would really be

2 arguing for antibiotic use and would not be

3 recognizing the global implications of

4 antibiotic resistance and that that is a real

5 threat and that organic has built its brand

6 here in the United States around that

7 exclusion and around that distinction and that

8 organic livestock producers had benefitted

9 from that distinction and that we should

10 continue to be that haven where consumers can

11 find a safe and sane alternative to antibiotic

12 use in agriculture.

13 We also recognize that we all take

14 a responsibility for being in this conundrum,

15 that we have encouraged the production and

16 expansion of susceptible varieties and that

17 the marketplace has promoted them and that all

18 of us, as organic apple-eating consumers, have

19 also contributed to this conundrum we find

20 ourselves in. But at the core of this, to me,

21 is, you know, I was leading the NOSB in 1995. 

22 We thought we were settling this matter with
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1 a two-year extension that would be resolved in

2 1997. So there is this lack of institutional

3 memory both across administrations and across

4 NOSBs that we somehow need to embrace and

5 memorialize. And I strongly urge this board

6 to look at, when you make this decision, to

7 create a process where you reflect on the

8 lessons from this and you memorialize this

9 decision so that you're very clear about that. 

10 And future boards can then refer to that

11 clarity of thought because that's part of the

12 difficulty here. I try to go back and parse

13 through that 40-page analysis that was put

14 together about the history of this subject,

15 and it's very convoluted and it's very, you

16 know, frankly, checkered. 

17 And we have to be, as a board, we

18 have to be able to send the clear signal to

19 the marketplace that innovation is being

20 encouraged and give the marketplace that time

21 to create that innovation because the model of

22 organic is continued quality improvement over
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1 time and that has got to be at the core of it. 

2 And if that signal is confused, the market is

3 not going to respond. We're not going to come

4 up with an alternative to antibiotic if we

5 don't signal that correctly. Thank you. 

6 CHAIRPERSON STONE: Thanks,

7 Michael. Questions? Jay? 

8 MEMBER FELDMAN: Thanks, Michael. 

9 I'm curious, given your experience with all

10 this, why you feel it's so difficult to get

11 something off the list once it's on? I mean,

12 even with this recent, relatively recent

13 decision on sodium nitrate, I would argue that

14 it wasn't because of the true analysis that

15 the Board did but more because of

16 international pressure that that was moved

17 off. So even that isn't a good example of the

18 Board removing something based on the

19 criteria, the list of criteria that we utilize

20 for review.

21 Why is it so difficult? I mean,

22 the whole concept of sunset and continuous
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1 improvement, it seems hard to operationalize

2 for some reason. Why do you think that is? 

3 MR. SLIGH: Well, certainly, in

4 the founding Board, it was our strong

5 understanding that the model we were using was

6 that, as we were encouraging the growth of

7 organic, we recognized there were certain

8 transitional tools or materials that we would

9 need that would -- you know, bottlenecks or

10 deficiencies in our holistic system. And so

11 the idea was that you could have something on

12 a list for a period of time, but it could come

13 off. And, in fact, much of what we voted on

14 in the original list was predicated on that

15 strong assumption that, A, annotations gave

16 you scope and clarity of use; and, secondly,

17 that those materials were not permanent

18 additions and they would come off as better

19 choices were innovated.

20 And so that's the model that this

21 was built on. And why it hasn't worked is, I

22 think is, there are multiple factors as to why
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1 it hasn't worked, but one I alluded to was the

2 fact of our institutional memory and the fact

3 that the board rotates and the new board

4 coming in may not share the former board's

5 analysis. There can be new data that comes. 

6 The NOP also changes staff, and they have had

7 different interpretations of this over time. 

8 So that continuity of thought and clarity has

9 not persisted. 

10 And then I think we have also

11 violated our own process probably several

12 times where we failed to follow the process,

13 just for many different reasons. And so, to

14 me, this concept of takings and the economic

15 impact, that was not a part of our thinking in

16 the original analysis of this, and we

17 certainly never thought about that in putting

18 it into the language of how this operated. 

19 This is a new factor that has emerged in this

20 debate, and I think it's one that both the

21 Department and the NOSB needs to wrestle to

22 the ground because, indeed, if that is the
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1 barrier, that's where you need to have that

2 conversation. 

3 I don't want to be between you and

4 lunch. 

5 CHAIRPERSON STONE: No, that's a

6 good way to send us off for lunch. Thank you. 

7 So I've got about a quarter until 12. We'll

8 break now, and we'll come back promptly at one

9 and -- excuse me. Oh, did you have a

10 question? I'm sorry. Go ahead. Sorry I

11 didn't catch you. 

12 MEMBER BONDERA: Thank you. 

13 Sorry. I hate to interrupt a break because I

14 want one maybe as bad or worse than anybody,

15 but, Michael, I appreciate what you said and

16 I am intrigued a little bit and inspired a

17 little bit, but I'm, in my brain, thinking

18 about, when you introduced yourself, you

19 mentioned the fact that you're a farmer. And

20 I'm curious if, you know, I wrote down what

21 you said, innovation is being encouraged. 

22 As a farmer, do the behaviors of
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1 the NOSB or the NOP encourage innovation in

2 your activities at the practical farming scale

3 and/or -- and that doesn't have to be a yes or

4 no answer -- but and/or what could we be doing

5 realistically and in practice that would be

6 encouraging innovation? Because from my

7 perspective, it's a great idea, but I don't

8 know where to go with it. If you could, I

9 don't know, address that. Thank you. 

10 MR. SLIGH: Well, I mean,

11 certainly, clarity of standards and clarity of

12 instruction helps to provide, you know, that

13 motivation to do the best practice. But I

14 think where this is broken down has been in

15 this decision-making around encouraging

16 alternative improved products to be developed. 

17 If I was a German company and I had a product

18 that might be a solution to the antibiotic

19 issue here that was actually found in this

20 local area, but the message from this body was

21 ambivalent, I'm not sure I would make that

22 investment. 
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1 And so that's what I'm getting at

2 is that, if you want to encourage better

3 tools, this body has to be clear, you have to

4 be decisive, and you have to set goals, and

5 then you have to follow them out, because

6 every time you don't do that it just, I think

7 it throws a monkeywrench in that ability. 

8 Farmers, of course, need time to adapt. I

9 mean, I'm not for taking anything away that

10 doesn't have a better replacement, but we've

11 been at this a long time and we've got to run

12 this railroad better than this. 

13 CHAIRPERSON STONE: Thanks,

14 Michael.

15 MR. SLIGH: Thank you. 

16 CHAIRPERSON STONE: So Urvashi

17 Rangan will be on first thing after lunch at

18 one. We'll break and return at 1:00. Thank

19 you very much.

20 (Whereupon, the above-entitled 

21 matter went off the record at 11:50 a.m. and

22 resumed at 1:05 p.m.)
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 (1:05 p.m.)

3 CHAIRPERSON STONE: If we could

4 have the Board members take their seat,

5 please. We want to get started for the

6 afternoon session. We want to backtrack a

7 little and be sure. Some of those that

8 weren't available when their name was called -

9 - so Urvashi is still on because we asked her

10 to be, but is Gabriella Nunez available? I

11 don't see a hand. What about Erik Paul? 

12 Okay. Laura Reed? These are people that were

13 notified of being after lunch, so I'm checking

14 that back. Judith Reedy? No. Amy

15 Wachspress? Kathie Weinmann? Jennifer

16 Wilcox? Okay.

17 With that, we'll go where we are. 

18 MS. ARSENAULT: Tracy's here. 

19 CHAIRPERSON STONE: Okay. Tracy

20 is here. Okay. Jessica Zern? Okay. So

21 we'll back up to those that we do know. So at

22 this time, let me see who's going to be on
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1 deck. One second. So Urvashi is up, and Jo

2 Ann Baumgartner is on deck. Thank you. 

3 MS. RANGAN: Thank you. Good

4 afternoon, everybody. My name is Urvashi

5 Rangan. I'm head of the safety and

6 sustainability group at Consumer Reports. 

7 I've been there about 15 years, and I'm a

8 scientist. 

9 I'm here today to talk about, for

10 the most part, the antibiotics issue in apples

11 and pears. As you know, this has been a

12 controversial issue for the last couple of

13 years. It's something we've known about, too. 

14 I spoke with you all at the last National

15 Organic Standards Board meeting in Providence. 

16 This is something we don't think that comports

17 with consumer expectations of organic. It's

18 inconsistent in that it's the only product

19 that allows for antibiotics, and it really

20 doesn't comport with what consumer

21 expectations are.

22 But because we've had a lot of
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1 dispute about whether it comports with their

2 expectations or not, we actually conducted a

3 poll this month of over a thousand consumers

4 online and asked them the question. And so

5 the first question we wanted to know was

6 whether consumers actually knew about this

7 practice, so the question was are antibiotics

8 used to treat disease in apple and pear trees?

9 So about 70 percent, 67.9, did not

10 know that. They just don't know that these

11 things are being used in agricultural

12 practices, other than sort of what's going on

13 in meat production. Only 15 percent knew, 17

14 percent said they did not know, and 67 percent

15 -- I'm sorry, 17 percent said, no, they are

16 not used and 67.9 percent said they didn't

17 know. So the overwhelming majority of

18 consumers actually don't know that this

19 practice is going on.

20 Then we informed the same

21 consumers who were taking the survey that this

22 was a fact, that these were being used, and so
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1 should fruit from these trees be allowed to

2 have the organic label? Fifty-four percent

3 say no, thirty-five percent say they don't

4 know, and only ten percent say yes. 

5 So we've got some, at least

6 statistically, significant data here showing

7 what consumer expectations are around this

8 issue. Frankly, it hasn't been transparent. 

9 Consumers haven't known about it. We don't

10 talk about. We're part of that issue. We are

11 talking about it now because it needs to be

12 talked about, and it needs to be transparent

13 to consumers for as long as we are using these

14 materials. It is our position at Consumers

15 Union that we would like this oxytetracycline

16 to retire in 2014. We do not want any further

17 extensions on it. 

18 So there is a failure sort of of

19 transparency, and there's also a failure of

20 sunset. And I think consumers are weary of

21 materials that are being allowed in organic

22 production. I get calls from reporters all
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1 the time about it, about what materials are

2 being used, is that really appropriate, does

3 that comport with consumer expectations? And

4 the answer to these things around this issue

5 is no. And the failure of these materials to

6 sunset is a real problem in creating a real

7 incentive for organic alternatives to be

8 developed.

9 And I think we're all really

10 pleased that we are seeing the emergence of

11 these alternatives. Pamela Coleman from

12 Cornucopia can comment on even how long ago

13 these alternatives were starting to be

14 developed, but the real pressing rush didn't

15 happen until the last year or two. That's

16 because we're at year, what, seventeen or

17 eighteen of this listing on the National List. 

18 So this has been a very long time, and because

19 it doesn't sunset we diminish the incentive to

20 actually create commercially-available organic

21 alternatives.

22 But perhaps the most pressing
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1 issue of all are the public health concerns we

2 have around the use of antibiotics. And as a

3 scientist who runs safety and sustainability

4 at Consumer Reports, I can tell you that we,

5 as an organization, are simply against the use

6 of antibiotics in agriculture, in farming,

7 except for the treatment of sick animals. 

8 And, frankly, the problem with antibiotic

9 resistance is real. There is scientific data

10 around that. Thank you. 

11 CHAIRPERSON STONE: Thank you. 

12 Questions? Jay? 

13 MEMBER FELDMAN: Hi. Thanks for

14 coming to this important meeting. Explain a

15 little bit more about the process that you

16 use, please, to get public opinion, generally. 

17 And in addition to that, if you, as an

18 organization, really chose to sort of get the

19 word out, I guess you'd call this preliminary

20 type of work you did with a thousand, a

21 targeted population, what impact do you think

22 that could have, given your preliminary
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1 results? 

2 MS. RANGAN: Well, we just did

3 this poll about a week ago, Jay, and we have

4 done a press release yesterday, along with

5 Food and Water Watch and Center for Food

6 Safety. We all share the same position around

7 this. We all represent consumers. 

8 I think this poll, basically, was

9 conducted online. It's done by our national

10 survey center through Google Online Polls. We

11 actually have an entire survey department

12 dedicated to polling. And this is one of the

13 polls that we've done. It was these two

14 questions. It's more than a thousand

15 respondents, so it's statistically

16 significant. And it's randomized.

17 CHAIRPERSON STONE: Jean? 

18 MEMBER RICHARDSON: Hi, Urvashi.

19 MS. RANGAN: Hi. 

20 MEMBER RICHARDSON: So as a

21 scientist, could you point me to the direction

22 of any research which has been done which
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1 measures the amount of residues of antibiotics

2 left in fruit that have been harvested? 

3 MS. RANGAN: So, Jean, it's a good

4 question, and I'll start by saying our primary

5 concern with antibiotic use in these

6 situations is about the resistance and the

7 resistance that can grow and spread in the

8 environment. But residues are certainly

9 important to some consumers. Some consumers

10 don't want to buy things if they think it

11 might have residues.

12 There's no question that you can

13 get residues from the use of this, and there

14 are studies out there to show that. In fact,

15 on page 11 of your technical review from April

16 2011, the EPA 2006 source states there is a

17 high probability that oxytetracycline18 resistant bacteria are present in the

19 environment as a consequence of pesticidal

20 use, which may have negative consequences for

21 humans. 

22 So they've acknowledged the
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1 resistance. In terms of the residues, EPA set

2 a tolerance of 0.35 PPM for oxytetracycline in

3 apples and pears. They did that based on

4 field studies that they did looking at

5 residues and potential residues that may

6 result. The residue levels that they found,

7 in general, were at the limit of detection, a

8 little bit lower, but some were above that. 

9 So that suggests that the scientific question

10 of can it be possible is yes. Does it happen

11 all the time? No. And we know this use is

12 somewhat intermittent, so you're not going to

13 see always a residue on there. But the fact

14 of the matter is this practice can, in fact,

15 lead to that, although, like I say, we think

16 that's a secondary issue compared to the

17 resistance problem.

18 There's also other papers out in

19 Europe, but I encourage you to go to those EPA

20 sources, read through the EPA documents for

21 how they arrived at that tolerance level for

22 tetracycline. They have actually looked at
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1 the uptake in fruit. 

2 MEMBER RICHARDSON: A follow-up

3 question. If it's an issue and there have

4 been alternative ways of controlling fire

5 blight in Europe, why is that we have not used

6 the European materials to control fire blight

7 in the United States? 

8 MS. RANGAN: Well, I think that's

9 a really good question, and it's not that

10 we're always the same as Europe, but we began

11 in 1995 by putting these materials on the

12 list. And because we didn't retire things

13 properly like they should have been, it's now

14 almost 20 years later, and so back to the sort

15 of why don't we have these incentives created

16 for commercially-available alternatives? In

17 part, it's because the sunset system is

18 broken, and we don't retire materials when we

19 are really supposed to be retiring these

20 materials. And so we don't see these

21 developed in an adequate amount of time. 

22 CHAIRPERSON STONE: Colehour? 
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1 MEMBER BONDERA: Yes, thank you,

2 Urvashi, for what you've shared. And I

3 actually would like a little bit more

4 information from your perspective because I

5 also am a member of the public, I also am a

6 consumer, even though I'm here representing

7 farmers, and I think the truth is I'm curious,

8 in that survey, did it go the next level of

9 asking what people were concerned about

10 related to this, if you were informed them

11 through the survey that this was a reality? 

12 And I guess from a public health perspective,

13 were there questions and how those were

14 answered if they were in that? Thank you. 

15 MS. RANGAN: Sure. Colehour, you

16 know, we didn't go into this survey. There

17 was really two questions, and we really wanted

18 to be very targeted about asking about

19 antibiotic use as it relates to organic apples

20 and pears because, after all, that is the very

21 sliver of the issue we are focused on here.

22 So in terms of why consumers care
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1 about that, I'd like to offer at least some

2 greater perspective. And we, as an

3 organization, have a whole meat on drugs

4 campaign. We think that no animals should be

5 given antibiotics. We're pushing Trader Joe's

6 to only carry no antibiotic meat. We hold

7 Whole Foods up as a model of providing no

8 antibiotic meats to people. 

9 So we think that that is one rung

10 up on the sustainability chain. We say

11 organic gets you a few more rungs up on that

12 chain. And then there's other things, like

13 animal welfare-approved when you add on to

14 that that does even more. 

15 And so there's a sustainability

16 continuum. The lack of using antibiotics, at

17 this point in animal production, is now

18 considered the first step up but an incredibly

19 important one.

20 I also want to say that you're

21 going to hear from three physicians over the

22 next 24 hours who are going to speak to the
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1 incredible public health threat of antibiotic

2 resistance. It's not about using little bits

3 or comparing that to a lot. Little bits of

4 antibiotic in the environment do create

5 resistance, and you're going to hear from a

6 physician that's working with us at Consumers

7 Union, Dr. Michael Crupain. You've already

8 heard in written testimony from Dr. Bob

9 Lawrence at the Johns Hopkins Center for a

10 Livable Future where Michael teaches classes

11 with him on antibiotic resistance. And you're

12 also going to hear from the Infectious Disease

13 Society from Dr. Morris tomorrow who will also

14 be speaking to this issue.

15 So the public health problems are

16 real. They're scientifically-based. We are

17 concerned about them from a public health

18 community, not just scientists but also

19 medical professionals, as well. 

20 CHAIRPERSON STONE: Tracy? 

21 MEMBER FAVRE: You've talked about

22 this survey a couple of times, and you
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1 mentioned just a moment ago that it's a very

2 narrow sliver that you're looking at about the

3 antibiotic use in apples and pears. I'm

4 curious, I think most of us know that the

5 design of the questions used in the survey

6 have a lot to do with the response that is

7 elicited. So my question is do you believe

8 that consumers understand that, potentially,

9 with a decision to remove the antibiotics, we

10 might be looking at the loss of organic apples

11 and pears in this country so we're faced with

12 either eating conventional apples and pears or

13 getting them imported from other countries who

14 may or may not have the same stringent

15 evaluation? So do they really understand the

16 potential for that if they want to continue to

17 consume those products? 

18 MS. RANGAN: Yes. We worked

19 pretty extensively with our survey department

20 to actually structure these questions in a way

21 where we could provide enough information and

22 then give them the factual information because
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1 we didn't want this to be an esoteric

2 question. And so, you know, gauging whether

3 they know or not about the practice was

4 important for us because that's been the

5 subject of some debate here over the last few

6 years. Some people say consumers know about

7 it, they don't care, they're paying for it, it

8 doesn't matter.

9 But what we know from this poll

10 data is that consumers don't know. They

11 actually don't know the practice is going on. 

12 So now, in a survey, once you get a response

13 like that that you don't know, then you have

14 to provide them the information of what the

15 fact is.

16 And then our next question was

17 really do you think an organic label then

18 should be used on those apples and pears? And

19 it's only ten percent that say yes. The rest

20 either don't know or more than half say no. 

21 That's a pretty definitive answer. 

22 And, you know, I think, from a
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1 consumer point of view, why this product gets

2 antibiotics, why dairy never does, consumers

3 have come to expect that this is a practice

4 not used here. And the fact of the matter is

5 that alternatives are being developed, and

6 there are some producers who aren't using it. 

7 And we think the market should reward those

8 people who can truly differentiate themselves

9 as meeting the gold standard here.

10 And the problem here is that

11 there's no way for them to do that. There's

12 absolutely no way. The organic label doesn't

13 distinguish them as actually meeting a

14 standard that they have come to expect from

15 all other organic products that they buy, and

16 that's a problem. And we think there may be

17 some market depression, but there will be a

18 supply that comes in that meets that standard. 

19 That is how our market works. And we don't

20 think, by simply saying we need to keep the

21 acreage, we need to keep the subpar products

22 on the market, that that is a reason to
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1 continue to do it year after year after year. 

2 We're in year 17 or 18 of this listing. It is

3 time to retire it, and that's what we think

4 needs to be done. And we're really looking

5 forward to the alternatives coming onto the

6 market. And at the very least, we need to

7 have a transparent system where consumers can

8 know. And we had a really interesting

9 discussion yesterday with the folks in, I

10 believe it was Washington State University,

11 I'm sorry, Washington State Department of Ag

12 who were actually saying on the certificate

13 they are noting whether they're certifying a

14 block in an orchard, they do it by variety,

15 that didn't use antibiotics.

16 So is there a way now to start

17 differentiating? Is there a way to say, no,

18 these apples didn't get antibiotics, these

19 ones did? Because, frankly, this is where

20 consumers are completely in the dark, and

21 that's not fair, and that's not fair to the

22 market. We need full transparency here
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1 because we don't want this label to be

2 undermined. And when consumers are in the

3 dark and feel sort of cheated and they learn

4 about these things, that's when the serious

5 undermining of the label actually happens from

6 a consumer confidence point of view. 

7 So we think it is time to

8 recognize what those expectations are and at

9 least make it transparent to consumers and

10 provide a way for growers who are truly

11 meeting the gold standard to be able to

12 differentiate their product as that.

13 CHAIRPERSON STONE: Harold?

14 MEMBER AUSTIN: In your expert

15 opinion, in terms of the potential to induce

16 resistance in the environment, is there a

17 difference between the various antibiotics

18 that are currently being used? And if so, is

19 there an impact on where and how those are

20 used? 

21 MS. RANGAN: Yes, it doesn't

22 really matter. I mean, there are a number of
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1 different antibiotic classes, and they have a

2 number of antibiotics within each class. 

3 Streptomycin and tetracycline are both broad4 spectrum, medically-important human

5 antibiotics. So as an antibiotic goes for

6 using it in agriculture, that's a pretty

7 serious decision to use a drug that is

8 critically important in human medicine.

9 Now, when bugs get resistance to

10 these things -- and, remember, you use, when

11 we treat sick people, you want to use

12 pharmacologically-relevant doses that are

13 going to kill that bacteria. When you use low

14 levels in the environment, it's like a perfect

15 recipe for creating resistance in the

16 environment. The bacteria sort of gets pinged

17 with these things, and then it learns how to

18 mutate and, essentially, resist it. And then

19 what happens is those bacteria can pass along

20 that resistance to other related bacteria. 

21 They can also, in that genetic resistance

22 pattern, transfer resistance among that class
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1 of antibiotic. And in some cases, in certain

2 antibiotics, you can hop classes. 

3 The point is really that

4 resistance isn't contained. It isn't just

5 based on the little amount you think you might

6 be using. Once you put that resistance into

7 the environment, into a bacterial gene, you're

8 sending it through. You have a live bacteria

9 now that can, indeed, grow and spread its

10 resistance over time, not only to the fire

11 blight organisms but any of those related

12 organisms that are in the orchard. And there

13 are studies to document that.

14 CHAIRPERSON STONE: Nick? 

15 MEMBER MARAVELL: Yes, Urvashi. 

16 We've heard some discussion of antibiotics use

17 in livestock and then distinctions made with

18 regard to the amount and frequency of

19 antibiotics used in tree fruit. And then

20 we've heard various suggestions as to what

21 should be a phase-out date. I was wondering

22 if you could comment, just from your
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1 perspective, on your distinctions between

2 livestock use and tree fruit use and your

3 sense of urgency to phase this product out,

4 specifically with regard to tree fruits? 

5 MS. RANGAN: Sure. Thanks, Nick. 

6 I think there's a misnomer that somehow,

7 because less antibiotics are used in apples

8 and pears compared to livestock, it is,

9 therefore, less of a problem. That simply

10 doesn't hold scientific water. The fact of

11 the matter is that wherever you put

12 antibiotics into the environment, you start to

13 create and exacerbate the resistance. I mean,

14 resistance is there, naturally. But you will

15 accelerate that resistance wherever you're

16 applying those antibiotics. These are sprayed

17 onto trees, so they're sprayed in the orchard

18 and all the bacteria, which there many of,

19 that sit in the orchard, once that antibiotic

20 hits them, that resistance can take place. 

21 And then that resistance can start to spread

22 and move downstream and do all sorts of
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1 things. That mechanism is in livestock

2 production, but it's not dependent on

3 livestock production. It's because, once the

4 bacteria itself is resistant, that is the

5 problem of antibiotic resistance in the

6 environment.

7 So it's not a matter of quantity

8 of antibiotic used. It's once you start to

9 actually put that into the environment, you

10 start to create the dilemma and the resistance

11 problem. 

12 In terms of phase-out, because I

13 think we have had this on the list for such a

14 long time and we have testified prior to this

15 in the last round it was re-listed that this

16 was not appropriate and that it was time to

17 retire this material. And at the last re18 listing of this material, we were here telling

19 you the same thing, that this really has to

20 stop, this has to be the last listing. And

21 now we're here again having the same

22 discussion. And so for us and for consumers,
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1 we think that the phase-out should happen in

2 2014 and that we should start moving towards

3 those alternatives.

4 In the meantime, whatever your

5 decision is, and between now and 2014, if that

6 is the date that is chosen, we want it to be

7 very transparent to consumers that this is

8 going on. And we think, frankly, if the OTA

9 and the industry is saying we all agree that

10 we want to get rid of this, take a pledge, say

11 something, take a position. You guys could

12 write a policy. Let's anchor that down

13 because consumers need to know that, as an

14 organic community, there is commitment to

15 doing away with a practice that they don't

16 want, they don't expect, that has public

17 health ramifications. And I think we need a

18 serious commitment to the closure of this use. 

19 And if it's true in this room that everyone

20 agrees with that, and the question is really

21 on date, then I think that can at least begin

22 a public dialogue showing that there is true
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1 commitment to end this practice. 

2 CHAIRPERSON STONE: Jay, are you

3 going to wrap this up? 

4 MEMBER FELDMAN: Thank you. I'm

5 trying to -- and you addressed this, in part,

6 but I'm trying to ask you to help the Board

7 understand its responsibility in this

8 balancing act. Obviously, everybody sitting

9 around the table here is concerned about

10 impacts on growers. How do we integrate the 

11 concern about consumers, which is a

12 requirement, actually, of the Board, as we

13 balance and calculate this decision? 

14 MS. RANGAN: Well, Jay, you know,

15 on other issues, and it's sort of a similar

16 approach, we look to you all from the public

17 as being guardians of the materials that are

18 allowed and not allowed for use in organic

19 production as a way that maintains the

20 integrity in this program. And we truly

21 believe that your goal is not to maintain

22 acreage, your goals is not to grow it as fast
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1 as possible, the goal is not to approve as

2 many materials as possible at all times. The

3 goal is actually to maintain the high

4 integrity of the meaning of these standards, 

5 and welcome aboard if you can meet that.

6 But the goal is not to somehow

7 create a lopsided standard that then creates

8 an exception for certain products but not for

9 other products because that is very negatively

10 perceived. And part of the goal of the

11 Organic Food Production Act was to impart

12 consistency in this label. And so

13 consistency, high integrity, and quality

14 improvements over time, that's your goal. 

15 And this is a slippery slope,

16 isn't it? I mean, peaches and nectarines,

17 from what I understand, are also, in

18 conventional agriculture, use streptomycin and

19 tetracycline. They don't in organic. So I

20 don't see any organic peach and nectarine

21 growers here, but they're not allowed to use

22 it either. 
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1 And so, really, this is about

2 leveling the playing field. And if we don't

3 have a certain product on the market because

4 they can't get to that standard quite yet,

5 that's okay. And we're having this whole

6 debate in fish, aren't we? I mean, whether

7 it's the fish meal in the open net pins or

8 even antibiotic use in aquaculture. We're

9 going to get into that. We don't want to see

10 this slippery slope of allowing something that

11 is really incongruent with the organic program

12 and doesn't comport with consumer expectations

13 to then start bleeding into other areas, and

14 we think it is the job of this board to

15 maintain that. 

16 CHAIRPERSON STONE: Thank you very

17 much. 

18 MS. RANGAN: Thank you. 

19 CHAIRPERSON STONE: So I let us

20 run on that one, but just remember we may not

21 have this luxury tomorrow. So, Jo Ann, you're

22 up, and Lisa Bunin is on deck. 
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1 MS. BAUMGARTNER: Hello. I'm Jo

2 Ann Baumgartner with the Wild Farm Alliance. 

3 We're based in Watsonville, California. Thank

4 you for the opportunity to share Wild Farm

5 Alliance's comments. As you might imagine,

6 we're pleased that the NOP is pursuing the

7 development of biodiversity guidance. It

8 comes at an important time now that the NOP

9 checklist used to accredit certifiers

10 addresses the Natural Resource Conservation

11 Standard. 

12 To remind you, organic operations

13 must maintain or improve the natural

14 resources, including soil, water, wetlands,

15 woodlands, and wildlife. Biodiversity

16 conservation is part of the definition of

17 organic production. It's in the preamble

18 language, and it's in the crop production

19 standard for perennial systems. Native

20 habitat supports natural enemies of crops and

21 has been estimated to be valued at $100

22 million in a seven-state region of the U.S. 
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1 Moreover, habitat supports

2 pollinators, many of which are in decline. In

3 California alone, researchers have estimated

4 that wild pollinators are worth one to two

5 billion dollars and actually provide a third

6 of the pollenation services for that state.

7 Soil biodiversity is critical for

8 competition, predation, and eventual die-off

9 of foodborne pathogens. Raptors and four10 footed predators help keep rodents in check,

11 which is not only good for yields but also

12 good for food safety. It's better to have a

13 couple of predators in the field than many

14 rodents. 

15 In FDA's proposed produce safety

16 rules, they state that the presence of

17 wildlife, in and of itself, is not a food

18 safety issue. And in five areas of their

19 preamble, they say they do not require farms

20 to take measures to exclude animals or destroy

21 habitat.

22 We are happy to see that the NOP
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1 is working on sound and sensible project in

2 order to make organic certification

3 accessible, attainable, and affordable. With

4 upcoming guidance on biodiversity, we propose

5 that a slate of examples are given to help

6 farmers see how they can shape biodiversity

7 conservation practices to fit their specific

8 situations in an attainable way. And with

9 help from NRCS, installing practices can be

10 affordable for farmers.

11 Wild Farm Alliance, MOSES, and

12 several other sustainable ag groups are

13 assisting NRCS to better serve organic

14 farmers, and it's starting to pay off. 

15 Recently, hundreds of NRCS personnel have

16 participated in our eight webinars, and in

17 Santa Cruz County, where I'm from, the NRCS

18 conservationist says he works now with more

19 organic farmers than conventional farmers.

20 And integrity. Consumers expect

21 organic products to protect the environment. 

22 One of the issues that the guidance needs to
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1 cover is addressing the conversion of high2 value conservation lands, which could give

3 organic a black eye. So by addressing all of

4 biodiversity in the guidance, it will uphold

5 the integrity.

6 Besides guidance, what we need is

7 a concerted effort to train inspectors,

8 certifiers, and operators about biodiversity

9 conservation. Later this year, we'll begin a

10 process working with several partners in hope

11 that, once guidance is out, the NOP, too, will

12 be incorporating this critical issue in their

13 trainings. In regard to the penalty matrix,

14 we're glad that it's back under review because

15 the NOP needs to consistently address the full

16 definition of natural resources in the non17 compliance, not just soil and water. 

18 Now, to the tetracycline used in

19 apple and pear production. It should be

20 phased out in a way that support those farmers

21 that are diligently using antibiotics

22 sparingly while fostering biodiverse vibrant
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1 soils that produce healthy trees, versus those

2 who schedule sprays based on the calendar and

3 don't take a holistic approach to plant

4 nutrition. The spread of antibiotic

5 resistance is troubling. We don't understand

6 all the consequences to the environment and

7 human health.

8 Sulfuric acid. It's very toxic,

9 and it should not be allowed in organic

10 production.

11 IBA. Since we don't know what the

12 environmental effects of it are, the

13 precautionary principles should be used. 

14 Finally -- okay. Thank you. 

15 CHAIRPERSON STONE: Thank you, Jo

16 Ann. Questions? All right. John? 

17 MEMBER FOSTER: So I thought I

18 heard you say the tetracycline and

19 streptomycin were applied on a calendar basis

20 just now. Where did that come from? Because

21 I haven't heard that up until now. 

22 MS. BAUMGARTNER: Were you on the
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1 tour yesterday? 

2 MEMBER FOSTER: Yes. 

3 MS. BAUMGARTNER: I had heard that

4 that's what one of the farmers had responded

5 when they were asked about the application. 

6 MEMBER FOSTER: Well, the Board

7 can correct me if I'm wrong, but I have no

8 recollection of that. 

9 CHAIRPERSON STONE: Nick? 

10 MEMBER MARAVELL: Yes, I don't

11 know if you were in here, but, basically,

12 there was one orchard that was pretty much

13 practicing three applications of tetracycline,

14 on average. They could go more or less, but

15 it was not indicated that any individual year

16 would be zero and there was some skepticism

17 voiced with regard to the use of the fire

18 blight models for the exact trigger to start

19 that. That's what I heard. 

20 MEMBER FOSTER: That's real

21 different than a calendar basis, to me. 

22 MS. BAUMGARTNER: Okay. 
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1 MEMBER MARAVELL: Yes. Well, I'm

2 not defending the words "calendar basis." 

3 MEMBER THICKE: But it was based

4 upon the bloom stage, per se, without the

5 model or weather conditions. 

6 CHAIRPERSON STONE: Okay. Thank

7 you. Lisa Bunin is up, and Tracy Miedema is

8 on deck. 

9 MS. BUNIN: Good afternoon. My

10 name is Lisa Bunin, and I'm the organic policy

11 director at the Center for Food Safety. CFS

12 oppose extending the use of tetracycline until

13 2016. A growing body of evidence demonstrates

14 the public health threat of antibiotic

15 resistance and warns of the dangers of losing

16 tetracycline considered by the World Health

17 Organization as critically important for

18 combating human infection. This is reason

19 enough to prohibit tetracycline in organic.

20 CFS supports the minority position

21 to maintain the expiration date of 2014

22 because tetracycline used for fire blight
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1 control in organic apple and pear production

2 fails to meet the material review criteria. 

3 What is most concerning about even low-level

4 uses of antibiotics is that their use can

5 contribute to reservoirs of resistance that

6 can spread to other bacteria and human

7 pathogens through horizontal gene transfer.

8 The Board has repeatedly warned

9 growers that antibiotics would not be allowed

10 in organic indefinitely. Growers who sell to

11 the EU have heeded this warning by finding

12 ways to successfully avoid antibiotics,

13 demonstrating that they are not essential.

14 This extension request has sparked

15 public debate about why antibiotics are used

16 in organic in the first place. Over 30,000

17 people signed CFS' petition to end

18 tetracycline use, and many are asking

19 questions about which varieties are likely to

20 be sprayed so they can avoid buying them.

21 CFS urges the NOSB to deny the

22 extension because allowing it could tarnish
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1 both the organic apple and pear industry and

2 the reputation of organic. We further urge

3 the Board to state in its final decision that

4 antibiotics are incompatible with organic. 

5 CFS agrees with the GMO

6 Subcommittee that clarity is needed around the

7 median words used in excluded methods, but we

8 support leaving the definition of excluded

9 methods intact. The regulatory history shows

10 that it was never intended to be rewritten

11 but, rather, it was a benchmark against which

12 new and emerging technologies would be

13 evaluated.

14 CFS believes that the term natural

15 condition and traditional breeding should not

16 be replaced. We urge the NOSB to use guidance

17 and policy statements to clarify the rule,

18 instead of regulations. And we urge the Board

19 to confirm in writing at this meeting so that

20 there's no doubt that excluded methods

21 prohibits genetically-engineered organisms and

22 processes.
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1 Sugar beet production and beet

2 sugar extraction are chemically intensive and

3 environmentally destruction, and the TR makes

4 that clear. Conventionally grown sugar beets

5 use synthetic toxic fertilizers, pesticides,

6 and soil fumigants that harm the environment. 

7 Sugar beets are processed with formaldehyde

8 and generate a large volume of wastewater. 

9 Sugar beet seeds are treated with a

10 neonicotinoid pesticide which threatens bees,

11 beneficial pollinators, and birds. This

12 certainly is not the type of production that

13 organic should support under any

14 circumstances, particularly since viable

15 alternatives are commercially available.

16 To meet OFPA requirements,

17 conventional sugar beet seeds would have to be

18 non-GE and identity preserved. This seems

19 unlikely, particularly since 95 percent of all

20 sugar beets grown in the U.S. are genetically

21 engineered. 

22 While the petitioner is based in
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1 Sweden, granting the petition would open up

2 sugar beet fiber production to all companies,

3 including U.S. producers. We urge you to

4 reject the petition. 

5 Transparency is the bedrock of

6 organic. Consumers buy organic food because

7 they know what's in it and how it is grown. 

8 Yet for innovation to thrive in organic, some

9 limited and prescribed CBI may be necessary. 

10 Some materials ingredients can never be

11 permitted in an organic system, and, for the

12 NOSB to make that determination, all materials

13 and processes must be transparently

14 scrutinized and never be claimed as CBI. CBI

15 may be warranted for protecting formulas,

16 recipes, market research, and financial data,

17 but we oppose allowing the NOSB but not the

18 public to see confidential business

19 information because it could undermine

20 transparent public participation which lies at

21 the core of regulatory development.

22 Other ingredients need to be
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1 reviewed, like all other materials. And CFS

2 supports the recommendation to deny the

3 polyoxin-d zinc salt fungicide petition. 

4 Thank you. 

5 CHAIRPERSON STONE: Very good,

6 Lisa. Questions? Calvin? 

7 MEMBER WALKER: Dr. Bunin, could

8 you share with the Board, as well as the

9 organic stakeholders, how the Center for Food

10 Safety survey was done? I did hear you

11 mention --

12 MS. BUNIN: Oh, the petition? 

13 MEMBER WALKER: -- quite a large

14 number. Yes. 

15 MS. BUNIN: Well, what we do is,

16 in order to get one of our action alerts, you

17 have to sign up. So you either have to go to

18 our website or sign up on a list when we're at

19 a conference. And so then you get your action

20 alert, in this case telling you about how

21 Center for Food Safety viewed the antibiotics

22 issue. You read through our position. We
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1 also have a web link to the MSB website where

2 you can read the background information for

3 yourself. And then if you agree with the

4 petition, then you have to click "take

5 action." If you don't click "take action,"

6 you are not signed up on the petition. And

7 then before we submit the petition signatures

8 to the docket, we have a program that goes

9 through and sweeps to make sure that there are

10 no duplicates on our lists. 

11 CHAIRPERSON STONE: Harold? 

12 MEMBER AUSTIN: Could you clarify

13 for us your position on polyoxin-d zinc salt? 

14 MS. BUNIN: We think that it

15 shouldn't be on the list. 

16 MEMBER AUSTIN: Rational for that?

17 MS. BUNIN: Because it is a

18 fungicide, and it's toxic and it doesn't

19 belong as a material on the list. 

20 CHAIRPERSON STONE: Okay. Thank

21 you, Lisa. Tracy Miedema is up, and Steve

22 Crider is on deck. 
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1 MS. MIEDEMA: Good afternoon,

2 everyone. Welcome to Oregon. I hope you

3 enjoy our majestic state and have a little

4 time to take in some street food while you're

5 here, maybe get up into the mountains. I am

6 here today to urge us to all look at the

7 tetracycline issue from the perspective of

8 consumers who aren't necessarily answering

9 online answering online polls. 

10 My name is Tracy. I'm a mom. I

11 have three kids that are all school lunch box

12 age, and I buy an awful lot of organic apples. 

13 I grew up in Washington state, a great apple

14 growing state, and it's been wonderful. And

15 a person very involved in the organic foods

16 industry for the last 15 years. I work for an

17 organic farm. To have seen organic apples

18 really become a bonafide part of the orchard

19 industry and farming.

20 So two years ago, we were in

21 Seattle, a lot of the people in this room. I

22 broke a gavel at that meeting. And I was, you
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1 know, I heard a lot of information about

2 tetracycline. Some of it that was just, it

3 was just not true. And I heard Urvashi up

4 here. I heard her ask the question of are

5 there antibiotics in the apples, and I didn't

6 feel like we got a straight answer. The

7 answer is almost none and almost never, ever.

8 And here's the thing. 

9 Tetracycline will go away from organic, but

10 two years is just not enough time for

11 alternatives. It's just not enough time. And

12 so the alternative to tetracycline today is

13 conventional apples.

14 I can just barely afford to keep

15 my kids in organic apples. Organic apples are

16 set to become food that only the most elite

17 consumers are allowed to eat. And moms all

18 over just won't be able to put them in lunch

19 boxes anymore. So, you know, just looking at

20 logic, two years is not enough time to do the

21 research. And let's play this through.

22 Last year was the first year that,
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1 potentially, field trials could have gone. 

2 And we had two years, let's just say two years

3 in a lab working on what these alternatives

4 are to combat fire blight. This spring we

5 might have got out into the orchards. We need

6 another year to get into the orchards for

7 trials, minimum. And my family has some

8 involvement in some of these alternatives,

9 works in the wood products industry, and

10 there's some amazingly promising alternatives. 

11 We just don't have enough time to actually do

12 the field trials because this is a crop that

13 we get one shot a year out there to do the

14 testing.

15 So I'm really here today to just

16 urge some balanced thinking and reason around

17 this and give the researchers the time. Don't

18 take the wind out of their sails. And, you

19 know, if tetracycline were to sunset in 2014,

20 as it's set to do, you're going to see

21 orchards go back to conventional. And, you

22 know, it's going to be really disappointing,
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1 and that's where they're going to stay. 

2 So, you know, let's find a way,

3 let's find something that's balanced where the

4 orchardists, the consumers, and the scientists

5 can work together. And what we're heading to

6 is something that's really, that's not

7 balanced. 

8 CHAIRPERSON STONE: Thank you,

9 Tracy. Questions for Tracy? I'll say I have

10 a renewed respect for those that came before

11 me that have to swing this thing around. Zea?

12 MEMBER SONNABEND: Thank you,

13 Tracy. Have you talked to other moms and

14 other consumers about the issue? And do you

15 think they're capable of understanding it and

16 tend to agree with your or not? 

17 MS. MIEDEMA: You know, I manned

18 the phones and talk to organic consumers

19 everyday for about six years and realized, you

20 know, the people in this room are probably the

21 most educated people in organic on the planet. 

22 It's like a brain trust in this room, and we
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1 know a lot. If the study had been fielded

2 that, you know, Consumers Union, I believe,

3 fielded it, asked the same question about a

4 multitude of materials that are on the

5 National List today. There are multisyllabic. 

6 They're hard to pronounce. I think we would

7 have gotten a wholesale rejection of a large

8 swatch of the National List. I think we can

9 manipulate consumers into being scared through

10 surveys like that. 

11 No, Zea, I haven't gone out and

12 fielded a study. I really come at this from

13 a personal experience and as an insider that

14 knows those details and is thrilled to be able

15 to provide that kind of wholesome food.

16 And I will say one last thing,

17 which is the characterization of the sunset

18 process as a retirement process is not the

19 congressional mandate here. It's to review,

20 not to retire. And nowhere in the OFPA or in

21 the regulation does it say the list should

22 only be six inches long or X number of digits. 
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1 And so we're starting to promulgate that as if

2 it were true that the sunset equals

3 retirement. It's just not true. 

4 So don't let that, you know,

5 vernacular start to work its way in. It will

6 cause you to think something that's not true

7 about the sunset process, which is to review

8 any new information that's come to light. 

9 CHAIRPERSON STONE: Harold? 

10 MEMBER AUSTIN: Tracy, thanks for

11 coming today. As a mom with kids that you

12 firmly believe in organic and what it stands

13 for, the principles, we hear and we've heard

14 ever since Seattle that some of the

15 alternatives would be to change varieties, go

16 back to those less resistant. As a consumer

17 and as a mom, what dictates the choice of the

18 fruit or the apples that you, as a consumer,

19 a mom, would buy and what would your kids

20 prefer to eat varietal wise? 

21 MS. MIEDEMA: Well, you know, I

22 grew up in the sad era of the Red Delicious,
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1 knocking around, pithy, mushy. I didn't even

2 know what a good apple tasted like from a

3 store, you know. There were orchards around

4 my house. I grew up here in the Pacific

5 Northwest. We canned food in the summertime,

6 and it was really, you know, it was quite

7 wonderful. However, the grocery store was not

8 a place where you found a decent apple. And

9 the same apple gets put back in the lunch box

10 the next day, just more bruised than the day

11 before, because the kids don't eat.

12 So what dictates, you know, it

13 needs to be tasty. It needs to be wholesome

14 and crunchy and all the wonderful things that

15 the apple growers have done to actually bring

16 apples back to life. And, you know, it just

17 would be a crying shame that, in this room

18 today, we could set back what's going on with

19 organic apples and the inroads that organic

20 has made and reintroduce pesticides onto

21 thousands and thousands of acres.

22 CHAIRPERSON STONE: Jean? 
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1 MEMBER RICHARDSON: So I'm one of

2 those consumer reps on the Board that is

3 trying to understand consumer perception and

4 concerns. So I'd like to try to understand

5 how you made your decision that you would

6 rather be feeding an apple to your kids that

7 may potentially have a detectable amount of

8 tetracycline antibiotic in it. I'm not saying

9 it does or doesn't, but it may. Balanced off

10 against the -- did you do it by balancing off

11 the risks of all the other things that are in

12 the conventional apple or pear by comparison? 

13 So did you look at sort of risk versus risk

14 when you made the decision to, and came here,

15 of course, obviously, to say I'd rather stay

16 with the, for the next couple of years anyway,

17 the pear that had been treated or the apple

18 that had been treated with antibiotic? 

19 MS. MIEDEMA: You know, just,

20 again, speaking as a mother, I didn't weigh

21 any of those things, Jean. I would say I'm

22 coming at it much more from the avoidance of
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1 the pesticides. And I have tremendous faith

2 in organic apples and quite unquestioned the

3 notion that there is some residual

4 oxytetracycline from a blossom spray. It's

5 more likely somebody handling it, you know,

6 and not having it have been washed. A

7 pathogen from a hand would make me a lot more

8 nervous than a potential diluted

9 oxytetracycline spray six months before the

10 fruit came to market. 

11 I don't know that any moms are

12 kind of thinking that way. You go in and

13 there's certain mandates now for organic

14 consumers where we've decided we're going to

15 get as much organic, we're going to buy

16 organic milk. Even if times are tight, we're

17 going to buy organic milk. We're going to buy

18 organic apples. When we can, we're going to

19 buy the meats and the breads and the other

20 groceries. But apples, you know, they're an

21 iconic organic item now. Please, let's keep

22 it here to stay. 
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1 CHAIRPERSON STONE: Thank you very

2 much, Tracy. 

3 MS. MIEDEMA: Thank you. 

4 CHAIRPERSON STONE: Next up is

5 Steve Crider with Brady Jacobson on deck.

6 MR. CRIDER: Yes, I'm Steve Crider

7 with Amy's Kitchen. We're a large organic

8 food company based in California and here in

9 Oregon. My comments today may not rise to the

10 same level of controversy as tetracycline, but

11 I'm here to speak on behalf of our company

12 with regards to silicon dioxide, which is

13 currently allowed as a synthetic under

14 205.605. And we appreciate the opportunity to

15 address the Board.

16 Extensive detail and technical

17 background have been submitted by our team in

18 our written statement regarding our concerns

19 with the commercial availability and the

20 sensory issues around silicon dioxide

21 alternatives. But we have one other issue

22 that we wish to raise in our oral comments.
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1 At Amy's Kitchen, we use a large

2 amount of rice in our frozen meals, our soups,

3 in our gluten-free line. And we go to

4 extraordinary lengths to protect our product

5 quality, flavor, integrity, and safety. Our

6 brand is found nationally at all levels of

7 retail distribution.

8 Therefore, when news events occur,

9 such as the article by our friends at Consumer

10 Reports highlighting detectable levels of

11 heavy metal arsenic in the U.S. rice products,

12 we receive an enormous response from concerned

13 consumers regarding our products. What is the

14 truth of the matter? Are they safe for us to

15 eat? What risk are we taking in buying Amy's

16 foods? What steps are we taking as a company

17 to assure that the food we produce is a safe

18 as possible?

19 At Amy's, we've been investigating

20 this matter, working with others in the

21 industry, like Lundberg Family Farms, UNFI,

22 the OTA Research Group on arsenic, to better
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1 understand this phenomenon and how it might

2 best be prevented or mitigated. In the course

3 of this study, it has come to our attention

4 that rice will uptake and retain detectable

5 traces of arsenic which tend to concentrate in

6 the hulls at levels at up to 1,000 parts per

7 billion. Much more study is needed on this

8 question, but it raises serious concerns for

9 us. 

10 We currently use spices with

11 silicon dioxide added to keep them free12 flowing. This substance, though synthetic, is

13 neutral, safe, and with proven functionality. 

14 It's approved for use in certified organic

15 food system plans throughout North America,

16 Europe, Japan, Asia, all of which are

17 important export markets for Amy's products.

18 We would find it extremely

19 difficult to justify substituting silicon

20 dioxide, something that we know now could add

21 incrementally to possible detectable arsenic

22 levels in our finished product. This flies in
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1 the face of the expectations of our large

2 consumer base, who we hear from daily via

3 email and social media. And it places us at

4 increased risk in the marketplace. It also

5 raises serious ethical concerns within the

6 company with our production team.

7 Amy's Kitchen strongly encourages

8 the continued use of silicon dioxide as an

9 improved synthetic while further study of

10 potential alternatives are thoroughly

11 investigated and researched. As outlined in

12 our written comments, it would take Amy's

13 around three or four years for a thorough test

14 of any reformulation of a substitute product

15 for its effect on shelf life, both in storage

16 and in our finished products.

17 So we thank you for this chance to

18 comment on this substance and look forward to

19 the rest of the week with you. Thank you. 

20 CHAIRPERSON STONE: Great. Thank

21 you, Steve. Questions? All right. Thank

22 you, Steve. Brady Jacobson is up, and Ib
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1 Hagsten is on deck.

2 MR. JACOBSON: Hello. My name is

3 Brady Jacobson, and I am not the enemy. My

4 husband, John, and I are co-owners of Mt. Hood

5 Organic Farms, which is located in the Hood

6 River Valley of Oregon. Our area is

7 responsible for growing about 30 percent of

8 the winter pears in this country. I'm here

9 today representing the interests of the Hood

10 River Valley commercial organic growers.

11 This issue of the use of

12 antibiotics for control of fire blight is of

13 upmost importance to organic tree fruit

14 growers of apples and especially of pears. 

15 There is still no acceptable substitute for

16 antibiotics for fire blight control available

17 for commercial organic growers. I know that

18 researchers are working on other biological

19 control options, but they are not thoroughly

20 tested and proven under the variable and

21 extreme conditions that kill orchards and will

22 not be ready by 2014. 
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1 What I do know is that there's

2 been an orchestrated campaign of fear by

3 certain seemingly well-meaning organizations

4 timed to coincide with this meeting that have

5 distorted and misrepresented this subject, and

6 this I find extremely disappointing. The

7 message has gone out and gone viral that

8 antibiotics are sprayed on the fruit and that,

9 by eating organic apples and pears, you're

10 being exposed to antibiotics. I have

11 personally responded to a number of the blogs

12 and Facebook posts, as well as to many of our

13 wholesale customers who are being barraged

14 with inquiries about this issue.

15 While I understand that the phase16 out of antibiotics for organic orchardists is

17 inevitable, the science of this subject is a

18 difficult one to understand. The loss of

19 tetracycline will put organic orchardists in

20 a very precarious position, both in the

21 marketplace and in the continuing existence of

22 our orchards. My hope is to convey to you,
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1 the NOSB, the ones who really count in this

2 debate and who are under tremendous pressure

3 by ill-informed consumers and the media, the

4 importance of staying the course with this

5 until there's an acceptable substitute that is

6 generally agreed to be so and is tested by the

7 industry. 

8 Our orchard, Mt. Hood Organic

9 Farms, was the first commercial orchard

10 certified organic in Oregon in 1989 and,

11 certainly, pre-dated the NOP. We grow eight

12 varieties of pears and 26 apples. Tree fruits

13 are a specialty crop, and orchardists receive

14 no subsidies. Profit margins are very slim,

15 which makes things all the more difficult for

16 the smaller growers. But it's the small to

17 medium-sized growers who aren't independently

18 wealthy who will be hurt the most by this ban

19 of antibiotics. It's just that in some cases,

20 in extreme fire blight conditions, when you

21 know that you don't have a good tool like

22 tetracycline, which is 85 to 90 percent
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1 effective if used properly, that you stand to

2 lose parts or all of your orchard. There's

3 absolutely no fairness or common sense in this

4 approach. Also, the fact that fire blight is

5 the disease issue that is unique in its

6 circumstances and it affects a specialty crop

7 but a crop that takes many years and many

8 thousands of dollars to bring to production. 

9 In 31 years, we've probably used

10 antibiotics six times and never on the whole

11 orchard because you spray according to models

12 of open bloom, temperatures, and moisture. 

13 All of the orchardists that I'm representing

14 today follow this protocol of antibiotics as

15 the tool of last resort to protect the life of

16 our trees. I can't convey this message

17 strongly enough. There are no fire blight

18 resistant pears, and most of the interesting

19 and good-tasting apple cultivars are also

20 prone to fire blight. So the proposed

21 solution to planting different varieties, as

22 if it were as easy as changing your boots, is
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1 no solution at all. 

2 Thank you for your time and for

3 listening with an open heart and mind to a

4 passionate, long-time organic farmer and all

5 the other farmers I represent. Thank you. 

6 CHAIRPERSON STONE: Thanks, Brady. 

7 Jean, question? 

8 MEMBER RICHARDSON: Brady, first,

9 thank you very much for visiting your farm

10 yesterday. That was really interesting.

11 MR. JACOBSON: Well, that wasn't

12 my farm, Jean. 

13 MEMBER RICHARDSON: Well, all the

14 ones that we went to and you were there. We

15 really appreciated that. We learned a great

16 deal. 

17 MR. JACOBSON: Thank you. 

18 MEMBER RICHARDSON: In your

19 orchards, have you tried the Blossom Protect

20 that came out last year, 2012? And if you

21 haven't or if you have, will you be using it

22 or trying it this year as an alternative to
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1 using the tetracycline? 

2 MR. JACOBSON: Well, the Blossom

3 Protect is something that I understand you

4 need to spray multiple times. To my mind,

5 since we have had a devastating episode of

6 fire blight back when we were naive enough in

7 1990 that we did not use any antibiotics and

8 lost almost 25 percent of our pear orchard, I

9 don't think that it's worth the risk. It

10 isn't proven. And when you have had such a

11 devastating loss, you don't want to go with

12 something until it's been widely tested in

13 field trials under all circumstances. 

14 And every year is not a fire

15 blight year. As I said, we've used it

16 probably six times. We wait and we watch and

17 we hope that we never have to use it. But

18 knowing that it's something that actually --

19 it's like killing your children, watching your

20 children die. I can't even tell you how

21 devastating it is to have -- it takes 12 years

22 to bring pear trees into production. Twelve
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1 years. It's not like some annual row crop. 

2 When you plant those trees and you watch and

3 you spend thousands of dollars and so many

4 hours of time, and then you lose those trees

5 because you don't have an adequate tool or

6 you're naive enough to think that you don't

7 have to spray something like an antibiotic. 

8 I hope and pray that something

9 like Blossom Protect or some of the other

10 products that are being tested right now will

11 become an adequate substitute. But they need

12 to be tested in field trials on orchards other

13 than people that stand to lose everything. 

14 CHAIRPERSON STONE: Harold?

15 MEMBER AUSTIN: Hi, Brady. Six

16 applications, six times you've used it in 31

17 years. When you get to that point in time

18 when you make that determination that you are

19 going to have to use antibiotic or something

20 for fire blight control, what criteria are you

21 using in the field to help you make that

22 determination? 
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1 MR. JACOBSON: Well, when we

2 started growing organically, there were no

3 Cougar Blight programs. There were no

4 computers in general usage. And so there was

5 the, you get out and you add all the degree

6 days, the highs, the lows. You look at the

7 models. Maybe you all know by now that it's

8 a combination of moisture, vectors, and

9 temperature that create the disease. And so

10 in the old days, we added the numbers, and now

11 we look to the Cougar Blight model. There are

12 weather stations throughout our valley. 

13 People are fairly sophisticated now about

14 this. People are also well educated about the

15 overuse of antibiotics. 

16 And so we do work with field men

17 and they do tell us, and, you know, it's like

18 the forest fire danger exactly. It goes from

19 low to moderate and then you hope that it

20 never goes to severe. If it goes to severe

21 and they're telling me it's severe, then I

22 would have to spray.
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1 Fortunately, we haven't had that

2 many times. As I said, we've probably sprayed

3 six times in all of those years. So it is our

4 tool of last resort. 

5 We have done anything and

6 everything that you could imagine as good

7 husbands of the soil and our farm to create

8 biodiversity, to create the kind of

9 environment in our soil that actually produces

10 natural disease-reducing antibiotics produced

11 by the soil. We hope that those bacteria are

12 not out there, and I can't imagine that the

13 usage of tetracycline that I have seen and

14 know that my fellow orchardists, the models

15 that they follow, are going to create any kind

16 of major problem to the health of the consumer

17 or the health of the environment. And I'm

18 standing here as a very longtime staunch

19 environmentalist when I say that. I've built

20 and staked my life on this so -- 

21 MEMBER AUSTIN: One more question. 

22 You mentioned the field men.
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1 MR. JACOBSON: Yes.

2 MEMBER AUSTIN: Could you explain

3 to us the role that the field man plays in

4 your operation, as far as do you receive a

5 written recommendation from the certified crop

6 consultant to make an application?

7 MR. JACOBSON: Do I get a good

8 recommendation from them? Are they people

9 that I trust?

10 MEMBER AUSTIN: Well, do you work

11 with a licensed crop consultant, and is your

12 spray program based off of a written

13 recommendation from a certified crop

14 consultant?

15 MR. JACOBSON: I don't know that

16 we actually have a certified crop consultant

17 that you may be describing in our area. The

18 field men are usually the agricultural field

19 men associated with the, they're the ones that

20 actually sell the chemicals. When we first

21 started in this business, we sought out field

22 men that could help us because nobody knew. 
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1 The research was not there. We had been

2 guinea pigs. We actually had the first

3 pheromone trials ever in existence, happened

4 on our farm. 

5 So we've been kind of guinea pigs

6 for this. We've built up a lot of information

7 over the years. So I almost know, without

8 anybody telling me, without looking at a

9 computer model, when I'm going to need to

10 spray for fire blight. 

11 So when my field man calls me up

12 and says, "I guess you know that there's a

13 severe fire blight infection happening," I

14 already know that. So there is not, to my

15 knowledge, a certified crop consultant that

16 runs around our valley.

17 CHAIRPERSON STONE: Nick? 

18 MEMBER MARAVELL: Yes. We

19 appreciate you going with us yesterday on our

20 field visits. You've been at this a long time

21 and have been a pioneer in the field. Could

22 you give us just a few little details about
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1 what you've discovered along the way in trying

2 to manage your orchard so that fire blight

3 would not be a devastating occurrence? And

4 where do you see, where do you see the future

5 of this going, particularly with regard to

6 pear production, which we understand is

7 different in terms of its innate ability to

8 resist the fire blight? 

9 MR. JACOBSON: Well, there's all

10 these things that you balance, being an

11 orchardist. Economics is, unfortunately, a

12 really important part of that. So we've tried

13 and done a little bit of everything over the

14 years. We, at one time, had 150 acres of

15 high-density organic orchard. We took a

16 century-old farm, and, when we came, we

17 followed European models. We planted high18 density orchards. They were only doing it at

19 that point. There were a couple of people in

20 Washington state that were doing it. We

21 actually got bud wood from this fellow. His

22 name is Grady Auvil in Washington who
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1 introduced Gala apples in this country. We

2 actually grew the first commercial Gala apples

3 in the state of Oregon. We're now taking out

4 a lot of our Gala apples because they've

5 become a commodity. It's not because they're

6 prone to fire blight. It's because they've

7 become a commodity item, and they aren't worth

8 as much money. So that's part of the reality

9 of being an orchardist. You have to make

10 money to stay alive. 

11 So as beautiful as our farm is,

12 the land use laws in the state of Oregon are

13 extremely restrictive. If you live on

14 farmland, you grow farm crops. That's kind of

15 the way it works.

16 So we have gone to high-density

17 blocks on dwarfing rootstocks for a number of

18 reasons. I actually think that the airflow is

19 actually -- and we have, we're on a slope, so

20 we have a great sight. We get a lot of air

21 drainage, natural air drainage, which makes

22 us, in theory, relatively frost-free, although
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1 the frost fans were going this morning, which

2 reminded me of the difficulties of being an

3 orchardist when you have one shot at a crop. 

4 Fortunately, we're not yet quite in bloom.

5 But we've gone with high density

6 because that's the quickest way to actually

7 get your money back. It also reduces the

8 volume of spray that you use, and we found

9 that early on. It's also a better usage of

10 the land. We have 200 acres, and of that,

11 now, we've downsized. We have about 50 acres

12 of that of orchard, and so we have huge pools

13 of biodiversity on our property. We have

14 ponds and lakes, insectaries. I planted wild

15 flowers all throughout the property. The

16 central core of our property is all open

17 space, gardens, lawns. We also pack and ship

18 all our own fruit. So we're kind of

19 vertically integrated. We were actually

20 forced to do that because there was nobody

21 packing organic fruit. We naively came and

22 said we're here, we're going to grow
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1 organically, but then nobody would pack our

2 fruit. So we actually spun off a number of

3 marketing companies. There was no

4 distribution system set up. You know, this

5 was kind of back in the beginning stages.

6 So we have gone with varieties now

7 that are more heirloom varieties. It doesn't

8 mean that they are not prone to fire blight. 

9 That's the unfortunate thing. So we've gone

10 with things that I think that the consumers

11 are much more interested in, and we also sell

12 directly to the public. We wholesale. We're

13 big enough that we wholesale and always have. 

14 But we also go to farmers' markets. We have

15 people come directly to our farm to buy our

16 fruit. We have worked at all the major

17 markets sampling apples and pears. We have

18 our finger on the pulse of the consumers. 

19 So as I said, we now have eight

20 varieties of pears. We have 26 varieties of

21 apples that we've planted. For labor shortage

22 reasons, for ease of picking, and for reduced
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1 spray volume, for light penetration, and for

2 the fact that there are no true dwarfing

3 rootstocks for pears, so it takes a long time,

4 a much longer time for pears to come to

5 production than it does for apples. Apples

6 are more precocious on the dwarfing rootstocks

7 and maybe it takes five years before you can

8 start to pick some fruit for sale. 

9 Pears is a different story. But

10 with apples still you have to imagine that it

11 takes a long time to not only grow them, to

12 pay yourself back. If you're talking about

13 starting to introduce varieties into the

14 public sphere for consumers, it takes years

15 and years and millions of dollars, campaigns

16 to actually make consumers want to buy certain

17 items. But from my knowledge, the consumers

18 really love what we grow. And we have Cox's

19 Orange Pippin, Ashmead's Kernel, Newtown

20 Pippin, these are ancient varieties, as well

21 as we have Swiss Gourmets, Rubinettes. We

22 have Honey Crisp. We have some Galas. We
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1 have Jonagolds. I could go on and on. Sierra

2 Beauties. I mean, 26 varieties. That would

3 test my 65-year-old brain to have to tell you

4 those. 

5 But economics is really important

6 and working with the consumer and giving them

7 what they want is really important, as well. 

8 CHAIRPERSON STONE: Jay? 

9 MEMBER FELDMAN: Hi. Thanks again

10 for joining us yesterday.

11 MR. JACOBSON: You're welcome. 

12 MEMBER FELDMAN: You know, we saw

13 a snapshot yesterday of different growers and

14 practices, perhaps. I'm wondering if you felt

15 we saw the range of variability in terms of

16 management practices that go on or did we see

17 some outliers, or how would you characterize

18 what we experienced yesterday in terms of

19 typical practices? 

20 MR. JACOBSON: Well, I'm glad you

21 asked that. And I have to be really careful

22 as to how I answer that. I was not contacted
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1 about that tour. I had no idea that that was

2 going to happen until two days before the

3 tour. And I was actually gone for three

4 weeks. I don't think anybody tried to contact

5 me. 

6 But when I found out where you all

7 were going, I kind of looked askance at that

8 because I did not think at all that that was

9 representative of our industry. So one of the

10 growers actually, he was certified the year

11 after we were, so he's a longtime grower, as

12 well. But you'll notice that he had about

13 five acres of pears left. They decided, they

14 were struggling to make a living as a pear

15 grower, and they took their orchard out and

16 they planted wine grapes. So that's one of

17 the -- it's almost like that voice doesn't get

18 to be counted because the trees are standard

19 trees. They're old trees, and there's only

20 five acres of them. And I don't think that

21 that's what we're talking about when we're

22 talking about somebody that actually makes
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1 their living as a pear or apple grower.

2 And the third person on the tour,

3 the third group on the tour was a conventional

4 orchard. And I think that our extension

5 agent, who is not particularly well-versed in

6 anything to do with organics, who actually set

7 the tour up or was one of the people that set

8 the tour up, thought maybe that that was a

9 good idea to take you there because that

10 particular orchard, and they have 700 acres of

11 conventional orchard, and, of that, 20 acres

12 are organic. They have had a history of

13 problems with fire blight, and I think, in his

14 mind, he was thinking, well, I should show

15 them what the reality of what fire blight can

16 do. And it is true. They've been devastated

17 by fire blight, and it can do that. The same

18 year that they lost a lot of trees to fire

19 blight was the same year that we lost 25

20 percent of our pears to fire blight. And the

21 world's experts in fire blight convened at our

22 orchards, both of our orchards, talking about
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1 the subject, trying to get more information

2 about the subject. 

3 But what I knew that you were

4 going to pick up on and I already heard that

5 asked was that they said that they had a spray

6 program, that they use antibiotics as part of

7 a spray program. And you notice that their

8 spray person that was talking had been

9 spraying, he had been their guy for 40 years. 

10 So I don't think that they come

11 from my perspective of being organic growers. 

12 They are conventional growers that were trying

13 it organically and had been disappointed

14 because it's so very challenging. And that

15 part, I guess, I wish you would pick up on

16 that it is very challenging. And he said they

17 had, as part of their regular program -- I

18 don't know any other truly dedicated organic

19 orchardists that include that as part of their

20 regular preventative program. 

21 CHAIRPERSON STONE: Thank you very

22 much for your time and your input.
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1 MR. JACOBSON: You're welcome. 

2 Thank you for having me.

3 CHAIRPERSON STONE: Ib Hagsten is

4 up. While Ib is coming up, is Angie Crawford

5 here? Anthony Kritikos? Diane Brighton? 

6 Lisa Stoke? Stoke? Stoke? I got the Lisa

7 part. Dave Murphy? Okay. Ib? 

8 MR. HAGSTEN: Thank you. Good

9 afternoon. My name is Dr. Ib Hagsten. I'm an

10 independent organic inspector and chair of the

11 IOIA Board. IOIA means International Organic

12 Inspectors Association. During the dialogue

13 about sound and sensible organic

14 certification, we have seen NOP focus on

15 improving communication, and thank you, Miles,

16 for coming to our annual meeting.

17 The ACA is focused on reducing

18 paperwork, and we are pleased to learn of some

19 of the changes that are being done by the

20 people behind me. During the focus on making

21 certification simpler for the client and the

22 certifier, there is little mention of
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1 meaningful life for organic inspectors. Let

2 me remind us that the organic inspector is the

3 only onsite, on-the-ground, eyes and ears and

4 nose for the certifier and for the entire

5 verification process.

6 NOP oversees the organic program. 

7 The NOSB makes recommendations to the NOP. 

8 And while I'm here, I want to thank each of

9 you for the often thankless job you do as an

10 NOSB Board member. 

11 The ACA manages the organic client

12 certification, and the organic inspector is

13 expected to visit the operation, observe,

14 verify, collect, and summarize in the shortest

15 possible time. In recent years, inspectors

16 have tooled up to meet new NOP needs, like

17 pasture rule verification, dry matter intake

18 calculations, food safety verification,

19 enhanced mass balance calculations, animal

20 welfare assessments, and now pesticide

21 sampling. Dialogue among inspectors in

22 reference to Sound and Sensible, often we
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1 heard moans relative to the issues that bother

2 well-trained seasoned inspectors who have

3 uniform IOIA training coupled with ample

4 commonsense. Let me share two examples.

5 An inspector sits at a kitchen

6 table to dialogue the review letter. Three of

7 the six minor non-compliance issues are

8 referenced to a missing tag or invoice that

9 happens to apply to three sections in the OSP. 

10 When we allow one missing paper to result in

11 three non-compliances, the farmer gives up,

12 while the inspector is embarrassed on behalf

13 of the ACA.

14 Example two. The inspector opens

15 his clipboard to look at a farm map prior to

16 the farm walk-around. The farmer says,

17 "That's a two-year-old map. I sent a new one

18 this spring." Now we're scrambling. How can

19 we be sure we work off the same page?

20 In summary, please do not forget

21 to consider your inspectors, your on-the22 ground eyes, ears, and nose, when you try to
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1 make organic certification sound and sensible.

2 IOIA-trained inspectors are capable of seeing,

3 hearing, interpreting, evaluating, assessing

4 the OSP, the farm, the livestock, the fields,

5 and the direct and indirect answers and cues

6 received from the operator. However, when the

7 paperwork gets too cumbersome, one, the farmer

8 gives up, and, two, the inspector becomes a

9 paper pusher rather than what was intended: an

10 inspector.

11 Thank you for your consideration

12 of the IOIA inspectors. Thank you. 

13 CHAIRPERSON STONE: Thank you, Ib. 

14 I have a question. So in the vein of sound

15 and sensible, apparently many inspectors use

16 the checklist type of inspection form that

17 somewhat mimics OSP sort of generically. How

18 can inspectors using technology, if you do

19 inspecting as you describe it, visual, that if

20 the inspector sees it, it's the same as seeing

21 it and checking it on a list, so how can we

22 reduce paperwork but ensure, use your skills
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1 as an inspector and convey that back to the

2 certifier? 

3 MR. HAGSTEN: Obviously, we have

4 to write it down. We have to say it. He or

5 she said the following; we can state that. We

6 can write right on the paperwork. And, again,

7 we can say we saw things, we heard things, but

8 just to spend lots of time checking C tags or

9 those type of things. Some of that is work

10 that is just way too tedious that doesn't

11 really serve very much of a purpose. 

12 And, of course, we need to get out

13 and walk around before we start looking at

14 paperwork. How can we verify what the person

15 is doing if we haven't seen the place? Forty16 five minutes in a pickup truck with a guy, go

17 out and checking the fence and checking the

18 fields and digging the heels in the dirt, it's

19 amazing how much you know about him and his

20 operation versus trying to sit at a kitchen

21 table and just flip pages and think that you

22 know what's going on. 
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1 It's a good question, Mac. 

2 Thanks. 

3 CHAIRPERSON STONE: All right. 

4 Thank you very much. Thanks for your time and

5 attention and being here today. 

6 MR. HAGSTEN: Thanks. 

7 CHAIRPERSON STONE: So I think

8 with -- Zea, I'll get you a little warning

9 that we're ahead of schedule. My

10 recommendation would be is if we can take a

11 break now. If you need a few minutes to

12 prepare for the Materials Committee, yes or

13 are we ready to go? So what we have is we're

14 about an hour and a half ahead, even though

15 we're in two and a half hours into public

16 comment time. So let us run a little long. 

17 We had some great resources at the podium.

18 So if we work through the

19 materials in the GMO Committees, as are

20 scheduled this afternoon, then I want to

21 double back and make sure that some of these

22 folks were delayed or got here that were
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1 scheduled for sometime during today. We'll

2 run back through the list and be sure that if

3 anybody had opportunity that they're here, and

4 we'll get them back up to the podium, as they

5 were scheduled.

6 So, Zea, can you -- ready, or do

7 you want to take a break to get ready? Okay,

8 okay. Well, let's take a 15-minute break. 

9 I've got 5:30, but, actually, it's 2:30. So

10 we'll come back at 2:45.

11 (Whereupon, the above-entitled

12 matter went off the record at 2:27 p.m. and

13 resumed at 2:47 p.m.)

14 CHAIRPERSON STONE: Board members,

15 we're going to go back in session. We're

16 taking up the materials. We are ahead of

17 schedule, so we still want to respect that

18 some of those that may have emailed a

19 scheduled time may have planned their schedule

20 very tightly around that. So we want to honor

21 those, and we'll double back and check, even

22 some of those that have scheduled to speak for
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1 materials or GMO. So if we get a little bit

2 out of order, we certainly want to get the

3 feedback from those that are planning to give

4 it to us. 

5 So at this time, I'll turn the

6 microphone over to Zea Sonnabend, the chair of

7 the Materials Committee. 

8 MEMBER SONNABEND: Thank you, Mac. 

9 Okay. We have three things we're going to

10 discuss today. We have the confidential

11 business information and petitions, the

12 limited scope technical reviews, and the

13 definition of production aids. So, first, Jay

14 will talk about the production aids discussion

15 document. We just need a logistical second

16 here. 

17 MEMBER FELDMAN: Thank you, all. 

18 Okay. And thank you for everybody that

19 commented on this discussion document. I'm

20 going to walk you through a PowerPoint here

21 that gives you some of the justification for

22 this, the legal basis for pursuing this issue. 
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1 And then, at the end, I'll summarize the kinds

2 of comments we got. Obviously, being a

3 discussion document, we will take all this

4 information under advisement, and we will make

5 a determination as to whether we need to do

6 anything. And if so, we will come back to the

7 Board and the community with a proposal.

8 Okay. The basis for this and the

9 definition of this as an issue stems from OFPA

10 Section 6517(c)(1)(B)(I), which allows

11 substances to be added to the National List. 

12 And as everybody knows, there are categories

13 of substances, the last one being the section

14 there in bold that says "and production aids,

15 including netting, tree wraps and seals, and

16 set traps to keep barriers, row crops, and

17 equipment cleansers." 

18 So the question is what is,

19 because that's a list of, perhaps, examples,

20 that is a list, and what is the definition? 

21 So the next slide is what is a production aid?

22 The examples in OFPA suggest that
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1 production aids are meant to include materials

2 that have a minimal impact on food, soil, or

3 the ecosystem. A bit of history here. In

4 2005, the NOSB recommended a much broader

5 interpretation that was referred to the NOP

6 for legal interpretation, and nothing has

7 happened since then really. 

8 In 2005, the recommendation read

9 as follows "carriers, stabilizers, adjuvants,

10 fillers, extractants, excipients, solvents,

11 that do have an active function in the

12 formulations of farm production aids, such as

13 fertilizers, soil amendments, compost,

14 inoculents, sanitizers, aquatic plant

15 extracts, and fish emulsions, and active

16 substances used in pest control, disease,

17 weed, insects, nematodes, that do not fit into

18 other OFPA categories."

19 So I think we agree pretty much in

20 the Materials Subcommittee that there is a

21 need for clarity in the NOSB practice. Only

22 one substance, microcrystalline cheesewax for
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1 use in log-grown mushroom production, is

2 listed as a production aid on the National

3 List. However, several items listed as crop

4 or livestock impacts inputs on the National

5 List do not fit into any of the OFPA category,

6 and some recommendations for these materials

7 refer to them as production aids. And, in

8 fact, many of the petitions that are passed

9 from the NOP onto the NOSB for review are

10 identified as production aids.

11 So on this document, we received

12 four comments. Wolf DiMatteo and Associates

13 said that it does not support continued work

14 on such a definition. NOC said, National

15 Organic Coalition said the terms should be

16 strictly limited to physical items with

17 minimal direct interaction with crops and

18 livestock, as well as chemical substances that

19 are used on equipment but not directly on

20 crops or livestock.

21 And then we received comments from

22 Cornucopia and Beyond Pesticides that said
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1 production aids include physical items used in

2 production but not leaving any residues in the

3 aquatic or terrestrial ecosystem and chemical

4 substances used on equipment but not used on

5 crops or livestock. And it also, these two

6 groups also said production aids do not

7 include any substances taken up by plants,

8 chemical substances dispersed into soil,

9 water, air, or plant surfaces. 

10 So there you have it. We didn't

11 get a lot of comments, but I think I captured

12 them all. Thank you. 

13 MEMBER SONNABEND: Thank you, Jay. 

14 So next we'll take up the confidential

15 business information and petitions. This was

16 also a discussion document, and I was the lead

17 person on this. As we stated, this was

18 brought before you because the procedure that

19 we have now has not really served either the

20 petitioner or the NOSB particularly well, and

21 it's also been cumbersome for the Department.

22 The petitioners usually don't
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1 realize what happens to their confidential

2 information or what doesn't happen. And

3 before I was appointed to this board, I found

4 myself in the awkward position of talking to

5 petitioners many times and being the one to

6 tell them that the NOSB themselves hadn't seen

7 their confidential information, which they had

8 just assumed that people would see it before

9 making their decisions.

10 Furthermore, we've been in

11 dialogue with Lisa Brines from the Department

12 who handles the petition process, and she

13 informs us that many people don't even

14 understand the instructions. And so it

15 results in petitions having to be sent back

16 and forth a number of times until they can get

17 the correct format for the confidential

18 business information and address all of the

19 issues that are actually in the guidelines.

20 So we thought, well, we want to

21 start reforming this process. And we realized

22 that, in fact, as Miles mentioned this
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1 morning, that, indeed, the whole petition

2 guidelines and associated parts of the policy

3 manual that govern how petitions are accepted

4 and reviewed and TRs happen probably needs to

5 be revised, and you will see that on our work

6 plan when we get to the last day.

7 So we had put out a proposal, we

8 had worked on a proposal. To make it clear to

9 people in each subset of stakeholders in this,

10 petitioners, the USDA and the TR contractors,

11 the NOSB and the public, all are very clear

12 about what happens, what can be kept

13 confidential and what happens to anything

14 confidential once you submit it. And that

15 ended up in our discussion document as

16 possible recommendation two.

17 Shortly before we were finalizing

18 this, the Department came to us and said,

19 well, why accept CBI at all? And we had, up

20 until that point, just assumed that there was

21 some reason why CBI had to be accepted, but we

22 didn't really know what it was. And so we
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1 thought, well, we might as well ask the public

2 if they, what they think about that. And so

3 that turned out into possible recommendation

4 one, and this turned into a discussion

5 document rather than a recommendation.

6 So we received ten comments on

7 this specifically. Unfortunately, almost none

8 of them were from people who actually had

9 petitioned anything. In a few cases, they

10 were groups who had helped support petitions

11 for things, but especially not crop input

12 petitioners. We didn't hear from any of them.

13 We did, however, have some good

14 insight from the comments into what people

15 would like to see. And I think everyone

16 believed that this is needed. I think that

17 was universal, which was our first question:

18 is there a need to -- oh, let me scroll down

19 here. Well, is there a need to refine the

20 process? That wasn't our first question, but

21 everyone agreed that this is valuable to work

22 on. 
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1 People disagreed about whether CBI

2 should be prohibited categorically or not. 

3 But everyone agreed, as is already the case

4 but not so clearly spelled out, that the

5 actual ingredient that may be contained within

6 a petitioned item cannot be held confidential. 

7 So there's no such thing as confidential main

8 ingredients, other ingredients, et cetera. 

9 The only thing that's confidential at the

10 moment is inerts when they're used with a main

11 ingredient that may be petitioned. And as you

12 all know, we are planning to start the review

13 of inert ingredients. But those are,

14 generally, not submitted with the petitioned

15 item directly.

16 So there was, the main differences

17 in the comments submitted included whether

18 manufacturing processes could be held as

19 confidential or not. And some of the groups

20 think, you know, most of the groups

21 understood, and commenters, understood the

22 reality that a lot of times your manufacturing
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1 process is what's proprietary and not just the

2 formula, which, of course, we would expect

3 could be kept proprietary, but the steps and

4 what order those steps occur might be

5 confidential. And they have the right to this

6 under the trade secrets law, but, in many

7 cases, it doesn't serve us very well if we're

8 trying to make a decision on whether something

9 is synthetic or non-synthetic, agricultural or

10 non-agricultural, and which section of the

11 National List it belongs in.

12 We've also received a number of

13 petitions which had significant CBI in the

14 question about human health effects, and many

15 petitioners, many commenters commented that

16 this should never be allowed. You know, I,

17 personally, when I look at a petition that has

18 that, I will then look to a TR to see if

19 there's public information that would come in

20 about that that would not make the petitioner

21 have to disclosure. But, further, if it's

22 clearly a petition that probably isn't going
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1 anywhere anyway, I'm less inclined to send it

2 back for more work of the petitioner on the

3 human health if there's really other things in

4 the petition that make it clear I would vote

5 against it in the first place. And we will

6 see at least one petition on our agenda in the

7 future that that was the case.

8 So on the issue of whether there

9 could be an affidavit that would alleviate the

10 need for absolutely full disclosure, we had

11 mixed reactions, although nobody was violently

12 against it and the certifiers tended to be the

13 most supportive because they're used to

14 dealing with affidavits in the context of

15 excluded methods and other situations in

16 reviewing certifications. And so the main

17 comment we got on that was the wording had to

18 be really tight so that the affidavit could

19 really mean something because there's no point

20 having a meaningless affidavit.

21 So, you know, people recognize

22 that, some people recognize that, even if they
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1 don't like it, they could see situations in

2 which confidential information is appropriate. 

3 Recipes and formulas is the main one, but,

4 perhaps things like market research data, if

5 a company paid for their own market research

6 and doesn't really want it confidential, or

7 things that directly relate to financial

8 matters of a business are appropriate things

9 for CBI.

10 And then we received a comment

11 from OTA to make sure that the policy would

12 not be applied retroactively to when we adopt

13 it, and I'm sure that will be the case when we

14 do it. It will be only going forward and not

15 backwards.

16 So we received good input, and we

17 are going to take it back to our subcommittee

18 and work further on CBI. And you will be

19 seeing a recommendation from us probably at

20 the next meeting. So thank you. 

21 Next, Jay is up again to discuss

22 limited scope TRs.
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1 MEMBER FELDMAN: Okay. Thank you,

2 Zea. This policy we actually propose as a

3 policy. I think we're going to, for purposes

4 of this meeting, turn this into a discussion

5 document and take back the comments we

6 received and consider reissuing this as a

7 proposal for the next meeting. But I'd like

8 to walk everybody through it just so you know

9 our perspective on this and why we thought we

10 should propose a policy at this time.

11 The current policy on TRs is in

12 the Policy and Procedures Manual, and it

13 allows flexibility in topics, questions

14 considered in a technical review. The NOSB

15 committee assigned for the review must decide

16 whether there's sufficient information to

17 petition. The committee can reasonably

18 research any pending technical information or

19 there is the need to secure a technical review

20 from a third-party expert, and that's where we

21 get the TRs.

22 In addition, when requesting the
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1 assistance of a third-party expert to evaluate

2 a material, a committee must identify the main

3 technical review issues needed to be

4 addressed, including but not limited to all

5 uses of the petition material, all uses beyond

6 what the petitioner has requested, all uses of

7 the petition material in combination with

8 other materials that have already been

9 approved, interactions of the petition

10 material not addressed by the petitioner, all

11 possible manufacturing methods for a petition

12 material, potential effects on public health

13 and biodiversity, environmental risks, and

14 hazards including but not limited to. This is

15 our checklist, essentially.

16 So the purpose of this proposal

17 goes like this: since the three criteria of

18 environmental and health effects, essentiality

19 and compatibility, so it's environmental

20 health effects, essentiality and compatibility

21 with organic production practices, all must be

22 met in order for the material to be listed. 
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1 A full technical review is unnecessary if

2 certain threshold issues are not met. Should

3 those threshold issues not be met,

4 considerable resources of time and money could

5 be saved by conducting a first-stage TR that

6 would be allowed by, that would be followed by

7 a complete TR.

8 Now, you know, this was really

9 viewed, at least initially when we put this

10 together, as something that would create

11 efficiencies and reduce costs associated with

12 these rather expensive technical reviews. The

13 process applies in those cases in which the

14 NOP's review of the petition is unable to

15 assign the substance petitioned for a crop or

16 livestock use to an OFPA category and when the

17 material comes to the NOSB because of a

18 question of its synthetic/non-synthetic

19 classification. 

20 So the proposal was to incorporate

21 into the manual, the PPM, basically, a

22 procedure in which, before requesting a
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1 complete TR, the reviewing subcommittee would

2 receive a more limited review that would

3 answer the questions below, and we put three

4 questions there that would be answered. And

5 the following checklist questions there,

6 number one, two, and three: what categories in

7 OFPA does the substance fall under; number

8 two, describe the most prevalent processes

9 used to manufacture or formulate the processes

10 or the petition substance; number three, is

11 the substance synthetic?

12 And we sort of had unanimous

13 agreement on moving this forward. But then we

14 received ten comments, which suggested we had

15 more work to do on this. So total supporting

16 proposal was four. This is from the public

17 comments. And total opposing the proposal was

18 six. But it's interesting, of all of them,

19 there seemed to be an underlying support for

20 doing something to streamline the process.

21 MOSA supports the proposal as a sound and

22 sensible approach to moderating technical
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1 review work. We agree that checking threshold

2 issues ahead of a more complete technical

3 review is a wise use of time and technical

4 resources. Beyond Pesticides, National

5 Organic Coalition, Cornucopia supported the

6 proposal but thought there was some clarity

7 needed. And OTA said, "While we agree with

8 the intent of the proposal and we believe

9 there may be instances where a limited scope

10 technical review would be useful, we believe

11 the proposal, as written, is too prescriptive 

12 and is unnecessary at this time. We

13 respectfully request that this proposal be

14 withdrawn." We always do what OTA asks us to

15 do, so we've withdrawn the proposal. No,

16 seriously, we agree with that. 

17 And then CCOF said, "We agree with

18 the concept behind this proposal in that some

19 petitioned items do not need to have a full TR

20 for the subcommittee to decide on a course of

21 action. However, the whole petition and TR

22 process in the Policy and Procedures Manual
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1 should be rewritten," which is basically what

2 we're going to do when we bring this back to

3 the subcommittee, "with a step-by-step process

4 with the roles of the NOP and NOSB clearly

5 spelled out in the initial assessment of each

6 petition." 

7 Now, I should note -- that's the

8 last slide -- that NOP, I hope I'm

9 representing this accurately, believes that we

10 already have this authority, that we can ask

11 the contractor to do a limited TR based on the

12 subcommittee's request. And we will do that. 

13 We have done that, actually, in the Crops

14 Subcommittee already. This was really an

15 attempt to codify that process, to put it in

16 our PPM, and to affirm it. So we will do that

17 and bring it back to you all, hopefully, next

18 time as a proposal again. Thank you. 

19 MEMBER SONNABEND: And that's the

20 end of the Materials Subcommittee presentation

21 today. 

22 CHAIRPERSON STONE: Do any of the
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1 Board members want to comment or question on

2 either of those? Okay. 

3 MEMBER FOSTER: It just occurred

4 to me last night when I was thinking about

5 this on the production aids one, kind of the

6 broad description or potential definition of

7 what constitutes a processing aid. And this

8 gets to a question I've wondered for a long

9 time. Where does PVC pipe fit in? Where does

10 hoses fit in, plastic trays for transplants

11 things? And as I was reading those

12 definitions, there's a fair amount of latitude

13 there. And what I would not like to see is

14 needing to petition plastic trays for

15 transplants and hoses and greenhouse film and

16 aluminum or steel or rebar or things that do

17 have contact in a variety of, you know,

18 situations. Historically, like stainless

19 steel, well, it's synthetic. I just want to

20 kind of get that into the discussion at some

21 point because I don't want the definition to

22 be so broad that it immobilizes us as farmers
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1 and handlers and livestock producers. That's

2 all. 

3 MEMBER FELDMAN: Well, the broader

4 the definition, the more materials we can let

5 in. So it is a category, as you know, in

6 OFPA, so the question is does it need to be

7 constrained in any way and, if so, how, you

8 know, so that the Board has the authority to

9 review these materials in that category and

10 knows the sort of range of materials that fit

11 into that category or types of materials or

12 types of interactions with soil and food. So

13 that's what we are struggling with. And, you

14 know, I really do hope if there's more input

15 out there in the community that we could

16 receive that as we take this back to the

17 subcommittee because we really didn't get,

18 like your comment just now, I mean, we need

19 that kind of comment as a part of this

20 discussion. We didn't get a lot of it.

21 CHAIRPERSON STONE: Any other

22 thoughts around any of those material
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1 discussion documents? Okay. Jennifer, a

2 little heads up, depending on if these people

3 are here before they're allotted time, you may

4 start getting ready. Signing up for the

5 materials public comment, we have Carol

6 Boutard. Is Carol here? Craig Baker? And

7 we'll come back at this, at their official

8 scheduled time in case they're local and just

9 dropped the kids off at soccer and they're on

10 their way here. Christine Hall? Anthony

11 Boutard? Peggy Miars? I see Peggy. And

12 Darryl Williams? I saw him here earlier. 

13 Yes, you're on deck, Darryl. 

14 MS. MIARS: Good afternoon. I'm

15 Peggy Miars, executive director of OMRI, the

16 Organic Materials Review Institute. My brief

17 and non-controversial comments today address

18 the proposal for limited scope technical

19 reports, or TRs. And, Jay, I think you must

20 have missed OMRI's comments in your summary,

21 so I'll highlight them here. 

22 We do agree with the intent of the
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1 proposal to allow for limited or reduced scope

2 TRs, and we agree that a recommendation is

3 unnecessary at this time. OMRI currently has

4 a contract with the USDA that authorizes our

5 organization to bid on TRs, as requested, and

6 it does include the fact that TRs may be

7 limited in scope, including initial assessment

8 reports and supplemental reports, as needed. 

9 In addition, the categories in the

10 evaluation question number one of the proposal

11 seem to only address crop and livestock

12 materials, and the Handling Subcommittee may

13 have other questions for limited scope TRs for

14 handling materials. And we do agree that the

15 proposal should be withdrawn until a more

16 comprehensive proposal can be drafted that

17 possibly includes the other issues that are

18 being discussed, such as review of other

19 ingredients and whether to require

20 confidential business information in

21 petitions. 

22 And on the topic of production
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1 aids, since OMRI wasn't mentioned, I want to

2 mention that OMRI did submit comments that

3 included the definitions that we use for both

4 crop and livestock products for production

5 aids. In general, OMRI considers production

6 aids to be substances, rather than devices. 

7 And, therefore, we limit the scope of review

8 for production aids to be those that are

9 generally meant to be applied directly to or

10 come into contact with either directly or

11 indirectly with organic crops, soil, animals,

12 and food. And you can read our written

13 comments for the specific definitions that we

14 provided. 

15 And that's it. And in my

16 remaining time, I want to invite everyone to

17 our reception tomorrow night hosted by OMRI

18 OTA, organically-grown company, and Oregon

19 Tilth. And we're going to start at 5:30 with

20 organic apple and pear tasting so that we can

21 all taste the fruits that have been discussed

22 today, and we'll have more information on that
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1 tomorrow. Thank you. 

2 CHAIRPERSON STONE: Thank you,

3 Peggy. Question, Jay? 

4 MEMBER FELDMAN: Apologies for

5 leaving you guys out. I remember reading

6 those. I don't know how that got left out. 

7 I really apologize. And so we will take those

8 comments back and look at them. I guess I'm

9 trying to figure out, because we do, as a

10 board, have a Policy and Procedures Manual and

11 it does address technical reviews, and, in

12 fact, your contract with NOP should reflect

13 our board policy, to some extent, since it's

14 a materials issue and sort of how we go about

15 the process of conducting materials review. 

16 Is there a problem in memorializing that in

17 our PPM? 

18 MS. MIARS: No, there's not a

19 problem with it. In fact, I think that the

20 NOSB and the NOP should work together to

21 include that information. I'm just saying

22 that the specifics in the proposal are not the
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1 same as what's in the contract. 

2 MEMBER FELDMAN: Okay.

3 MS. MIARS: So you've got more

4 detailed and prescriptive information than

5 what we provided.

6 MEMBER FELDMAN: Right. But do

7 the details in the proposal preclude you

8 carrying out the contract, as you've agreed

9 to, with NOP?

10 MS. MIARS: If it was changed to

11 reflect the proposal? I'd have to go back and

12 look because our proposal -- well, we haven't

13 been awarded a TR at this point. So if we

14 were and if our proposal was based on the

15 information that we had at the time, it might

16 be different based on if we had to put in more

17 hours to answer more questions and do more

18 research and that sort of thing.

19 MEMBER FELDMAN: Right. Since you

20 mentioned that, do you, knowing what you know

21 at this point, do you think that a two-part

22 contract, a two-part process, say two stages
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1 of a process where a committee might ask for

2 a determination or a recommendation or

3 interpretation of synthetic/non-synthetic

4 classification of material assessment, and

5 then you come back with that assessment to the

6 subcommittee and the subcommittee says, well,

7 because it was determined synthetic, we need

8 now a full TR, do you think that will be in

9 the aggregate, a more expensive final document

10 than if we were to do it in one full shot? 

11 MS. MIARS: I would say that it

12 might be slightly more expensive but probably

13 not too much more. As you can imagine, it's

14 easier to do the work all at once, rather than

15 putting it aside and then two months later

16 pick it up and have to work on it again. 

17 MEMBER FELDMAN: Yes, that was my

18 only question. Okay, thank you.

19 CHAIRPERSON STONE: Okay. Other

20 questions for Peggy while we have her? All

21 right. Thank you very much. Appreciate

22 offering the reception tomorrow night. Darryl
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1 is up. 

2 MR. WILLIAMS: Good afternoon. 

3 Darryl Williams with Oregon Tilth. You're

4 invited to our reception tomorrow too. So

5 some of my comments, a couple of them are

6 materials based, others are for the NOP and

7 calculating organic percentages.

8 So the limited scope technical

9 reviews, we concur with OTA and OMRI on the

10 proposal for the process for limited scope

11 technical reviews. 

12 Other ingredients. It's been said

13 that evaluating other ingredients individually

14 will make less work for the NOSB. We do not

15 agree with this statement, as all of the other

16 ingredients accompanying the material on the

17 National List would need to be evaluated one

18 by one separate from the material in question. 

19 This makes more technical reviews and more

20 recommendations for the NOSB to accomplish.

21 The NOSB can evaluate the other

22 ingredients while looking at the general
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1 material, which allows a well-rounded decision

2 to be made without revisiting the original

3 materials' technical review and recommendation

4 the other ingredients reside in. The other

5 ingredients in a material may very well reside

6 and be needed in multiple materials on the

7 National List. So every time a material is

8 added to the National List or reevaluated, the

9 annotation for the other ingredient would need

10 to be changed. This seems to be an arduous

11 task and may not be feasible. 

12 The annotation can hold

13 information as other materials on the National

14 List do to show the allowance of carriers,

15 solvents, preservatives, et cetera, or a list

16 of allowed other ingredients could be listed

17 in the technical review or other location for

18 reference. 

19 Labeling of dietary supplements

20 and body care products. In the marketplace,

21 you can find many organic claims on body care

22 and dietary supplements that are not certified
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1 and, thus, not produced according to the Act. 

2 The lack of scrutiny in the organic labeling

3 of these types of products has been

4 substantiated by the preamble former NOP

5 guidance and various articles. However, it

6 seems as though the ones under scrutiny are

7 the businesses that are certified, as

8 certifiers are looking carefully at the

9 labeling claims in their facilities. 

10 Recently, we were told by the NOP

11 that products of these types can make organic

12 claims, but the organic claim may not modify

13 an agricultural ingredient. So organic

14 multivitamin is okay, where organic

15 multivitamin with herbs is not allowed as a

16 claim because of the word "herbs." 

17 As an organic certifier, we see

18 the way the NOP is looking at these products,

19 but our concern is that not all certifiers

20 have heard this the same way from the NOP. 

21 Because of this, we are asking for guidance

22 from the NOP for labeling of dietary
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1 supplements and personal care products. We

2 see this as not only a way to align

3 certifiers, but it will also alleviate unfair

4 advantages for uncertified manufacturers, as

5 well as increase market surveillance for non6 compliant labeling in the marketplace.

7 We understand that the NOP and the

8 NOSB are currently undertaking numerous

9 guidance documents and has to prioritize the

10 need for each. But we hope that this becomes

11 a priority in the near future.

12 Calculating percentages. Oregon

13 Tilth provided comments on the topic for

14 calculating the percent organic in multi15 ingredient products. Please see our comments

16 for details about the necessary changes or

17 clarifications to that document.

18 Aside from the proposal, we would

19 like to see water be counted towards the

20 organic percentage in ingredients other than

21 those in the FDA standards of identity when

22 they can be supported by sound science. The
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1 FDA standards of identity is a stagnant list

2 in a world of ever-growing ingredients for use

3 in many types of organic products. We see

4 that handlers are utilizing dehydration and

5 concentration of ingredients to save in the

6 transportation costs, ethics behind carbon

7 footprint, and, most importantly, food safety.

8 I have more but --

9 CHAIRPERSON STONE: Thanks,

10 Darryl. Is there questions for Darryl? I've

11 got one. Describe how, and I'm going to the

12 other ingredients topic here, describe how the

13 certifier cross-references currently if other

14 ingredients within a National List item, how

15 that verify that that item is compliant or

16 not.

17 MR. WILLIAMS: Well, some TRs have

18 listed the other ingredients that were looked

19 at. Other ones don't. So the way Oregon

20 Tilth looks at it is that these other

21 ingredients were looked upon by the NOSB when

22 that material was petitioned. Of course,
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1 those other ingredients have to have a

2 technical or functional effect in that

3 material you're looking at, and they can't

4 have any technical or functional effect in the

5 product they're going into. So we, basically,

6 allow the other ingredients as long as they

7 have a technical or functional effect, and we

8 do look at the TRs to make sure that, you

9 know, to see if there were some that were

10 recommended along with it. 

11 CHAIRPERSON STONE: So if you saw

12 a product X was in the TR for a given

13 substance, do you then extrapolate that it

14 must be okay in some different application,

15 some different product? 

16 MR. WILLIAMS: So you're saying

17 that if I see an other ingredient in a TR for

18 one material, would I expect it to be okay in

19 another? No, I wouldn't be able to

20 extrapolate that. 

21 CHAIRPERSON STONE: Jay? 

22 MEMBER FELDMAN: How often do you
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1 not see a TR address other ingredients, or do

2 you see them consistently addressing other

3 ingredients? 

4 MR. WILLIAMS: It varies. I

5 couldn't really say, I mean, with all the

6 technical reports out there, how many do and

7 how many don't. I could say, you know, maybe

8 half and half, I could guess. You know, it's

9 really hard to say. I see a material, and

10 then I evaluate it, and I look at those to see

11 if there was anything mentioned in there. 

12 MEMBER FELDMAN: And you may have

13 already said this, but if you don't find it in

14 the technical review, then what's the process

15 from there? 

16 MR. WILLIAMS: Again, that it has

17 a technical or functional effect in that

18 material and that it doesn't in the finished

19 good. 

20 MEMBER FELDMAN: Okay. 

21 CHAIRPERSON STONE: Jean? 

22 MEMBER RICHARDSON: Back to the
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1 calculating percentage organic comments, could

2 you expand on the comments that you were

3 making there verbally and that are also in

4 your written materials with regards to

5 extracts, hydrosols, flavors, and the water6 related issues in standards of identity? 

7 MR. WILLIAMS: Sure. That one has

8 been a really difficult one to figure out. 

9 Like I said, the standards of identity are

10 very slim in the FDA standards, and a lot of

11 them don't have what natural water occurred

12 prior to the process to make the ingredient

13 that has the standard of identity for. 

14 Currently, it's been interesting to try and

15 evaluate an extract or a hydrosol to figure

16 out what the organic, the contributing organic

17 percent would be of that. It's extremely

18 hard, and we've looked at -- so we do

19 certification for NSF-305, cosmetic and body

20 care. And they actually do have calculations

21 for different fresh extracts, you know, an oil

22 extracted from a fresh herb or a dried. And
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1 even those are, they're hard to take in as

2 accurate. You can end up with these

3 calculations with a negative contributing

4 factor depending on a scenario. 

5 And I've been starting to do more

6 and more research with other certifiers to see

7 what a sound approach is to an extract. I've

8 even talked to a body care professional that

9 said in some of these extracts you could even

10 consider tea an extract and that the

11 contributing organic percent would be less

12 than ten percent. So it's difficult. It's

13 something that we're trying to figure out a

14 sound approach to on extracts.

15 Fortunately, we don't see a lot of

16 them going into other products where we have

17 to pull out the water because the organic

18 contribution of all the other ingredients is

19 way more than the non-organic. So a non20 organic may be in there at one percent, where

21 you don't need to question that water content. 

22 You could just say that that qualifies as
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1 organic. 

2 So we haven't gotten ourselves

3 into any situation where we wondered whether

4 or not that calculation was correct. But I

5 can see it coming in the future. 

6 MEMBER RICHARDSON: Thanks. That

7 was very helpful.

8 CHAIRPERSON STONE: Colehour? All

9 right. Thanks, Darryl.

10 MR. WILLIAMS: Thank you. 

11 CHAIRPERSON STONE: Okay. Again,

12 we'll double back to make sure that anyone's

13 name that wasn't here when we called their

14 name for the entire day, we'll check at the

15 end of the program here. So with that, Ms.

16 Jennifer will begin the GMO Ad Hoc Committee

17 Subcommittee discussion. 

18 MEMBER FELDMAN: Mac, I have a

19 question. 

20 CHAIRPERSON STONE: Jay?

21 MEMBER FELDMAN: Are we going to

22 discuss some of these proposals we'll be
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1 voting on? I'm trying to figure out when

2 that's going to happen on the, like other

3 ingredients, for instance.

4 CHAIRPERSON STONE: Yes, during

5 the Handling Committee.

6 MEMBER FELDMAN: Okay. 

7 CHAIRPERSON STONE: We just got

8 opportunity --

9 MEMBER FELDMAN: Okay. So he was

10 commenting, right. Sorry. 

11 CHAIRPERSON STONE: Yes.

12 MEMBER TAYLOR: Okay. Thank you,

13 Mac. And good afternoon. I'd like to start

14 with a slide about the mission of the GMO Ad

15 Hoc Subcommittee, please. Thank you. The

16 National Organic Standards Board believes that

17 genetically-modified organisms must be kept

18 out of organic food and accepts responsibility

19 for making recommendations on policies that

20 can strengthen the rule's approach to excluded

21 methods. 

22 The NOSB GMO Ad Hoc Subcommittee
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1 will undertake examination of all the areas

2 where GMO contamination poses a threat to

3 organics and will attempt to provide

4 leadership in clarifying what excluded methods

5 actually are and how compliance to the

6 provisions of the rule can be monitored. So

7 we've received hundreds of comments from our

8 public and organic consumer communities that

9 address growing concerns for GMO contamination

10 in their produce in their fields that affect

11 and impact the food system and the need to

12 keep a high organic standard.

13 Organic stakeholders are concerned

14 about keeping genetically-modified organisms

15 out of organic livestock feed, crops, and

16 foods. These are some of the comments that we

17 have collected from your comments. 

18 Please do not allow the

19 introduction, by contamination or otherwise,

20 of organics by genetically-modified organisms

21 and seeds. Maintaining the trust of the

22 public and the integrity of the organic
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1 standards is imperative. 

2 Please keep our food safe. There

3 is no reason to allow synthetic chemicals or

4 genetically-modified organisms into the

5 growing or processing of organic food

6 production. I count on the certified organic

7 label on the food I eat. I, along with many

8 millions of humans, depend on organic food for

9 our health and well being. 

10 Preserving food planting and

11 organic methods of integrity is of utmost

12 importance to me personally, as well as

13 protecting my private land from negative

14 invasive techniques used by neighboring farms.

15 Thank you for reading this. 

16 Another comment. Keep GMOs out of

17 organic food. The USDA is responsible for

18 contamination prevention. Organic farmers and

19 the NOSB and the Program must hold USDA

20 accountable. 

21 Consumers choose to buy certified

22 organic food because they want to support
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1 systems of production that protect and enhance

2 human health and the environment. They also

3 expect their organic food to be grown without

4 the use of antibiotics, growth hormones,

5 genetically-engineered organisms, and

6 synthetic herbicides and pesticides. 

7 Preventing contamination of organic crops by

8 genetically-engineered organisms is important

9 to maintain the organic integrity. 

10 Other comments. Harmful

11 synthetics and GMOs must stay out of organic

12 foods. We are on the verge of a very serious

13 food crisis if we don't act now. Please

14 listen to your voting public. You are our

15 voice.

16 The hardworking members of the GMO

17 Ad Hoc Subcommittee include the list that you

18 have there. And we have before the public two

19 discussion documents, one on dealing with

20 excluded methods terminology and Zea Sonnabend

21 will provide the discussion and summary of

22 public comments, and then we have another
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1 document that has been revamped, so to speak,

2 and we're received additional comments on GMOs

3 and seed purity. It's also a discussion

4 document, and Colehour and Jay Feldman will

5 provide a summary of the comments that we have

6 received in regard to those documents. Thank

7 you, Colehour. 

8 MEMBER BONDERA: Okay. Thank you,

9 all. So at the last meeting, we had put forth

10 a discussion document on GMOs and seed purity. 

11 And we decided to extend that opportunity for

12 additional public comment on this same

13 discussion document. It's still as a

14 discussion document but looking for more

15 suggestions from -- sorry -- what did we say? 

16 Sorry. I'm a little bit distracted there. 

17 From seed and crop producers, ideally, to

18 carry forth with this.

19 So I don't really, like I just was

20 suggesting, it's not a brand new process. I

21 don't want to take you through too much of the

22 details, but I'll still quickly go through the
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1 eight discussion questions that are in this

2 discussion document that we did put forth. 

3 The first one is, essentially, is there a need

4 to establish a seed purity standard? What's

5 currently known about the contamination from

6 GMO contamination? What testing methods are

7 appropriate? How would some of the

8 possibilities that we had put forth in the

9 discussion document affect your farmer

10 business? Is some of the suggestions that we

11 put forth, you know, do you have better ideas

12 or options? What's known about sampling,

13 testing, and detection levels to be able to

14 implement such a standard? What training,

15 guidance, or resources do certifiers need to

16 verify compliance for such a standard? And

17 also what could organic seed producer do to

18 safeguard against GMO contamination? So

19 that's, very briefly, the different questions

20 that are in the discussion part of the

21 discussion document that we put forth. 

22 So, yes, like I said, we extended
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1 the deadline. So let me figure out how to

2 make this carry on for me. There it is. 

3 Let me just quickly mention what

4 had happened in the previous public comment

5 very briefly. I would say, generally

6 speaking, like was said at the last meeting,

7 there was general support received in

8 response. And it is perceived as a piece of

9 the whole process to protect organic from GE

10 contamination. In other words, if, you know,

11 the seeds are a critical component of that. 

12 I think that I realized a few

13 minutes ago that, from my perspective at

14 least, this is a subcategory, to some degree,

15 and I think I sort of suggest that there, of

16 the concept or definition or explanation of

17 excluded methods in OFPA, which is the topic

18 that Zea is going to be addressing. So at

19 some level, this is, because I think it's

20 related directly to that need for an update of

21 excluded methods, which is, generally, what

22 people said. Really, to consider the other
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1 pieces of the picture, since many organic

2 producers, as we all can and should be aware,

3 and, you know, it's not exclusively true but

4 it's true, are using conventional seed in

5 organic production. 

6 So, quickly, I'll just talk about

7 the highlights, in my opinion anyway, my

8 review with help from Jay, of what has come

9 from the written comments that we have

10 received. And I'm not going to quote and cite

11 a lot of details, but I think it's,

12 nonetheless, important to go through it. And

13 some of them are just generally taken,

14 essentially, do not make organic seed less

15 available is a concern that came up several

16 different places in a couple of different ways

17 but I think is very important for people to be

18 cognizant of the fact that would testing mean

19 that there's less organic seed available or

20 would this process constrain that? And I

21 think that that's important.

22 But I think, like I already said,
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1 generally speaking, testing is needed, is

2 really, in summary, what people said. But

3 several people commented on a slow phase-in of

4 what's already happening in terms of systems

5 for looking at seed is important. 

6 We put in the discussion document

7 the -- yes, I'm not ready to review it, but we

8 did put forth this zero in 3,000, yes, it's

9 item number seven in our discussion points,

10 seed sample, and we did get one public comment

11 on corn seed that went into that, and that's

12 important, I think, as one approach. I think

13 that several people, several comments refer to

14 the co-existence issue, and I think it's worth

15 noting Mark Lipson has been working with AC

16 21. AC 21's mandate is to look at co17 existence, which, you know, seeds is part of

18 that. And I think that it comes to that

19 concept of working together, but it comes to,

20 you know, how to get there. And I think that

21 co-existence of conventional and GMO

22 production relates directly to the opportunity
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1 to have seed that isn't GMO contaminated. I

2 think that that's a significant and important

3 issue, and I think Mark has been participating

4 in our discussions within this subcommittee on

5 this topic, and I think we will continue

6 working with and trying to move that forward.

7 I think I realize right now, and I

8 think in my last point it sort of referred to,

9 but I think that in this point, as well. You

10 know, some of the commentary suggests, and one

11 of the comments, and I'm not looking at it so

12 I'm not going to cite it specifically, refer

13 to the concept that the USDA really should be

14 gathering and reporting ongoing data,

15 including sources of contamination and things

16 like GE production sites must be a matter of

17 record where contamination trends are mapped

18 and really things like that technical support

19 should be given for remediation. And I think

20 my point is putting it back to the USDA to

21 enforce containment but also that the NOSB and

22 the NOP can and should be holding the USDA
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1 accountable, and organic farmers, holding the

2 USDA accountable to ensure that, not

3 specifically or necessarily, but this relates

4 to the co-existence topic, that it's possible

5 to have organic seed. 

6 And I think that that's my final

7 sort of point, and then I'll get to the final

8 point on there very briefly, which is I think

9 it starts out with, I think our discussion

10 document starts out with the concept of how

11 can we go about this or how can we pursue

12 this, and I think that that's sort of where

13 we're at right now. And I think from the

14 public comments that have come, and I was

15 happy that there have been some, and, in my

16 preliminary look through our oral testimony,

17 there was going to be even more people at

18 least including in their subject areas the

19 seed purity topic, I think that people are

20 definitely interested. I think that what

21 we've seen is that we need more information on

22 next options so that, as a subcommittee, we
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1 can really take this information and figure

2 out how to pursue either further research

3 communications, maybe do a study. I think my

4 personal general sense and from discussing it

5 with the Subcommittee, it doesn't seem like

6 we're going to be coming up with a

7 recommendation prior to seeking more

8 information, but I really think what I put

9 there of adding it to the NOSB's research

10 priorities is necessary. 

11 And I think, at this point in

12 time, if other Subcommittee members,

13 especially Jay, if anybody has anything to add

14 to what I've shared, I think that that would

15 be fine. But I do personally look forward to,

16 you know, any oral testimony at this meeting

17 that we get on this topic. I think it will

18 help guide our direction, so thank you. 

19 MEMBER TAYLOR: Zea? Thank you. 

20 MEMBER SONNABEND: Thank you,

21 Jennifer. Well, as Jennifer provided in the

22 introduction to the GMO Subcommittee, Ad Hoc
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1 Subcommittee, consumers are united in not

2 wanting any GMOs in their organic food. And

3 as one of the commenters that she quoted

4 stated, we are their voice and it's our

5 obligation to help keep the GMOs out of

6 organic food. So in trying to think

7 strategically about how we do that, we have to

8 deal with the areas that we can do something

9 about and try to raise the level of visibility

10 of these issues and keep putting pressure on

11 the powers that are imposing GMO dominance

12 onto the world and try to resist them to be

13 able to keep organics free of GMOs.

14 So for all of those positive

15 consumer comments who recognize this, and we

16 very much appreciate the reinforcement, there

17 are a few who commented about things that we

18 can't really do anything about. Much as I

19 think we universally would support labeling of

20 GMOs on conventional food, we can't really do

21 anything about that. That's a state-by-state

22 issue, and we will support them in our own
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1 states, as we see fit. And we feel that

2 organic food already does not contain GMOs,

3 and that's more of our responsibility to try

4 and keep GMOs out.

5 We also are accused by some

6 commenters of the ulterior motive of trying to

7 sneak them in without their knowledge. And

8 believe me, while I can be as paranoid as the

9 next person, but I really hope that we're all

10 on the same page here and we are not trying to

11 sneak them in by opening up these subjects,

12 some of which are very complicated, for

13 discussion. We're trying to air them out, air

14 out the issues with a goal of strengthening

15 keeping GMOs out of organic food.

16 So, that being said, we proposed a

17 very complicated and ambitious topic, and that

18 was is the term "excluded methods," which is

19 used for genetic engineering in the rule,

20 really sufficient as a definition? Our paper

21 is fairly complicated. It analyzes the actual

22 words of the definition word-by-word and
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1 phrase-by-phrase. Then it suggests a number

2 of other possible terms that may or may not

3 belong in the definition. It takes no stand

4 either way on whether something should be or

5 shouldn't be in the definition but asks the

6 public for their input on what should and

7 shouldn't be in the definition.

8 It also takes no stand on how

9 we're going to achieve a new definition. We

10 did not specifically say that we are going to

11 open up the rule and actually change the

12 definition in the rule. We didn't

13 specifically say we were going to have

14 guidance or some interpretation of it through

15 guidance or any other format. All of that is

16 still a ways away, and we will be looking at

17 all of our options in the future.

18 So, you know, I hope those of you

19 who objected to the whole idea based on the

20 fact that it was opening the rule understand

21 that that isn't necessarily the outcome of

22 this, and we do, we expect this will be a
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1 long-term project until we come to this stage

2 of a recommendation about this. 

3 So we asked several questions of

4 our public about what they thought of what we

5 had put forth. We got more questions back

6 then we got answers to those questions, and we

7 got a lot more questions back. And they were

8 really good questions, and they were sort of

9 all over the place, which is why I haven't

10 tried to summarize them with slides. 

11 But suffice it to say that we

12 appreciate very much that some of you turned

13 in articles with your comments that brought up

14 more terms that we hadn't considered. We got

15 lots of good information about what other

16 countries are doing. A group in Switzerland

17 talked about their situation in Europe, which

18 was very helpful to us, as well as we heard

19 from Canadian stakeholders and others

20 concerned with international equivalency on

21 this issue.

22 So I'm not going to be, you know,
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1 highlight specific comments like we've done in

2 many of the other presentations here but just

3 say that we are going to thoroughly digest

4 each and every one of them and we will come

5 back in the future with probably a few more

6 discussion documents before we come to a

7 recommendation on this subject.

8 Also, later today or, not today,

9 later in the meeting, you will hear that we're

10 hopefully finally ready to pass a

11 recommendation about public communication. 

12 The public communication document is designed

13 so that we can have an open docket year-round

14 so people can provide input, not just in the

15 three to four weeks before each meeting. And

16 we're hoping that that is going to be able to

17 be used two ways so that, because, really, for

18 a document as complicated as this excluded

19 methods document, we should have been able to

20 have it up for six months to get comments from

21 everyone. And so we're hoping, in the future,

22 we can have a long-term document that can
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1 really have a chance to get out there and get

2 comments in for a long enough period so that

3 everybody can properly review it.

4 So that's what we're anticipating. 

5 And we expect a lot more work on this issue to

6 come. Thank you. 

7 MEMBER TAYLOR: Thank you, Zea. 

8 Mac? 

9 CHAIRPERSON STONE: All right. 

10 Thanks, Jennifer. We have, I believe, 11

11 people signed up to comment as part of the GMO

12 Committee. First up is John Tanzi. John is

13 available. And, again, we're a little ahead

14 of schedule, so we'll double back if we have

15 the opportunity. Kelci Bynum? Laura Batcha,

16 I know you're here. Dag Falck, I know you're

17 here. Dag is on deck. 

18 MS. BATCHA: Hi and thanks. I'm

19 Laura Batcha with the Organic Trade

20 Association. I serve as a vice president of

21 the Trade Association, and I serve on two

22 federal advisory committees that are relevant
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1 to some of the areas I'm going to comment on. 

2 One is the AC 21 that advises the Secretary of

3 Agriculture on issues related to co-existence. 

4 And then the second is the Agricultural Policy

5 Advisory Committee, which is an international

6 trade advisory committee to the Secretary of

7 Agriculture and the U.S. Trade Representative.

8 I have signed up to primarily talk

9 about the seed purity document, but I just

10 wanted to clarify a couple of things that I'm

11 hearing about the difference between the use

12 of alternatives in the European Union versus

13 the U.S. in terms of practices and

14 alternatives and antibiotics. So I'll just

15 quickly address that and then move on.

16 I think, primarily, the difference

17 is to keep in mind that what we're talking

18 about for alternative protocols that are under

19 research here is a combination of a yeast

20 product and a copper product. In the case of

21 what the trials are looking at, it's the

22 Blossom Protect and the Previsto. 
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1 In the United States, the Blossom

2 Protect was first tested in `08, registered

3 with the EPA in 2012. So it was not available

4 for growers to use until 2012. The copper

5 product, the Provista, which is a 3-percent

6 copper solution versus the more widely

7 available copper product that's a 50-percent

8 solution, is not yet registered with the EPA. 

9 We expect that that process could be completed

10 in 2013. It could get kicked out further.

11 So one of the primary differences

12 between the way U.S. orchardists and European

13 orchardists have been able to manage this is

14 that they have had these tools available to

15 them to use, the yeast product and copper

16 products, in the management of fire blight. 

17 To date, the alternatives that are under

18 research have not been available to U.S.

19 growers, so it's not just as simple as the

20 fact that they're used to antibiotics and that

21 was they've just grown up with them and so

22 they like to use them. The tools we're
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1 talking about and the research have been

2 available in the European Union and they

3 haven't been available here.

4 And I think the only other thing

5 that I'll note about that is that keep in mind

6 the European Union standards for copper

7 applications are a little bit different than

8 they are here. They typically will use that

9 higher solution of copper, the 50 percent, and

10 the requirements in the EU for restrictions on

11 copper have to do with kilograms applied per

12 hectare per year that you cannot exceed over

13 an annual basis in terms of application. They

14 do not have the restrictions that we have

15 around accumulation in soil and requirements

16 to test for copper accumulation.

17 And then, lastly, in the European

18 Union, the standards allow for the member

19 states to issue derogations or what are

20 temporary variances on that restriction. So

21 you only have to hit that load rate on copper

22 of kilograms per hectare on average over a
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1 five-year period. And we've heard about fire

2 blight coming in cycles, so you could actually

3 use all of it in one year in a bad fire blight

4 year and still meet the requirements in the EU

5 standard.

6 So I just think there's a little

7 bit of difference in terms of what is allowed

8 and not allowed in the standards that may

9 provide a little bit more color to the

10 difference in how those practices have

11 developed.

12 So the first thing I want to do,

13 as I change gears, is to do a shout-out to

14 NOP. We just completed our consumer survey

15 for the fifth year in a row, and this is the

16 first year that we have seen a statistically

17 significant increase in the consumers' trust

18 in the organic seal. So a ten-percent

19 increase over where we've been tracking as a

20 flat line historically, where we'd see 32

21 percent of parents report in that top box that

22 they had high trust that if it was labeled
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1 organic it was organic. We saw that jump by

2 ten percentage points in the last 12 months,

3 and so I think that that's important as we

4 take a step back because you guys do all the

5 hard work on the leading edge of continuous

6 improvement where you're challenging the

7 things that need to be pushed forward. 

8 So if anybody wants to ask me

9 about seed purity, please do. 

10 CHAIRPERSON STONE: Well, that was

11 one way to time it good with the light but not

12 -- I think Terry still gets the prize on that. 

13 Zea? 

14 MEMBER SONNABEND: I'm going to go

15 a little bit beyond seed purity, but this

16 might enter into it. What I'd like to hear

17 is, from your AC 21 perspective, how our work

18 can best support your work on AC 21 and

19 whether that might include seed purity issues

20 at all.

21 MS. BATCHA: Thanks, Zea. I think

22 if you all are not familiar with the final
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1 recommendations from the AC 21 to the

2 Secretary, they were, in large measure,

3 disappointing. It was a tough debate in terms

4 of stakeholders that represented organic and

5 identity preserved agriculture. We had about

6 5 of 22 seats on the committee, so it was a

7 very tough discussion in terms of getting our

8 point across about fair, equitable solutions

9 to prevent gene flow and contamination.

10 There were a few highlights in the

11 recommendations that were delivered to the

12 Secretary that called for USDA to engage in

13 data collection about the state of genetic

14 purity of the seed stock as a whole and also

15 a request for seed providers to give data to

16 USDA about the contamination levels of their

17 non-genetically-modified seed that they're

18 selling into the marketplace.

19 So there's a piece in the AC 21

20 recommendation that could further this

21 discussion if that data is actually collected. 

22 I like the idea that Colehour suggested about
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1 adding that to the NOSB research priorities

2 because I think that could signal to the

3 Secretary that the NOSB agrees that that data

4 collection is critical in terms of getting the

5 conversation off the ground. So I think I

6 would fully support that.

7 One of the challenges that we

8 faced over and over again in the discussions

9 at AC 21 was, no matter how we presented the

10 information, the response we got was, well, it

11 doesn't matter in the organic standards how

12 much GMO contamination you have in terms of

13 your certificate, there are no consequences. 

14 Therefore, we are not taking seriously your

15 communication to us that there are economic

16 consequences of contamination. 

17 So I share that because that's

18 what we heard repeatedly. So I think you saw

19 it in some of the public comments from other

20 groups. I think, in fact, ASTA weighed in

21 saying there are no consequences, so we

22 shouldn't even be talking about this. So
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1 that's an underlying debate that, you know,

2 is, quite frankly, challenging because you

3 don't want to see people losing their

4 certificates for things that are beyond their

5 control. But at the same time, the forces

6 that don't want to see those hard restrictions

7 on gene flow use our processed-based standard

8 without a threshold as a rational for not

9 taking action.

10 CHAIRPERSON STONE: Calvin? 

11 MEMBER WALKER: Would you finish

12 your comments on seed purity and, two, the

13 survey? That is very good news. Could you

14 give us a little bit more on the 58 percent

15 and the sample size? 

16 MS. BATCHA: Sure. Happy to. 

17 I'll do the seed purity first, and I'll try to

18 do a short version of it. You have my written

19 comments. This is the second time we've

20 commented on it. I think it's clear to the

21 Board that OTA's official policy, unanimously

22 adopted by our board, is that we think it's
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1 time for the organic standards to evolve vis2 a-vis GMO. And that includes looking at a

3 seed purity standard as the first place to

4 start, in terms of controlling the

5 contamination of GMOs in organic products. We

6 see the consumer data showing regular upticks,

7 statistically significant, every year about

8 consumers' concern about GMO in products. 

9 They want to look to organic as the gold

10 standard in terms of avoiding GMOs.

11 What we hear from our members and

12 the reason we've gotten involved more deeply

13 in this discussion is that our members are,

14 quite frankly, frustrated. They're seeing a

15 consumer expectation out there for organic,

16 and they're seeing marketplace requirements to

17 not have GMO contamination. So there's a

18 whole set of external requirements on the

19 marketplace right now, whether you're an

20 international trader or selling into retail,

21 that expects that there's testing and limits

22 on the amount of GMO that's in the product. 
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1 It's not required in the standard, but it is

2 becoming de facto in the marketplace.

3 So whether you're a farmer or a

4 grain elevator operator or an exporter or

5 processor, your interacting with an ad hoc

6 testing system that is existing outside of the

7 organic standards. And whenever you have an

8 ad hoc solution that requires testing, it gets

9 very expensive. The same crop of corn could

10 get tested numerous times throughout the

11 system, and so the costs become burdensome. 

12 People are frustrated, and they've committed

13 decades to their organic program, and we're

14 hearing a lot of people fed up. We want to

15 know that our organic certificate is enough to

16 demonstrate that we're meeting this

17 expectation in the marketplace. So it just

18 kind of gets that simple. So it's not about 

19 -- I completely understand and we advocated

20 for it at AC 21 the perspective that the

21 makers of the technology need to take

22 responsibility for their products moving into
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1 other people's products where they're not

2 wanted, and we're in full agreement with that. 

3 But the reality is our members and the farmers

4 and the operators are already taking

5 responsibility because they're having to do

6 the testing, they're having to do the

7 controls. And if you look at seed as a place

8 to start, you could see how rationally then

9 certifiers could engage with growers around

10 the practice standards.

11 So a certifier can't come in and

12 test a crop and say, oh, we're detecting GMO

13 in the corn, and have any idea about how to

14 work for continuous improvement because you

15 just don't know what was in the seed when it

16 was planted. If you can eliminate that from

17 the equation, then the variables are much more

18 discrete. It's buffer zones and it's

19 commingling prevention in the supply chain. 

20 And then you can work towards improvement in

21 those areas, and I think it's a very basic

22 concept and I know there's all kinds of
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1 details that have to get worked out. We

2 wouldn't want any farmers left behind. We

3 would want to know it was feasible. We

4 wouldn't want to drive people away from

5 choosing organic seed. We want farmers to be

6 able to save their own seed. But, ultimately,

7 if that standard came through on the seed bag,

8 the farmer would know they had a chance to

9 meet the market expectations when they planted

10 it and harvest their crops and moved into the

11 supply chain. 

12 And they wouldn't have to be

13 testing the seed. It could come in like the

14 other standards of analysis that come in on

15 seeds, and certifiers could use the five16 percent testing requirement to, if they

17 choose, determine whether or not the label is

18 true and the farmer wouldn't have to be

19 testing. So that's sort of the concept, and

20 we'd like to see you all sort of push

21 yourselves to, you know, we know it's going to

22 take a long time, but we encourage you to make
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1 a commitment in that regard. 

2 CHAIRPERSON STONE: Jean? 

3 MEMBER RICHARDSON: Laura, thank

4 you for clarifying the situation with regards

5 the lack of availability for commercial

6 alternatives to the tetracycline antibiotic. 

7 What about the situation with Canada? Are you

8 aware from the OTA what is used in Canada for

9 fire blight control? Is it any different to

10 the Europeans? 

11 MS. BATCHA: They're not allowed

12 to use antibiotics. We know that, so I would

13 imagine their protocols are similar. They

14 tend to sort of differ that way. I don't have

15 the specifics on that. I could find out for

16 you, Jean. Their tree fruit production is a

17 little bit more geographically limited. A lot

18 of their consumption of tree fruit comes from

19 the U.S. in Canada.

20 CHAIRPERSON STONE: John? 

21 MEMBER FOSTER: So I like this

22 union of analytics and process. So what would
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1 you guess is the, you know, the final outcome? 

2 Are we looking at more organic seed or less

3 organic seed as the seed purity standards

4 moves forward? As you know, many in the

5 audience know, that's kind of what I'm about

6 is more organic stuff, so that's what I'm

7 interested in here with respect to seed -- 

8 MS. BATCHA: Yes, you know, I

9 think you guys hear us. Sometimes, you don't

10 like it, but consistently we say take the time

11 you need so we don't leave farmers behind. 

12 That's what we're saying on antibiotics. So

13 we wouldn't take a different position than

14 that on this. We don't want to see farmers

15 left behind, and we don't want to see acreage

16 move out of organic. 

17 I think, to answer that question,

18 you'd have to really look at and ask the

19 question of the farmers that are planting

20 those row crops because you're talking about

21 a pretty small set of crops that would be

22 impacted, at least out of the gate, on this:
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1 corn, soy, cotton, a couple of others. 

2 So the extent to which people are

3 already using organic corn and soy versus

4 commercially-available non-GMO alternatives,

5 I can't answer that question. But I think

6 that's important because it may have a

7 different organic use rate than, say,

8 vegetable crops, John. 

9 So I think you'd have to start

10 with that, and you would want to make sure

11 that you didn't lose growers. But I know that

12 one of the most dramatic drops in acreage for

13 organic and the difference between the `08 NAS

14 census and the 2011 USDA production survey is

15 in the area of corn and soy. We're already

16 losing organic acreage. 

17 CHAIRPERSON STONE: Nick? 

18 MEMBER MARAVELL: Yes, Laura, just

19 to play devil's advocate, and I know you know

20 I've never done that before, why not let the

21 marketplace handle this specifically within

22 the seed industry? And, that way, the cost
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1 would be restricted to the seed industry, and

2 it would be handled on a market basis. 

3 MS. BATCHA: You could certainly

4 do that, and that's already happening. There

5 are private contracts that are being put into

6 place. You know that. So there's certain

7 blocks that are not purchasing seed unless it

8 meets that standard. So I think to codify it

9 gives a level playing field for all organic

10 farmers to be buying seed that's disclosed and

11 labeled so that they can, you know, again,

12 sort of have a fighting chance to get out the

13 other side. And I think what you don't gain

14 by that is preventing what a lot of folks are

15 concerned about, which is the erosion of the

16 seal as the gold standard in the minds of the

17 consumer for avoidance of GMOs if it's

18 happening outside of the organic standards

19 itself. But by the time you all get that work

20 done, the private sector will have moved and

21 you'll probably have something that's more

22 feasible and viable by the time you wrestle
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1 all the details on it. 

2 MEMBER MARAVELL: Well, and this

3 is a little bit more of a statement than a

4 question, but are we transferring the cost and

5 the effort to the organic community here? And

6 in the interest of full disclosure, I'm a corn

7 and seed, organic corn and seed producer. Are

8 we transferring that to the organic community

9 here? Has that meant that we are giving up on

10 looking for other ways to handle this

11 situation? 

12 MS. BATCHA: You know, I would

13 really hope that that doesn't mean that we're

14 giving up on other ways to handle that

15 situation, and I think there are ways for the

16 Board to continue to articulate that to the

17 Secretary and keep the pressure on because

18 there's what USDA perceives as legal

19 limitations through their ability to put real

20 teeth into contamination prevention protocols. 

21 That absolutely has to get addressed.

22 What we're hearing from our
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1 members is the difference is symbolic more

2 than it is, in some, actual. They're already

3 taking responsibility. They're already having

4 to test. They're already having to meet the

5 market requirements. So the cost burdens are

6 already falling on the organic community in a

7 way that is not as controlled as it could be

8 were it to happen through the regulatory

9 framework. 

10 So that's sort of the top level

11 what I hear from our members is they're

12 bearing the cost. 

13 CHAIRPERSON STONE: Thank you,

14 Laura.

15 MS. BATCHA: Thanks. 

16 CHAIRPERSON STONE: So in the

17 effort of trying to be in respect to people's

18 schedules, we're going to back up to the folks

19 that were here for materials, a little closer

20 to their actual time they were advised to be

21 here. Carol Boutard, you're here. And Craig

22 Baker is on deck. 
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1 MS. BOUTARD: Should I start? Hi. 

2 My name is Carol Boutard, and I'm speaking on

3 behalf of Marcus Kastel who can't be here

4 today. I'm a member of the Cornucopia

5 Institute and here today as a citizen

6 lobbyist. Together with my husband Anthony,

7 we run a certified organic farm in the

8 Willamette Valley. 

9 Although it is not on the agenda,

10 Cornucopia would like to comment on the

11 conflict of interest issue. We disagree in

12 several ways with the memo by USDA's Mr.

13 McEvoy to the NOSB chair, which appears to

14 attempt to highjack the process of developing

15 an improved conflict of interest policy,

16 historically, under the purview of the Board.

17 In light of this recent memo, we

18 urge the Board to reclaim authority. This is

19 especially important given the USDA's severely

20 guidelines for determining whether a conflict

21 of interest exists. The NOP essentially

22 states that no conflict of interest exists if
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1 at least one other business entity has an

2 interest in the vote, as well. This ignores

3 the very basic definition of a conflict of

4 interest, which has nothing to do with whether

5 others have a conflict of interest, as well. 

6 Two conflicts of interest do not cancel the

7 other out.

8 A conflict of interest exists when

9 a Board member has an interest that would

10 impair his or her objectivity when voting. A

11 Board member's primary responsibility is to

12 the entire organic community and to organic

13 integrity. Yet, the USDA has changed the

14 definition of a conflict of interest by adding

15 the criterion of disproportionate benefit. A

16 conflict of interest has nothing to do with

17 whether others stand to benefit, as well. It

18 is about whether a secondary interest impairs

19 a Board member's objectivity and

20 responsibility to the organic community as a

21 whole. 

22 If a Board member's employer,
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1 including its CEO, lobbies NOSB members for

2 their vote, as happened prior to last year's

3 carrageenan vote, how does that Board member

4 not have a conflict of interest? Was that

5 Board member able to look objectively at the

6 science and make an objective decision, given

7 her employer's clear interest in the outcome

8 of the vote? Just because another Board

9 member has a conflict of interest doesn't mean

10 she didn't. It means there were two Board

11 members with a conflict of interest.

12 Again, this is about whether a

13 secondary interest unduly influences a Board

14 member's ability to look objectively at the

15 material and vote in the interest of the

16 entire organic community. It has nothing to

17 do with whether others benefit, as well.

18 We are also concerned that the

19 USDA sets different standards for for-profit

20 business employees and non-profit employees. 

21 A for-profit business employee, according to

22 the USDA, can vote as long as others stand to
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1 gain from the vote, as well. But a non-profit

2 employee is expected to recuse him or herself

3 if a donation was received, regardless of

4 whether other non-profits are also the

5 recipients of charitable donations by a

6 petitioner. This double standard is not

7 acceptable.

8 For the upcoming tetracycline

9 vote, we believe two Board members involved in

10 organic apple and pear production have a

11 conflict of interest and should recuse

12 themselves to protect the integrity of the

13 process. Our aggressive pursuit in this

14 matter is not an attempt to embarrass any

15 Board members. It would reflect a highly

16 ethical approach to voluntarily step away from

17 such a vote. Thank you. 

18 And as a farmer who has carefully

19 followed organic standards for many years, I

20 was personally insulted by the memo from

21 Director McEvoy because anything that

22 challenges the quality of the USA organic mark
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1 is unacceptable. Thank you. And I'm sorry I

2 read that so fast. 

3 CHAIRPERSON STONE: Thank you. Is

4 there questions? Zea? 

5 MEMBER SONNABEND: I'm one of

6 those people you're accusing. How do you know

7 I have a conflict of interest? 

8 MS. BOUTARD: I personally do not

9 know if you have a conflict of interest. In

10 a direct question like that, I would like to

11 refer to Charlotte Vallaeys, who would

12 probably have a clearer notion of that. 

13 MEMBER SONNABEND: No, no

14 referrals. 

15 MS. BOUTARD: Okay. 

16 MEMBER SONNABEND: But you did

17 accuse me in your statement, and I submit that

18 you have no idea if I have a conflict of

19 interest or not.

20 MS. BOUTARD: I have great

21 confidence in Mark Kastel's impression of the

22 events that occurred, and I would refer, I
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1 would stand behind any statement that he made.

2 CHAIRPERSON STONE: Thank you for

3 you being here. Thank you. 

4 MS. BOUTARD: Thank you. 

5 CHAIRPERSON STONE: Dag, sorry I

6 stepped around you. And that puts Craig Baker

7 on deck. 

8 MR. FALCK: Hi. I'm Dag Falck,

9 organic program manager for Nature's Path

10 Foods. Thank you for this opportunity to

11 comment. Nature's Path Foods is North

12 America's first and still largest certified

13 organic breakfast cereal producer, and our

14 highest priority is to keep organic standards

15 strong and to prevent GMO contamination. 

16 We support tightening the excluded

17 methods language to be more accurate. Rather

18 than using specific examples, we propose broad

19 but accurate descriptions. And I'll just give

20 you a very brief example. I drafted a

21 rewording of it. Methods that change the

22 genetic material of an organism through
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1 recombining DNA in ways that are not dependent

2 on the use of conjugating sexual or asexual

3 reproduction methods. And there's some more

4 detail in my written submissions.

5 In general, we feel that the

6 current standard does prohibit GMOs in organic

7 food production, but it does not prescribe the

8 necessary tools to prevent GMO contamination

9 from increasing in organic. This must be

10 addressed so we don't allow uncontrolled

11 contamination to start creeping into organic

12 food production. 

13 GMOs cannot be seen. Therefore,

14 we must use testing for a farmer to know if he

15 or she is planting a GMO-contaminated crop or

16 not. Without mandated testing for GMOs in

17 organic, there is no way to stop GMO

18 contamination increasing year by year.

19 We strongly propose that the NOP

20 should prescribe the using of PCR testing and

21 to set a maximum contamination level for the

22 protection of the farmers. In our experience
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1 as a manufacturer, 0.9 percent in ingredients

2 is achievable but not easy for organic

3 products. To achieve 0.9 ingredients, seed

4 thresholds probably need to be set at 0.5

5 percent.

6 On the issue of how to express the

7 levels, the proposal from the committee talked

8 about a number of seeds in the sample, and we

9 propose that that's not the best way to

10 express. We think it should stay with the

11 percentage because that's what's being used

12 currently, and it's not confusing. And we

13 think that using seeds in the sample would be

14 confusing.

15 We do not think that organic

16 should accept or tolerate any level of GMO

17 contamination. A threshold is only a

18 practical way to ensure farmer protection and

19 to make it possible to measure and achieve

20 continuous improvement. And as soon as

21 possible, the threshold should be reduced

22 until the day GMOs are eradicated in organic.
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1 A different topic. Nature's Path

2 also wishes to comment again on why we need

3 nanotechnology regulated in the NOP. The

4 urgency of this is increasing daily as the

5 field of applied nanotechnology is increasing

6 at a fast pace. Only April last year, the FDA

7 came out with a draft guidance document for

8 comment, including nanotechnology. It's in my

9 written documentation comments so you can look

10 up the link to it.

11 This guidance is moving in the

12 direction of treating substances that are

13 intentionally reduced to nano size in a

14 different way than their macro-sized

15 equivalents. Organic, at this point, does not

16 differentiate that. We believe it's not

17 difficult to clearly define and regulate

18 nanotechnology in organic without causing

19 unintentional disruption. 

20 And, last, we feel, Nature's Path

21 feels that it's time to ensure that

22 tetracycline used in organic is ended. And
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1 the only way to accomplish this is to ban it

2 as quickly as we're possibly able to do so. 

3 Thank you. 

4 CHAIRPERSON STONE: Thank you. 

5 Questions? Nick? 

6 MEMBER MARAVELL: I was wondering,

7 you refer to a threshold of GMO contamination

8 in organic product at 0.9 percent. This is

9 currently a standard used in Europe. Do you

10 have any thoughts on whether or not the U.S.

11 should just fall into line with that or create

12 its own threshold separately? And then the

13 second question I have is you indicated that,

14 for seed, the threshold should probably be 0.5

15 percent, and I was just wondering if you could

16 explain a little bit of your rationale basis

17 for that. 

18 MR. FALCK: Okay. Yes, I do

19 believe we should stay with the 0.9 percent

20 threshold for food, both because the EU has

21 set that and also because the Non-GMO Project

22 has several years' history with working with
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1 that threshold. And so we know it's

2 achievable. We know it's hard, so we know

3 it's not an easy slam dunk kind of thing,

4 anybody can do it. We know it's actually very

5 difficult to do it. We reject product in our

6 supply stream with that threshold.

7 So we think it's tough, but we

8 think it's achievable. And we think that's

9 kind of exactly where we need to be because

10 the idea here, the objective is to use a tool

11 to drive contamination down. So we have to

12 set it where we can live with it and then

13 drive it down. If we don't set it now and we

14 wait another few years, that level, that

15 balanced level is going to be higher than it

16 is today. So the sooner we set it, I think

17 the sooner we have the tools to start reducing

18 it. 

19 And so I think that is the level

20 that we found from our experiences that is

21 achievable. And, of course, it's handy to

22 have the same level as the EU, as well. 
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1 The reason I recommended 0.5 for

2 seed is because if you plant contaminated seed

3 in a field, the contamination increases

4 because what a GMO is is it's a technology

5 tied to a living organism, a living and

6 reproducing organism. So it's not like a

7 pesticide where you put it on and it

8 diminishes over time, you know, it dilutes in

9 the environment. What a GMO does is it's tied

10 to a living organism that breeds and

11 reproduces, and pollen that is spread from

12 that one plant goes and affects other plants. 

13 And then more seeds are genetically engineered

14 going forward.

15 So, you know, theoretically at

16 least, we know that chances of increased

17 contamination, so if you start with a certain

18 percentage of contamination in the field,

19 chances are you're going to have a higher

20 percentage of contamination at the end. 

21 That's why we need to start at a low level in

22 order to achieve because there's other sources
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1 of contamination, as well, in seed cleaning

2 and so on. 

3 MEMBER MARAVELL: I can understand

4 that rationale. Are you aware of any studies

5 or data on this? There's also a possibility

6 that the GMO, I'm not saying this is true, but

7 there's also a possibility that the GMO will

8 not be as selectively adapted in a particular

9 area and actually won't increase. It could go

10 either way. But chances are, you are correct,

11 it will continue to increase. But I was just

12 wondering if you're aware of any data, any

13 studies, or anything on that that would be

14 helpful to us? 

15 MR. FALCK: I believe there are

16 some references to it in the Myths and Facts

17 on GMO. Is that the right term for it? I

18 think there's a paper by John Fagan and some

19 other scientists. I think they treat that

20 issue there, but I'd have to go back to find

21 the specific source of it. 

22 But some studies have been done,
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1 but what we do know from experience, for

2 instance with flax in Canada, you know, ten

3 years ago there was some flax used and then it

4 was taken out of the system because the

5 farmers decided they didn't want to have it or

6 the Flax Council of Canada decided that they

7 wanted to end it. And so they did. They

8 thought they got rid of it, and then years and

9 years later the Europeans found it in Canadian

10 organic flax shipments. So we know even with

11 the best intentions, it got out of, you know,

12 it grew. 

13 So we do have some experience with

14 that. Canola is another example where we know

15 it started out being there, and then the

16 contamination increased to the point where no

17 certifier was willing to certify organic

18 canola in Canada. 

19 CHAIRPERSON STONE: Thank you very

20 much. We have Craig Baker, and Christine Hall

21 is on deck. 

22 MR. BAKER: Hello. My name is
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1 Craig Baker, and I'm a consumer, along with my

2 family, of organic foods. I'm a member of the

3 Cornucopia Institute, and I'm here today as a

4 citizen lobbyist. I volunteered to help

5 present testimony because I want to ensure the

6 integrity of organic food. Today, I will

7 comment on two items: production aids and

8 limited scope technical reviews. 

9 As more farmers switch to organic

10 certification, more materials have been

11 petitioned for use in organic crop

12 productions. The approved materials give

13 farmers more tools to use in their organic

14 toolbox, but, at the same time, the NOSB must

15 be careful to adhere to the categories of

16 substances allowed via the Organic Foods

17 Production Act.

18 One of these categories, the

19 production aids, has been used as a catchall

20 for any material that does not fit into any

21 other category. But it is not intended to be

22 used as such. We urge the NOSB to clarify
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1 this term. The examples given in OFPA are

2 clear. Production aids are materials that are

3 not dispersed in the environment and are not

4 taken up by plants.

5 We request that the NOP adhere to

6 a strict definition of production aids. We

7 also request that the NOSB adhere to a strict

8 definition of production aids as they are

9 asked to review the petitioned materials. The

10 production aids category includes only

11 physical items used in production without

12 leaving any residues on the crop or in the

13 environment. Production aids can also include

14 chemicals used to clean and sanitize equipment

15 but not used on crops or livestock. Materials

16 that do not fit that description should not be

17 called production aids. It may mean that some

18 petitioned materials will not be reviewed for

19 addition to the National List.

20 Using this strict definition will

21 reassure consumers about the integrity of the

22 organic label. It will also save time. The
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1 NOSB need not review materials that do not fit

2 the strict definition.

3 We support the proposal to

4 establish a process for limited scope

5 technical reviews. We support the proposal as

6 a way to save time and resources in cases

7 where certain threshold criteria are not met

8 and a full TR would not be warranted. 

9 I personally was shocked earlier

10 today to learn that antibiotics are still

11 being used in organic pear and apple

12 production. Myself, as a consumer and father,

13 am outraged that this has gone on for as long

14 as it has. I'm asking you to please keep the

15 2014 deadline and remove tetracycline.

16 Lastly, I expect all ingredients,

17 including ingredients of ingredients, to be

18 either organic or on the National List. Thank

19 you for your time. 

20 CHAIRPERSON STONE: Thank you. 

21 Questions? All right. Thank you very much. 

22 Christine Hall is up, and Anthony Boutard is
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1 on deck. 

2 MS. HALL: Hi. Good afternoon. 

3 I'm Christine Hall. I am a member of the

4 Cornucopia Institute and here today as a

5 citizen lobbyist. I would like to comment

6 specifically on the proposed recommendation

7 number two and the confidential business

8 information discussion document and why such

9 a policy would be unacceptable and likely

10 illegal in the sense that it would facilitate

11 violations of the Organic Food Production Act

12 of 1990. 

13 The subcommittee asked the

14 following question, "Provision one and

15 possible recommendation two is about using an

16 affidavit to supplement a CBI petition. 

17 Comment on whether this is valuable." Under

18 no circumstances should a petitioner be

19 allowed to sign an affidavit stating that its

20 ingredients and processing aids comply with

21 the OFPA, which is, essentially, a proposal to

22 allow manufacturers to regulate themselves. 
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1 Such a provision would prevent NOSB members

2 from fulfilling their legal responsibilities

3 under OFPA. 

4 Manufacturers are allowed to

5 police themselves by the FDA, which allows

6 manufacturers to make their own determination

7 regarding the safety of new food additives

8 called the GRAS system. This system has come

9 under heavy criticism, rightfully so, from the

10 Government Accountability Office, the Pew

11 Trust, and the media. 

12 The organic system was designed to

13 offer an alternative where independent panels,

14 the NOSB, independent scientists, the

15 technical reviewers, and public collaborate on

16 determining whether ingredients, additives,

17 and inputs are appropriate in food production

18 and processing. Allowing manufacturers to

19 sign affidavits would be asking them to

20 essentially perform their own technical

21 reviews, which is entirely unacceptable both

22 in the terms of OFPA and the consumer
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1 confidence in the organic label.

2 The subcommittee also asked,

3 "Should procedures, such as the

4 confidentiality agreement, be developed that

5 would allow NOSB but not the public to see any

6 CBI?" The Cornucopia Institute believes that

7 this would be unacceptable for several

8 reasons. First, the NOSB, which is not a

9 scientific body, benefits from public input. 

10 NOSB members depend on research and a

11 diversity of opinion from professionals in the

12 organic community to help them in their

13 decision-making process. If certain

14 information is withheld from the public, it

15 weakens NOSB's abilities to solicit and

16 consider public input from the public. 

17 We oppose the proposal to

18 introduce confidentiality agreements designed

19 to keep the public in the dark. Second, the

20 NOSB members need to be able to speak freely

21 and discussions during public meetings must be

22 uninhibited. It would be impossible for NOSB
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1 members to discuss a petition if they have

2 information that is confidential and protected

3 from public disclosure and could potentially

4 open up these volunteers or the USDA to civil

5 action if confidentiality is inadvertently

6 breached.

7 For these reasons, Cornucopia

8 supports recommendation one. Possible

9 recommendation two appears to be an attempt to

10 keep the NOSB and/or the public in the dark. 

11 We need to move towards more transparency, not

12 more secrecy. Thank you. 

13 CHAIRPERSON STONE: Thank you. 

14 Questions from the Board? John? 

15 MEMBER FOSTER: What's the source

16 of the information you're drawing, you're

17 commenting on here? 

18 MS. HALL: It's Cornucopia

19 Institute. Okay? Okay. 

20 CHAIRPERSON STONE: All right. 

21 Thank you very much. 

22 MS. HALL: Thank you very much. 
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1 Appreciate it. 

2 CHAIRPERSON STONE: Anthony

3 Boutard? I hope I'm pronouncing that at least

4 close enough for you to recognize it. 

5 MR. BOUTARD: Precisely. Thank

6 you. Good afternoon. My name is Anthony

7 Boutard. I'm a certified organic farmer here

8 in the Willamette Valley, about 35 miles due

9 west of here in Gaston, Oregon. And I am part

10 of the extended voice of Cornucopia this

11 afternoon, so I'll be reading some prepared

12 remarks.

13 I'm going to be, I'm commenting on

14 the Materials Subcommittee discussion document

15 on confidential business information. The

16 Organic Foods Production Act of 1990 specifies

17 that materials may only be added to organic

18 foods or to the National List if certain

19 criteria are met. The NOSB is not able to

20 make an informed decision whether a material

21 meets these criteria if critical information

22 is missing. I think this is really important
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1 stuff, and this is from the heart.

2 The only acceptable recommendation

3 in terms of ensuring that the NOSB decisions

4 are in compliance with the federal organic law

5 is proposed recommendation number one, and it

6 should be right there up there in the front

7 for you when you make your decisions.

8 Information necessary to make an

9 informed decision based on OFPA's -- I hate

10 those acronyms -- criteria includes the full

11 list of ingredients, sub-ingredients,

12 processing aids, manufacturing processes, and

13 complete disclosure of all known human and

14 health environmental impacts. OFPA

15 specifically states that NOSB must work with

16 manufacturers to obtain a full list of

17 ingredients of petitioned materials. OFPA

18 also states that materials cannot be added to

19 National List if they're harmful to human

20 health or the environment. The only way to

21 determine whether a material is harmful to

22 health or to the environment is by considering
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1 all the available data, including knowing

2 which processing aids are used and having

3 access to results from all safety studies, and

4 I say this, once again, from my heart as a

5 scientist.

6 Therefore, petitioners should not

7 be able to withhold any information regarding

8 processing aids or studies on human health

9 effects or environmental impacts. The

10 discussion document mentions the Trade Secrets

11 Act, but it is important to note that OFPA is

12 not subordinate to the Trade Secrets Act, nor

13 does it state that any information necessary

14 to carry out the requirements of OFPA is

15 exempt under the Trade Secrets Act. Clearly,

16 the Trade Secrets Act does not supercede OFPA

17 or the responsibility of the NOSB to carry out

18 their responsibilities. 

19 Participation in the organic

20 industry is voluntary. If a manufacture is

21 unwilling to share information about

22 ingredients, processing aids, or human
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1 health/environmental impacts to protect trade

2 secrets, the USDA is under no obligation to

3 make an exception for such manufacturers. 

4 Manufacturers who wish to keep the public in

5 the dark about their ingredients and

6 processing aids can sell their products in

7 conventional food stream. They can also apply

8 for patent protection if they have a truly

9 unique product. 

10 The organic label is an

11 alternative to conventional foods, an

12 alternative food system marked by transparency

13 and careful scrutiny. Manufacturers cannot

14 have it both ways. Transparency is a

15 prerequisite to participation in the organic

16 food system. And that includes me, too, as an

17 organic farmer. I can't go to Tilth and tell

18 them, well, you know, some of this stuff I

19 like to keep under my wings because I, you

20 know, but it is organic. That transparency

21 should carry through the system from the

22 farmer all the way up to the processor.
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1 Any petition with ingredients or

2 processing aids with human

3 health/environmental impact withheld as

4 confidential should automatically be sent back

5 to the petitioner by the NOP without wasting

6 the time of the NOSB. And I hope I haven't

7 wasted your time this afternoon. Thank you. 

8 Good day. 

9 CHAIRPERSON STONE: Thank you. 

10 Any -- we'll take that slip of the tongue. It

11 happens all the time. Any questions? All

12 right. Thank you very much. Kathy Felch? 

13 Kathy is here. Pam Larry? I think it's not

14 Larry Pam, but if there's a Larry Pam we got

15 it backwards. Very good. Jennifer

16 Forthmuller will be on deck. If you'd state

17 your name and relationship, please.

18 MS. LARRY: Sure. My name is Pam

19 Larry, and I am a grandmother from Chico,

20 California, and my business card says I am the

21 initial instigator and chief rabble-rouser for

22 Prop 37, the California ballot initiative to
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1 label genetically-engineered foods. This is

2 the first time I've been to the National

3 Organic Standard Board meeting. I tried to

4 come the last two times but was very busy with

5 the campaigning stuff. Even though we did not

6 prevail at the ballot, I can tell you that the

7 movement to label genetically-engineered foods

8 has increased exponentially around the

9 country. 

10 I come here representing myself,

11 the people of California. I'm also a member

12 of a nationwide coalition. I do not speak for

13 them, but I have talked to many of them and I

14 want to share with you some of the things that

15 are concerns.

16 I was very happy to see that OTA

17 had done a study on, a survey on confidence in

18 organics, but I'm wanting to know if people

19 know what the organic symbol means because I

20 have learned quite a bit today and I can tell

21 you that I trust the organic seal a lot less

22 after having been here.
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1 So what does it mean here? It

2 means a lot, and it seems like it's a

3 constantly moving target. I can tell you what

4 it means out in the field, which is what I

5 call the general public that I come in contact

6 with, hundreds and thousands of mothers and

7 fathers and grandmothers and grandfathers. 

8 It's a purity, it's a purity of food. They

9 don't think that there are antibiotics or

10 genetically-engineered stuff or pesticides or

11 chemicals or synthetic stuff are in there. 

12 They think natural food is organic. So, you

13 know, their concept of organic is nothing what

14 it is. And I can tell you that if they knew

15 they would be even less trustful than they are

16 now. And I worry about that because I would

17 like to see there be integrity in the seal.

18 I'm asked constantly during the

19 campaign and I continue to be asked by moms,

20 "Well, if I buy organic food, I'm safe, right? 

21 I know that that means that there's no

22 genetically-engineered products in there." 
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1 And at the beginning of my journey down this

2 rabbit hole, I would have said yes. But now

3 I cannot answer them truthfully that way.

4 What I have to say to them is that

5 if you buy USDA certified organic, you've got

6 a lot more chance of there not being GMOs, of

7 it not being contaminated. If you buy

8 products that are Non-GMO Project certified,

9 you have the knowledge that there's 0.9

10 percent or less in there. But just because

11 you buy something organic does not mean it

12 doesn't have genetically-engineered products

13 in it, and I think that's the little secret

14 that I don't hear talked about a whole lot. 

15 Albert Strauss showed the chart up

16 there earlier today. I've spoken with farmers

17 in Jackson County who grow chard and who have

18 plowed under their organic seed chard

19 businesses because they are afraid that their

20 product is contaminated with Syngenta's sugar

21 beet stuff. I don't know anymore. I'm

22 considering not even buying chard anymore or
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1 table beets because I don't know what's even

2 in my own area of Bute County because we grow

3 a lot of sugar beets there. I no longer eat

4 corn because I don't trust that it's not

5 contaminated. 

6 I would like to trust the USDA

7 organic symbol. I would like to be able to

8 tell other people to trust it. And we count

9 on you folks to establish that gold standard

10 that I've heard about so much here before. 

11 Along those lines -- oh, my God,

12 four minutes. Okay. So AC 21, I would like

13 to please say that we do not, I have not

14 talked to one person who thinks that just

15 offering farmers insurance is a good idea. 

16 Organic farmers must be protected. You must

17 hold a line, or you're going to be talking

18 about the same kind of stuff to clean up the

19 mess that I've been hearing about today with

20 the antibiotics in five years. Please,

21 establish the standard and then get it to zero

22 tolerance. Thank you. 
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1 CHAIRPERSON STONE: Thank you. 

2 Any questions? Jay? 

3 MEMBER FELDMAN: Hi. Thanks for

4 coming. 

5 MS. LARRY: Yes. 

6 MEMBER FELDMAN: One, thanks for

7 your good work on Proposition 35. 

8 MS. LARRY: Seven.

9 MEMBER FELDMAN: Thirty-seven. I

10 saw the statistics on the level of involvement

11 from different groups, demographic groups of

12 people, and the level of Hispanic population

13 involvement in voting for, the level of

14 African-American community is extraordinarily

15 high. We tend not to appreciate that when we

16 talk about people in different communities

17 concern about food safety and purity, but it's

18 even higher than the percentage of white

19 educated women. So we have, we have a

20 community out there that cares about their

21 food and, certainly, your work has shown that.

22 What I'm interested in asking you
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1 is about engaging the public more in this

2 process as a process that takes what is a very

3 sound and protective statute, which I hope you

4 have a chance to sit down and read, the

5 Organic Foods Production Act. It's a really

6 interesting law but, without public

7 involvement, cannot achieve the spirit and

8 intent because, like any law, it can be

9 overrun by special interests that want a piece

10 of the pie, from an economic perspective, but

11 don't necessarily buy into the core values.

12 So my question to you is, doing

13 what you did in terms of organizing people in

14 different demographic groups that care about

15 what's in their food, what would you see as

16 the opportunity to engage the public more in

17 the process that we're engaged in here? 

18 Because I can tell you if you were sitting at

19 a meeting like this of conventional food

20 producers growing food in the chemical21 intensive industrial, you know, side of the

22 equation, the story is much, much, much worse. 
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1 So we need the help of people like yourself

2 and your advice to this board as to how to

3 better reach out and engage the public so that

4 the standards that are in this statute, which

5 are incredible standards of protection of

6 human health, biodiversity, beneficial

7 organisms, air, water, land, etcetera, how do

8 we engage the public so that what you just

9 communicated to us is really felt by this

10 board so that it can, you know, adopt the

11 right positions that enable it to grow? 

12 Because we want, everybody here wants it to

13 grow. Everybody that's sitting at this table

14 wants it to grow -- 

15 MS. LARRY: I believe that. 

16 MEMBER FELDMAN: -- and are

17 bringing their own perspective to that. But

18 we can't do it without your involvement and

19 kind of the people that you have worked with

20 so effectively. 

21 MS. LARRY: I would suggest you

22 have town hall meetings where you get out --
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1 I know it sounds like you guys work

2 tremendously hard and when would you fit it

3 into your schedule. I get it. And I also

4 want to really express that I appreciate all

5 of your very difficult, your hard work and

6 your commitment to this. And I know that many

7 of us have different definitions of stuff, and

8 I want to honor that. 

9 But town hall meetings. I think

10 it's really important to not just do surveys

11 because surveys, you're asking the questions,

12 you're not listening to people and allowing

13 them to just speak from their perspective

14 without your direction. This is not to say

15 never to do a survey. I'm just saying there

16 are two ways of communicating. One, you only

17 give -- I never can answer a survey because

18 it's never my answer. You know, you only give

19 me certain options or something like that. So

20 get out and meet and talk to the people on the

21 ground. You know, internet activism is really

22 important. It's a crucial piece of what we
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1 do, but not everybody is on the internet. A 

2 lot of people aren't. 

3 There's a huge gap between what

4 exists -- again, I've been working in this,

5 like, double full time for two years now, and

6 I still have a lot to learn. A mother doesn't

7 have time to go out and learn, like I call it

8 a college-level course of trying to figure out

9 what's in our food supply. And so we count on

10 things like this symbol to be that gold

11 standard, not just, oh, well, you know, at

12 least it's not as bad as conventional. That's

13 the option that I'm seeing right now with USDA

14 certified organic, and I would like to be able

15 to go into my store and know that, when I pick

16 this item up, I'm not going to, you know, in

17 the future, we've got to figure out

18 definitions. You know, RNAI, DSRNA, you know,

19 the nanotechnology thing. Thank God you're at

20 least looking at that. Synthetic biology. 

21 What are we doing to our food, and when did it

22 become elitist to want real food? I mean, I
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1 don't get that part.

2 But I would do a town hall meeting

3 or five in each county. I'm just saying, I

4 realize that that's cost prohibitive, but

5 really listening to people. 

6 MEMBER FELDMAN: Thank you. 

7 CHAIRPERSON STONE: Nick? 

8 MEMBER MARAVELL: Yes, I want to

9 thank you for your wonderful efforts and the

10 fact that those efforts have spawned more

11 efforts in other states. You told us a little

12 bit about your education, your evolution about

13 finding out about GMOs and somewhat of their

14 use or non-use in organic products. But you

15 stopped short of saying what happens now when

16 you tell those consumers that, well, it's not

17 exactly like I thought it was with USDA

18 organic? What is their reaction now? What is

19 it that they are saying to you? 

20 MS. LARRY: Well, first of all, I

21 look at their faces, okay, and their faces,

22 they're shocked. They have trusted this
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1 symbol, and they feel betrayed. I mean, I

2 don't mean to be overly dramatic here. I am

3 an Italian Leo, so I tend towards the

4 dramatic. But I'm just saying they feel

5 betrayed, and many of them are angry. So

6 that's what happens when you feel betrayed. 

7 You get angry.

8 Now, many of them are reasonable

9 people, and they want to at least have

10 something better than conventional, so they

11 may still buy. But I am concerned that, as

12 time goes on and the erosion of the trust, why

13 would somebody go out and, if all they have is

14 an option to get organic food is to go to

15 Whole Foods, why would they be willing to

16 spend three times more on something and then

17 find out it's very little, there's very little

18 difference between it and conventional? And

19 that's kind of what's starting to happen more

20 and more is different things are allowed in 

21 or, like, I'm finding out, I had no clue

22 antibiotics were on apples or pears. I'm not
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1 going to eat them anymore unless I ask and I

2 find out directly from the producer.

3 So that's what happens, and

4 they're getting angry and they're starting to

5 really get angry. And the good news is is

6 they're starting to get out on the streets

7 more. Mothers who voted no on Prop 37 because

8 they listened and they believed the PR,

9 they're now so angry they're becoming leaders

10 in their areas in California to fight this.

11 And I want to know why it is that moms who are

12 busy just trying to raise their family and

13 have healthy families have to do this kind of

14 work on top of everything else? 

15 You know, I would like to see,

16 we've got to hold the line at some point. At

17 some point, you're going to have the same

18 kinds of discussions with GMOs that I've been

19 hearing about with antibiotics today. The

20 sooner the line is drawn the less difficult

21 and complicated it's going to be to remedy on

22 the other side. You're not going to have to
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1 do a whole bunch of clean-up along with

2 establishing new protocols if you establish

3 protocols now and stick with them. 

4 And, really, I mean, 0.9 percent

5 is fine, but, I mean, I think that truth is a

6 very difficult thing for us to grasp

7 sometimes, but what is this for? And maybe we

8 just have to let go of some products as being

9 organic, and that's the truth because if we

10 don't tell the truth about the corn -- and the

11 corn is contaminated. It just is. There's no

12 amount of hiding, and I know we want to

13 protect farmers and I want to protect farmers

14 because I love farmers. Some of my best

15 friends are farmers. But we have to tell the

16 truth because if we don't tell the truth about

17 this now then what else is going to be so

18 contaminated -- and I realize that this board

19 is not trying to sneak things in, okay? I

20 don't believe that at all. But I do believe

21 that there are interests out there that are,

22 and the longer this board takes to fight, you
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1 know, draw a very strong line, the more you

2 leave yourselves open to being seen as

3 colluding, whether you are or not. Does that

4 make sense? I mean, not that I would agree

5 with it, but I'm just saying, you know, I'm

6 just saying. 

7 CHAIRPERSON STONE: Thank you very

8 much for saying it. 

9 MS. LARRY: Sure. Okay. 

10 CHAIRPERSON STONE: We were

11 listening very closely. I was watching the

12 Board members. Any other questions? Great. 

13 Thank you --

14 MS. LARRY: Thank you so very much

15 for listening. 

16 CHAIRPERSON STONE: Thank you for

17 being here. Jennifer Forthmuller? I didn't

18 see any movement a minute ago on there. Is

19 there anyone that got an email that was

20 scheduled to be here today that wasn't here

21 when your name was called? Okay. 

22 So, Board members, there were
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1 several no-shows today. I let the

2 conversation run because we had the

3 opportunity. I think it was a great

4 opportunity to ask questions and allow some

5 positioning of the questions, which took a

6 fair bit of time. So tomorrow we may not have

7 that luxury. We heard a lot. We were able to

8 ask a lot of questions on different topics

9 today that we'll have to be a little more

10 reserved tomorrow. 

11 So I just sort of put that out

12 there. If you acted like I was in a bad mood

13 tomorrow, it's not that. It's just that it's

14 a time factor here.

15 So we're scheduled to be back at

16 8:00 in the morning. Is there any other --

17 Michelle, do we have anything you need to let

18 us know? So I appreciate all the input today,

19 thank the audience. The audience, again,

20 appreciate your participation. If you were

21 one of those that got to stand here longer and

22 I cut you off tomorrow, again, it's not
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1 personal. It's I'm cutting the audience off,

2 as well as Board members, depending on how the

3 schedule unfolds. 

4 So thank you. We will recess

5 until tomorrow morning at 8:00. 

6 (Whereupon, the above-entitled

7 matter went off the record at 4:54 p.m.)

8

9

10

11

12

13

14

15

16

17

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32:22 34:14,19,20

35:9 37:18 40:18

41:20 45:7 46:3

50:16,19 51:5,8

62:3 67:9 71:12

93:18,19 114:16

115:9 122:6 126:3

126:6,8 127:12,14

135:14 146:21

173:6 209:15,16

221:1,1,1,2 234:9

236:15 245:22,22

246:6,13 261:20

261:22 262:14,15

274:10 275:18,19

340:12 341:3,4,15

341:16 346:7

362:18,18 364:6

years 6:14,15 7:1

34:1,2 52:21 53:9

58:22 70:7 72:7

82:1 88:12 117:5

135:14,15,15

143:12 161:14

170:18,19 174:8

175:14 186:9

187:13 206:7,13

214:14 219:6

244:16,20 245:10

245:20 246:2,2

247:19 251:16

256:13 260:7,9

262:21 263:1,17

265:3 267:7

268:14 272:7,14

272:15 276:9

278:15 359:19

365:22 366:14

369:3,8,9 385:20

390:5

year's 358:2

year-round 40:16

336:13

yeast 338:19

339:15

Yelena 160:6,7

yellow 21:1,3

yesterday 31:20

59:17 91:22

196:10 211:4

221:9 236:1

261:10 267:19

273:10,13,18

yields 232:11

yogurt 161:5,6

young 31:21 32:1,6

32:9,22

Z

Zea 1:21 3:10 7:8

65:14 73:7,19

149:10 159:2

175:17 247:11

248:11 282:8

283:6 284:6 296:2

323:20 326:18

331:19 337:7

342:13,21 360:4

Zern 160:17 205:20

zero 127:19 236:16

328:8 385:21

zinc 242:3 243:13

ziram 113:17

Zirkle 11:11

zones 348:18

$

$1 35:3

$100 231:21

0

0.1 166:22

0.35 213:2

0.5 363:4 365:14

367:1

0.9 162:7 363:1,3

365:8,19 384:9

394:4

08 339:2 352:13

1

1 26:9,13,17 27:1,4

27:10 28:1,7,15

28:18,21 29:19

30:13 31:1

1st 45:4

1,000 255:6

1,500 74:5 142:5

1:00 204:18

1:05 204:22 205:2

10,000 50:1 67:16

10:18 136:17

10:30 136:13,15,18

100-percent 19:13

161:10

101 49:21

11 162:5 166:21

212:15 337:10

11th 21:21 23:17

11:50 204:21

12 34:20 202:7

262:21 342:2

13 120:11

133 34:4

14 129:13

142 100:14

15 93:1,11 138:1,2
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206:7 207:13

244:16

15-minute 283:8

150 19:18 268:14

16 129:5

17 129:5 207:13,15

221:2

17,000 98:15 99:8

17,025 98:15 99:8

18 6:14 221:2

1957 127:17

1970s 195:21

1981 8:1

1989 259:10

1990 67:22 88:11

262:7 373:12

377:16

1992 177:19

1995 108:3 197:21

214:11

1997 198:2

2

2 27:3,6,13,18,22

28:3,11,14 29:3,7

29:15,22 30:6,9

30:16 31:3

2,200 103:9 105:4,5

2,280 100:16

2,500 95:6

2:27 283:12

2:30 283:9

2:45 283:10

2:47 283:13

20 88:12 151:1

214:14 275:11

200 139:10 270:10

2002 128:10

2005 139:9 150:20

286:4,8

2006 161:12 212:16

2007 48:11

2008 151:14 152:2

201 49:21

2010 36:6,12 69:21

161:17

2011 34:12 37:1

47:12 140:11

162:3 212:16

352:14

2012 24:11,22

49:16 122:7

261:20 339:3,4

2013 1:8 34:19 50:1

50:14 98:11

339:10

2014 42:9 84:13

87:20 93:13

117:13 118:13,17

121:8,11,15,17

129:3,12,16,22

134:12 135:2

170:21 208:16

227:2,5 237:21

246:19 257:22

372:15

2015 126:9

2016 77:3 87:1 88:1

117:15 118:10,12

129:11,18 136:3

146:1 180:7

187:13 237:13

2017 88:3 118:10

126:3 127:11

128:20 129:11

136:4

205.501(a)(8) 60:6

205.605 47:6,10

253:14

205.606 42:5

21 146:1 328:16

338:2 342:17,18

343:1,19 344:9

347:20 385:12

21st 87:1 129:16

21's 328:16

22 108:14 343:6

24 3:5 177:22

216:22

25 3:6 98:13 100:15

262:8 275:19

25,000 34:4

26 259:12 271:20

273:2

284 3:10

29th 37:20

3

3rd 44:13

3,000 328:8

3-percent 339:5

30 24:1 30:1 86:12

162:4 167:1 257:7

30,000 238:16

300 177:19

304 3:13

31 260:9 263:16

32 341:20

320 3:17

337 3:20

35 377:8 386:7

37 381:22 393:7

38 139:10

397 3:22

4

4 3:3

4B 171:6

4th 42:9 44:21

4:54 397:7

40 276:9

40-page 198:13

42 11:14

45 137:5,7,16

48 116:4

49,000 139:3

5

5 343:6

5.1 34:19

5:30 283:9 306:19

50 270:11 340:9

50-percent 339:7

500,000 32:20

501(a)(11)(4) 60:15

58 345:14

6

6th 1:11 106:12

6,000 116:4

605 48:7 74:20

120:11

606 48:7 74:21

120:12

65-year-old 273:3

6517 74:22 75:14

6517(c)(1)(B)(I)

285:10

67 3:8 207:14

67.9 207:9,16

69 100:14

7

70 207:9

700 86:18 275:10

8

8:00 1:10 396:16

397:5

8:01 4:2

85 34:3 259:22

9

9 1:8

90 259:22

90s 108:18

921 1:11

93 130:5,7

95 240:19
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 

456

National Organic Standards Board

USDA

04-09-13

Portland, Oregon
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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

 APRIL 10, 2013

 + + + + +

 The National Organic Standards

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

Portland & Executive Tower, 921 Southwest 6th

Avenue, Portland, Oregon, Mac Stone,

Chairperson, presiding.

MEMBERS PRESENT

MAC STONE, Chairperson

HAROLD AUSTIN

CARMELA BECK

COLEHOUR BONDERA

JOSEPH DICKSON

TRACY FAVRE

JAY FELDMAN

JOHN FOSTER

WENDY FULWIDER

NICHOLAS MARAVELL

JEAN RICHARDSON

ZEA SONNABEND

MAC STONE

JENNIFER TAYLOR

FRANCIS THICKE

CALVIN WALKER
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STAFF PRESENT

MILES McEVOY, Deputy Administrator, National 

 Organic Program

MICHELLE ARSENAULT, Advisory Board Specialist

MELISSA BAILEY, Director, Standards Division,

 National Organic Program

LISA BRINES, Standards Division, National 

 Organic Program
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 A G E N D A

Policy Development Subcommittee........ 7

Public Comment......................... 22

Aquaculture Working Group.............. 44

Livestock Subcommittee................. 107

Public Comment......................... 133

Crops Subcommittee..................... 196

Public Comment......................... 317
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1 P R O C E E D I N G S

2 (8:01 a.m.)

3 CHAIRMAN STONE: I've got eight

4 o'clock. We'll get the meeting settled down

5 and we'll get to work this morning. We have

6 a lot of information to exchange amongst

7 ourselves in the room, so I want to have as

8 much opportunity to do that as we can.

9 Again, thank you all for being

10 here. We have an aggressive agenda. We'll

11 start with policy and then we've got

12 livestock. We'll have a presentation on

13 aquaculture this morning, and the afternoon is

14 dedicated to the Crops Committee, and

15 obviously the tree-fruit conversation will

16 dominate the afternoon.

17 So we want to have as much

18 opportunity for information exchange as

19 possible. This morning, Miles has a little

20 thought for the day, I believe, is what we'll

21 call this. So Miles, if you have a mic up

22 there and thought for the day.
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1 MR. McEVOY: Okay. Good morning,

2 everyone. Oh, we've got a little less people

3 here this morning. People just waking up, but

4 we'll have a poem to share. This is a poem

5 from Marge Piercy. It's called "The Influence

6 Coming Into Play, the Seven of Pentacles."

7 "Under a sky the color of pea

8 soup, she's looking at her work growing away

9 there, actively, thickly like grapevines or

10 pole beans. As things grow in the real world,

11 slowly enough. If you tend them properly, if

12 you mulch, if you water, if you provide birds

13 that eat insects, a home and winter food; if

14 the sun shines and you pick off caterpillars.

15 "If the praying mantis comes and

16 the lady bugs and the bees, then the plants

17 flourish, but at their own internal clock. 

18 Connections are made slowly. Sometimes they

19 grow underground. You cannot tell always by

20 looking what is happening.

21 "More than half a tree is spread

22 out in the soil under your feet. Penetrate
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1 quietly as the earth worm that blows no

2 trumpet. Fight persistently as the creeper

3 that brings down the tree. Spread like the

4 squash plant that overruns the garden. Gnaw

5 in the dark and use the sun to make sugar.

6 "Weave real connections, create

7 real nodes, build real houses. Live a life

8 you can endure. Make love that is loving. 

9 Keep tangling and interweaving and taking more

10 in, a thicket in bramble, wilderness to the

11 outside, but to us, interconnected with rabbit

12 runs and burrows and layers.

13 "Live as if you like yourself and

14 it may happen. Reach out, keep reaching out,

15 keep bringing in. This is how we are going to

16 live for a long time. Not always, for every

17 gardener knows that after the digging, after

18 the planting, after the long season of tending

19 and growth, the harvest comes."

20 CHAIRMAN STONE: Thank you. Very

21 appropriate. Appreciate that. We're going to

22 jump right into the Policy Subcommittee, so
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1 I'll turn the microphone over to Colehour

2 Bondera.

3 Policy Development Subcommittee

4 MEMBER BONDERA: Okay. Thank you

5 very much and good morning to everybody. I

6 hope that this is a good, smooth, easy start

7 to our day. So yeah, I'm the chair of the

8 Policy Development Subcommittee, and we are

9 going to present today a few items. 

10 Let me just briefly talk about

11 what we are and who we are. Like it says on

12 the screen, the members are on the right there

13 of the Subcommittee, and we're trying to

14 provide guidance, clarification and/or

15 proposed standards for operations, policies

16 and procedures.

17 We're the internal subcommittee,

18 and I think that one of our ongoing activities

19 is the content and updates of the policy

20 procedure manual, which is our -- like I was

21 told when I started, is our bible, and I think

22 many people do see it that way. I think that
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1 that's vital, and our new member guide, and

2 then working in collaboration with other

3 subcommittees, where policy issues are

4 unfolding.

5 So today, we're going to be

6 talking about three items, and I guess that

7 frankly, in my slide there on -- with the word

8 "Recommendation" at the top is slightly

9 erroneous since the third one is actually a

10 discussion document.

11 But we're going to talk about the

12 New Member Guide, Public Communications, and

13 new material initiation discussion.

14 Generally speaking, and each of

15 the lead people will in a moment talk about

16 this, the written comments that came in, we

17 received none on the New Member Guide, which

18 is fine. It's for a new member of the NOSB. 

19 So it's really an internal process.

20 And really on the other two items,

21 Public Communications and material initiation

22 discussion document, there were not a lot of
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1 comments. But we can, you know, listen to

2 each of the lead people review those, and then

3 we can listen to the public testimony provided

4 at that time.

5 So I'm going to at this point in

6 time turn it over to our initial one, who is

7 Calvin Reuben Walker on the New Member Guide.

8 MEMBER WALKER: Good morning. 

9 Probably before Colehour sit down, I probably

10 will be finished, so we can move on to other

11 topics. As Colehour mentioned, there was

12 three individuals signed up for oral comments. 

13 One was scheduled for yesterday but did not

14 appear. One is scheduled, I believe, for

15 today, maybe two.

16 So I have a total of about 500

17 slides, if that will be okay. I'm going to

18 try to condense them down, just kidding Wendy. 

19 I condensed them down to four, and as Colehour

20 mentioned, it wasn't a lot. There was no

21 written comments, but I would like to share

22 with you the changes that the Subcommittee
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1 did.

2 (Pause.)

3 MEMBER WALKER: Oh, okay. Well,

4 since I have so many slides I can go through

5 them verbally. The purpose of the New Member

6 Guide is primarily to provide new guidance for

7 the members. As the Vice Chair of the Policy

8 Subcommittee mentioned that it will be a while

9 before we have any new members.

10 But still, we do this on an annual

11 basis, and also another purpose is to help

12 ease the transition of new members. 

13 Personally, I found it helpful. When the

14 program -- when I was appointed to the Board,

15 I found it very helpful to have a New Member

16 Guide.

17 It is updated yearly, and the

18 reasons are for policy changes, subcommittee

19 membership changes, staffing changing and

20 personnel additions. Of the updates, one was

21 in '07. '08 there was two. In '09 there was

22 one update. In 2010, there were one, and last
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1 year was one update. 

2 Next to the last slide. The

3 general changes were one, membership changes. 

4 As you know, we had went from committees to

5 subcommittees. So that was noted in the

6 update.

7 Where we had executive director

8 and Lorraine Coke in the document, we made the

9 modification of our current individual,

10 Michelle Arsenault, where there's an email,

11 and she's our Designated Federal Officer.

12 We've replaced the Terms

13 Committee, it was quite extensive in the

14 document, to subcommittee. We kind of fine15 tuned the Travel section of the document, and

16 we also noted that the listing of Federal

17 Agencies, All, was not in alphabetical order. 

18 So we placed an order to those.

19 And next to the last thing what we

20 did was officers, as you know, changed. Last

21 year at this time it was Dr. Barry Flamm, our

22 chair. Subcommittee changes, so we made those
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1 changes. 

2 Another change we did, but it's

3 still listing all the program personnel and

4 numbers and emails. We didn't use that; we

5 just created the link.

6 Last slide. This is -- oh, it's

7 not. The committee consists of Colehour --

8 (Off record comment.)

9 MEMBER WALKER: Oh, how about

10 that. Next to the last. Yes, that's the one. 

11 The committee members are the chair, Colehour

12 Jordan Bondura, Jay Feldman, John Foster our

13 Vice Chair of the Board, Nick Maravell,

14 Jennifer Taylor and yours truly.

15 That is in essence the changes

16 that we have provided to the New Membership

17 Guide. As we said, there was no written

18 comments and there was two individuals signed

19 up for oral comments we'll get to hear from. 

20 That is it.

21 MEMBER BONDERA: Thank you very

22 much, Calvin. We're going to go ahead and
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1 move on directly to Jennifer presenting to us

2 about Public Communications. Thank you.

3 MEMBER TAYLOR: Good morning. I'm

4 going to talk just a bit about the Public

5 Communications proposal.

6 The National Organic Standards

7 Board recognizes that members have been

8 specifically appointed to the Board to provide

9 advice and counsel to the Secretary concerning

10 policies related to the development of organic

11 standards, and the creation and amendments to

12 the National List.

13 A part of the Board's

14 responsibility is to communicate with the

15 organic community pertaining to the

16 implementation of the Organic Foods Protection

17 Act. The Board must receive and review

18 information from the USDA National Organic

19 Program and other sources during its

20 deliberations.

21 Input from the organic community

22 is valuable in the deliberations of the Board
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1 and the program and the community decision2 making process. So therefore, providing an

3 online mechanism that allows the public to

4 share information between official comment

5 periods will help to facilitate public

6 communication that informs the Board and

7 program deliberation in several ways.

8 So the online system is intended

9 to inform discussions early on in the

10 Materials Policy Review process, reduce the

11 amount of new information coming to the Board

12 and the program late in its deliberations,

13 increase transparency for the Board and the

14 program and the public itself to ensure that

15 everyone has access to the same information in

16 a timely fashion, and to help the Board and

17 the program to become aware of issues that may

18 not be on the work plan, or may not have been

19 generated internal to the program in the

20 Board's process, but are important.

21 The NOSB recommends, then, that

22 the program establish a year-round online
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1 communication mechanism for stakeholders to

2 communicate with the Board and the program on

3 matters of interest and concern. 

4 The recommendation that you'll

5 find in the public document reads "The NOSB

6 proposes amending PPM Section 6, Miscellaneous

7 Policies, page 27, to add a new subcategory,

8 which is listed in italics, `Policy for Public

9 Communication Between NOSB Meetings.'"

10 The NOSB and the program seek

11 Public Communications outside of the Board by

12 annual meetings and public comment periods, to

13 inform the NOSB and the NOP of stakeholders'

14 interest, and to comment on the NOB's and

15 N.O.P.'s work activities year round.

16 It goes on to state the PPM

17 Section 2 adds a phrase to the role of an

18 advisory board specialist to include the

19 following language: "With support from NOP,

20 identify, implement, administer and maintain

21 a year-round Public Communications mechanism,

22 Internet and other means, by which public
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1 feedback can be received, posted and archived

2 online for viewing by the NOSB and the NOP and

3 the public."

4 As a result of the posting and the

5 development of this information, the NOSB

6 received public comment that were very

7 supportive of the idea.

8 All of the comments were

9 supportive of the idea, and the concept of

10 providing a central location for all public

11 communication to the Board and to the program,

12 that would enable and enhance transparency in

13 Public Communications, and provide access to

14 information from the organic community is very

15 important. 

16 So some of the comments that we

17 received, the positive comments were "We

18 support the proposed Public Communications

19 policy. It is important that the members of

20 the NOSB have access to input from the organic

21 community during all stages of its

22 deliberations."
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1 Another comment. "We believe that

2 the development of a year-round online

3 communication mechanism would enable

4 thoughtful feedback on issues, provide an

5 opportunity to identify new or emerging

6 issues, prioritize issues and share timely

7 developments in thinking." That's also how we

8 were thinking about the idea as well.

9 Other comments include "We

10 specifically like the proposed policy for

11 Public Communications between the NOSB

12 meeting, voted by the Policy Development

13 Subcommittee. We think that a year-round

14 public communication mechanism sponsored by

15 the Board is preferable and more transparent. 

16 We appreciate this recommendation."

17 The Public Communications proposal 

18 in itself is seeking to establish the

19 development of a year-round online

20 communication mechanism for all stakeholders

21 to communicate with the NOSB and with the

22 program on matters of interest and concern.
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1 The Subcommittee vote on the

2 proposal was done on, excuse me, on January

3 22nd, and six of the members of the

4 Subcommittee voted to approve the proposal and

5 the recommendation, and two were absent. 

6 Thank you.

7 MEMBER BONDERA: Thank you very

8 much. At this point in time, I would like to

9 have Jay Feldman talk about the discussion

10 document on material initiation that we had

11 put forth, that I think he will be able to

12 talk about the public comment that came in on

13 that after he introduces it. So thank you. 

14 Jay.

15 MEMBER FELDMAN: Thank you

16 Colehour. So thank you. Okay. This is a

17 discussion document on materials review

18 initiation.

19 The statutory basis for work in

20 this area stems from OFPA 6518(n), which

21 states the Board shall establish procedures

22 under which persons may petition the Board,
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1 for purposes of evaluating substances for

2 inclusion on the National List.

3 This issue is addressed in the

4 policy and procedures manual, and which says

5 the PPM policy dealing with NOP requests for

6 modified or new standards, which we call the

7 NOB-N.O.P. collaboration, reads as follows:

8 "Recommendation for modification

9 of existing standards or new standards. The

10 NOSB will use the decision-making procedures

11 outline in Section 8 to justify modifying

12 existing standards or proposing new standards. 

13 The NOP may request that the NOSB develop

14 recommendations for new or existing standards.

15 "The request should be in writing,

16 and should include a statement of the problem

17 to be addressed, background including the

18 current policy or situation, statutory or

19 regulatory authority, legal situation, desired

20 time frame for receiving the recommendation. 

21 The request will be posted on the NOP

22 website."
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1 The manual goes on to say "The

2 committee work plan arises out of these main

3 situations, items committed or assigned to a

4 subcommittee by the Board during an official

5 session, items that are reviewed by a

6 subcommittee on a regular basis, such as a

7 materials sunset review, for petitions

8 submitted by members of the public, requests

9 or suggestions from the National Organic

10 Program such as clarifications on a particular

11 issue or guidance on enforcement, proposals

12 stemming from the Subcommittee members'

13 contact with the organic community. 

14 So the purpose of this discussion

15 document, four points. Clarify whether the

16 policy on NOB-N.O.P. collaboration covers

17 materials review.

18 Clarify whether NOSB initiated

19 proposals arising from contacts with the

20 community may include materials review. 

21 Clarify the process used by the NOSB in

22 initiating review in these cases, and to
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1 receive feedback on priority of petitions.

2 We received seven comments on

3 this, and we may hear that we received more,

4 if my work from yesterday is any indication. 

5 But I hope I covered them all. There were

6 seven comments on the proposal. Wolfe,

7 DiMatteo & Associates, OTA, Hain Celestial

8 Group, White Wave and California Natural

9 Products all objected to considering the

10 issue, but at the same time offered comments.

11 Beyond Pesticides and Cornucopia

12 did not object to considering the issue and

13 offered comments. All commenters agreed that

14 all materials issues should use the public

15 petition process.

16 All except Wolf DiMatteo said that

17 the NOSB-N.O.P. collaboration process covers

18 materials review, and Wolf DiMatteo said to

19 stretch the interpretation of the NOSB-N.O.P.

20 collaboration section of the PPM, as has been

21 suggested in this discussion document, would

22 not be in the interest of the stakeholders,
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1 who through OFPA, are the persons that may

2 petition the Board regarding the National

3 List. 

4 And then no one objected to the

5 current priority-setting process. Thank you.

6 MEMBER BONDERA: Yeah. I think

7 that that wraps us up in terms of where our

8 Subcommittee worked and what we did. I'm

9 going to pass it back to our Chairman.

10 Public Comment/Policy Subcommittee

11 CHAIRMAN STONE: Okay. We have

12 two people signed up for public comment. 

13 First up is Sophie Sherman-Burton, and on deck

14 will be Steve Connor.

15 Good morning, and just if you're

16 not familiar, some of you weren't here

17 yesterday, it's your first time. There's a

18 little green light. When it goes yellow,

19 Michelle, that means you have like one minute

20 or something? Then when it goes red, it makes

21 an obnoxious beep.

22 MS. SHERMAN-BURTON: Thank you.
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1 CHAIRMAN STONE: Thank you, and

2 welcome for being here.

3 MS. SHERMAN-BURTON: So my name is

4 Sophie, and I'm a member of the Cornucopia

5 Institute, and here today as a citizen

6 lobbyist.

7 I just wanted to comment before I

8 begin that I am really concerned about the use

9 of antibiotics in our orchards, not just

10 because of residues but because of the medical

11 implications as well.

12 So the Cornucopia Institute

13 supports the proposal to establish a year14 round online communications mechanism, to

15 facilitate communication between organic

16 stakeholders and NOB and N.O.P. 

17 The ability to communicate year18 round will benefit the NOB and the organic

19 community as a whole. Thank you for this

20 proposal.

21 We strongly urge the N.O.P. and

22 NOB to ensure that this mechanism will not
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1 become a substitute for any of the other

2 vehicles for public announcement and

3 participation that are already in place.

4 However, Cornucopia believes it is

5 unrealistic to expect NOB members, who are

6 busy enough volunteers as it is, to log on to

7 an online forum on a regular basis, to

8 ascertain if there are any noteworthy recent

9 postings.

10 Therefore, we suggest a daily

11 digest email be sent to NOB members' email

12 addresses, as well as to interested public

13 stakeholders. This will allow the proposed

14 forum to become a means for NOB members to

15 keep a pulse on the organic community, without

16 becoming overwhelmed with additional

17 responsibilities for logging on or reading

18 comments.

19 Cornucopia has some additional

20 suggestions for maximizing public input. 

21 Cornucopia is concerned with the short time

22 frame for submitting comments to NOB
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1 discussion documents and proposals. For the

2 Fall 2012 meeting, the public was given 25

3 days to comment.

4 For the Spring 2013 meeting, there

5 were 22 days between the public announcements

6 to the organic community and the due date for

7 comment.

8 One way to lengthen the time frame

9 for submitting comments is by posting

10 discussion documents as they become available,

11 rather than waiting for the semi-annual

12 meeting notice, using the proposed online

13 communication mechanism and using the N.O.P.

14 Insider to alert the public.

15 Recent discussion documents have

16 often been long, detailed and highly technical

17 papers. These take time to read, research and

18 analyze, and 30 days or 22 days, as was

19 recently the case, is simply not enough to

20 adequately address these extensive documents.

21 Some of these discussion documents

22 were finalized prior to the agenda posting,
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1 sometimes weeks ahead of time. Since it is a

2 discussion document, often with a long list of

3 questions that the NOB Subcommittee seeks

4 public input on, it would be advantageous for

5 the public to have access to these documents

6 as they become available.

7 For example, the discussion

8 document on GMOs and seed purity was first

9 posted prior to the Fall 2012 meeting. The

10 same discussion and questions were reposted

11 for the Spring 2013 meeting, but the public

12 was not notified that this was forthcoming.

13 The purpose for the reposting was

14 to gather additional input from organic seed

15 producers and handlers. If additional input

16 is desired on a discussion document, the

17 document could be immediately posted.

18 This would allow discussion within

19 the organic community, and allow time for the 

20 input the NOSB is seeking. We would also

21 suggest that the deadline for commenting on

22 discussion documents be lengthened to at least
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1 30 days past the date of the meeting. Thank

2 you for considering Cornucopia's comments.

3 CHAIRMAN STONE: Thank you. Are

4 there any questions for the presenter?

5 (No response.)

6 CHAIRMAN STONE: All right. Thank

7 you very much. Steve Connor.

8 MR. CONNOR: Hi. My name is Steve

9 Connor, as he already told you. I'm a member

10 of the Cornucopia Institute, and I'm here

11 today as a citizen lobbyist.

12 When I'm not up here outside my

13 comfort zone, I run a scaffold company here in

14 town. I've been eating organics for about the

15 last ten years, and I never get sick anymore. 

16 It's in my interest to uphold the organic

17 policies that we have set forth in the United

18 States. 

19 Cornucopia believes in

20 transparency and maximizing public engagement. 

21 For this reason, we believe the NOSB and the

22 NOP should follow the same procedures as the
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1 public in initiating material review. We can

2 think of no situations where it would be

3 appropriate for a change to the National List

4 to bypass the public petition process.

5 While it's entirely reasonable and

6 appropriate for NOSB members to be proactive

7 and initiate material review, their position

8 on the Board should not enable them to bypass

9 the public petition process, eroding

10 transparency and public participation.

11 We believe the existing

12 prioritization schedule, as outlined in the

13 policy and procedures manual, already

14 adequately ensures that the most important

15 items, petitions to remove materials from the

16 list, or the priority given to materials for

17 which environmental or health concerns exist,

18 be dealt with on an expedited basis.

19 Material review initiated by the

20 NOSB or NOP should be held to the same

21 prioritization schedule. The committee asked

22 for additional comments. Cornucopia would
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1 like the NOSB to develop a policy for the

2 reconsideration of yes votes on material

3 review. 

4 Under Roberts Rules of Order, a

5 member of the NOSB who voted with the majority

6 to, for example, add a material to the

7 National List, but then changes his or her

8 mind after the vote, can offer a motion to put

9 the item back on the agenda.

10 There have been a number of

11 instances in the past when Board members,

12 especially new Board members, voted to approve

13 a material during the meeting, only to

14 discover after the meeting that some of the

15 information that they relied on to make this

16 decision was materially flawed.

17 In such cases, we believe there

18 should be an established mechanism outlined in

19 the PPM for Board members to put the item back

20 on the agenda, and call for a revote at the

21 next meeting. 

22 Cornucopia also encourages the
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1 Policy Development Subcommittee to consider

2 recommending a prioritization schedule for

3 standards development. The NOP currently

4 instructs the NOSB to give priority to

5 petitioned materials.

6 This has led to slow development

7 of standards, including in cases where

8 existing standards needed clarification, such

9 as pasture rule and for the outdoor access for

10 poultry.

11 We believe that the clarification

12 of standards, especially when they involve

13 loopholes being exploited, should be given

14 priority over the development of new

15 standards.

16 Priority should be given to

17 clarification of existing standards, when

18 members of the organic community claim

19 economic harm arising from the lack of clarity

20 on the existing rule.

21 Examples include outdoor space for

22 organic poultry, or the alleged loophole
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1 allowing continual introduction of

2 conventional replacement dairy cattle on

3 organic dairy farms.

4 Development of new standards that

5 are not explicitly required should only be

6 worked on after loopholes have been closed,

7 and after standards required by OFPA, such as

8 peer review, have been adequately dealt with. 

9 Thank you very much. That didn't feel like

10 four minutes.

11 CHAIRMAN STONE: Thank you, Steve. 

12 Is there any questions for the presenter? 

13 Waldo.

14 MR. FOSTER: So a couple of times

15 you mentioned bypassing the petition process,

16 where I'm not seeing anyone wanting to do

17 that. So where are you urging us not to

18 bypass the public petition process, and why is

19 that a concern for you?

20 MR. CONNOR: Well, I'm not

21 necessarily saying that there are, but it's

22 always a good policy to keep aware that we
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1 want to keep the foxes out of the hen houses.

2 CHAIRMAN STONE: Thank you. Okay. 

3 That's it for this session. Mr. Chairman, did

4 you want to proceed with the vote, or are we

5 going to wait until Thursday?

6 MEMBER BONDERA: At this point in

7 time, I think it's -- I would entertain if

8 there's discussion among Board members on

9 these subjects to pursue that. But if there's

10 not, I think that we could move forward with

11 the vote. So I would entertain any

12 discussion. 

13 CHAIRMAN STONE: Any discussion

14 from the Board on these two proposals, New

15 Member Guide or Public Communications? Jay.

16 MEMBER FELDMAN: Excuse me. 

17 Thanks, Mac. Just to say that I'm really

18 pleased at the progress we've made on this

19 whole Public Communications thing.

20 I think it's, it would be

21 incredibly helpful to the public and to the

22 Board and to the program, to have the insights
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1 of the public on an ongoing basis.

2 Yeah, it will be more information,

3 but it will be more timely information to the

4 deliberations of the subcommittees, and less,

5 hopefully less 11th hour sort of decision6 making, where we're getting new information at

7 the last moment, and trying to integrate that

8 into our final decisions.

9 So I don't sense any objection. 

10 I'd like to hear if there is among any of the

11 Board members any objection. But it sounds

12 like there's, this is one of those consensus

13 proposals. I hope I'm correct about that. 

14 Thank you.

15 CHAIRMAN STONE: John.

16 MEMBER FOSTER: So I agree. I

17 think that progress on this has been terrific. 

18 It's a pretty different place now than it was

19 when it started.

20 My one concern I have is some

21 comment came up with a daily digest. I don't

22 know about other people, but I get about 300
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1 emails a day, and I need to really deal with

2 about 250 of them.

3 One more doesn't sound like a lot,

4 but when the content is as significant as this

5 is, it is a lot. So I'd just, I'm not -- I

6 don't want to sign on through this document to

7 a daily email, and that's putting a lot of

8 burden on the program also that we can't count

9 on. But in concept, I like the idea.

10 The other concern I have is that

11 in a small town when you put up a stop sign,

12 that implies that there's going to be people

13 held accountable when they don't use it

14 anymore. Same thing here. If there's

15 information being delivered to Board members

16 on a regular basis, there's going to be lots

17 of opportunity for criticism if we're not

18 reading it every day or every week.

19 That worries me too, just because

20 you have exposure to information. It's going

21 to -- I'm sensitive to kind of what, to not

22 being able to keep up, all of us keeping up. 
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1 I want to make sure that there's some sort of

2 cushion that we all have, because a lot of,

3 you know, everyone on the Board has their own

4 life, and I want to make sure that we're not

5 going to be -- 

6 Just because someone submits

7 something on Tuesday, that we're all going to

8 be accountable for knowing it on Wednesday. 

9 That's it.

10 CHAIRMAN STONE: All right, thank

11 you, and in our conversation with the program,

12 this isn't like a listserv that's going up

13 next week or something. This is going to take

14 quite a while to determine staffing and

15 capabilities and filtering and all sorts of

16 things that social media has gone through, to

17 protect it and make it a useful tool.

18 So this is, this will be a while,

19 a work in progress, to see what it actually

20 looks and feels like. Miles.

21 MR. McEVOY: Yeah. As I mentioned

22 in the opening remarks, the program is very
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1 supportive of this concept of having an

2 ongoing Public Communications channel, both

3 for the program and for the NOSB. Jenny

4 Tucker, the Associate Deputy Administrator,

5 assures me that we can set this up.

6 But we're going into a little bit

7 of unchartered territory of the actual

8 mechanisms for doing that, if you have some

9 concerns about how much time and resources it

10 will take for us to do it.

11 But we're very excited about the

12 project of getting an ongoing Public

13 Communications system in place. So thanks.

14 CHAIRMAN STONE: Okay. Anything

15 else or proceed with the vote? 

16 (No response.)

17 CHAIRMAN STONE: Okay. I think

18 we'll, just since Francis is brand new, I'm

19 not going to make him be the first vote coming

20 out of the gate. So that puts it over to

21 Colehour. So is there any conflict of

22 interest does anyone have on this
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1 recommendation, or declaration of interest is

2 actually the word.

3 (No response.)

4 CHAIRMAN STONE: Seeing none, and

5 again, to those in the audience, this is

6 discussed at the Subcommittee level.

7 I just want to make sure that as

8 we get to the actual voting, if any member has

9 had thoughts or something that's arisen or

10 changed since the Subcommittee conversation

11 started, this is public transparency of that. 

12 So seeing none, Colehour, proceed with the

13 vote.

14 MEMBER BONDERA: You need to have

15 a motion on the table.

16 CHAIRMAN STONE: Oh, that would be

17 good. The recommendation is to accept the

18 revised 2013 -- oh, we're on the

19 communications. Excuse me. Pardon? Start

20 with this one? Okay.

21 The recommendation is to accept

22 the revised 2013 NOSB New Member Guide that is
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1 attached and was presented in principle

2 earlier by Calvin.

3 MEMBER FELDMAN: I so move.

4 CHAIRMAN STONE: Is there a

5 second?

6 MEMBER TAYLOR: I second.

7 CHAIRMAN STONE: Any further

8 discussion?

9 (No response.)

10 CHAIRMAN STONE: Seeing none,

11 we'll start the vote with Colehour?

12 MEMBER BONDERA: Aye.

13 MEMBER FAVRE: Yes.

14 MEMBER SONNABEND: Yes.

15 MEMBER FELDMAN: Yes.

16 MEMBER RICHARDSON: Yes.

17 MEMBER DIXON: Yes.

18 MEMBER FOSTER: Yes.

19 MEMBER WALKER: Yes.

20 MEMBER FULWIDER: Yes.

21 MEMBER AUSTIN: Yes.

22 MEMBER TAYLOR: Yes.
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1 MEMBER MARAVELL: Yes.

2 MEMBER THICKE: Yes.

3 CHAIRMAN STONE: The Chair votes

4 yes. That was unanimous. Thank you very

5 much. We will move to the recommendation on

6 public communication. The recommendation is

7 NOSB proposes amending the PPM Section 6,

8 Miscellaneous Policies, page 27, to add a new

9 subcategory in italics. "Policy for Public

10 Communication Between NOSB Meetings."

11 The NOSB and the NOP seek Public

12 Communications outside of the Board biennial

13 meetings and public comment periods, to inform

14 the NOSB and the NOP of stakeholders'

15 interest, and to comment on the NOSB's and

16 NOP's work activities year-round.

17 PPM Section 2, page 13 adds a

18 phrase to the role of an advisory board

19 specialist to include the following language: 

20 "With support from NOP, identify, implement,

21 administer and maintain a year-round Public

22 Communications mechanism, `Internet and other
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1 means,' by which public feedback can be

2 received, posted and archived online for

3 viewing by the NOSB and the NOP and the

4 public." Is there a motion?

5 MEMBER FELDMAN: I was --

6 CHAIRMAN STONE: Motion by Jay. 

7 Second by Jennifer?

8 MEMBER FELDMAN: No. I was going

9 to second.

10 CHAIRMAN STONE: Motion by

11 Jennifer.

12 MEMBER FELDMAN: I second.

13 CHAIRMAN STONE: Second by Jay. 

14 Any further discussion? John.

15 MEMBER FOSTER: I just want to

16 reiterate what we talked about in the prior

17 meetings and in our session on Monday, that

18 I'm not quite certain that itemizing job

19 descriptions for NOP staff is appropriate in

20 our policy and procedure manual.

21 So I know that's no surprise. I

22 just want to get it out there and make sure
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1 it's part of the transcript.

2 CHAIRMAN STONE: Very good. 

3 Anything else? Colehour?

4 MEMBER BONDERA: Yes, and thank

5 you, John, for your comment. I think it's

6 worthwhile to point out when we did have that

7 discussion on Monday, that the fact is that we

8 are in the process right now of reviewing and

9 revising and updating the PPM.

10 So if it is deferment as you've

11 put forth, that it may not be appropriate

12 and/or we need to modify that, that is in

13 process at this time. 

14 So I just want to make sure that

15 this isn't seen as -- if this is done, then

16 this is the way it is, because that's already

17 up to reconsideration anyway.

18 CHAIRMAN STONE: Any other

19 thoughts, comments from Board members?

20 (No response.)

21 CHAIRMAN STONE: Okay, seeing

22 none, Tracy, we'll start the vote with you.
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1 MEMBER FAVRE: Yes.

2 MEMBER BECK: Yes.

3 MEMBER SONNABEND: Yes.

4 MEMBER FELDMAN: Yes.

5 MEMBER RICHARDSON: Yes.

6 MEMBER DIXON: Yes.

7 MEMBER FOSTER: Yes.

8 MEMBER WALKER: Yes.

9 MEMBER FULWIDER: Yes.

10 MEMBER AUSTIN: Yes.

11 MEMBER TAYLOR: Yes.

12 MEMBER MARAVELL: Yes.

13 MEMBER THICKE: Yes.

14 CHAIRMAN STONE: That appeared to

15 be unanimous as well. I appreciate your work

16 on that.

17 There are several of the

18 materials, and even when we were talking about

19 excluded methods, and there's already several

20 topics that we're discussing that it was

21 considered how this could be useful and give

22 the public more time to help us in our
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1 deliberations. Very good. Very good, Mr.

2 Chairman. We're exactly right on time. Good

3 job with that. Appreciate that.

4 Next, we're going to have a

5 presentation on aquaculture. As Miles said,

6 the program is working on a proposed rule for

7 aquaculture and Melissa said that April 11th,

8 I mean October the 11th, we should have

9 something on that.

10 So but at this time, we have Mr. 

11 George Lockwood and Mr. Sebastian Belle. 

12 George is chairman of the Aquaculture Working

13 Group. Sebastian was part of that group for

14 many years. They've worked tirelessly and

15 diligently for several years with previous

16 boards.

17 We wanted this Board to get up to

18 speed and try to regain some of that

19 institutional knowledge that was lost with the

20 transition of Board members, and be sure the

21 public is aware that this is back on our work

22 plan.
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1 There are several materials being

2 petitioned for both aquatic and animal and

3 plant aquatic production. So the idea is here

4 for these gentlemen to give us a mental

5 picture and get us up to speed of how organic

6 aquaculture may look different than commercial

7 aquaculture, and a little bit about the rule,

8 the proposed recommendation -- the

9 recommendation that's being considered by the

10 program.

11 So with that Mr. Lockwood, we

12 appreciate you and Mr. Belle being here.

13 Aquaculture Working Group

14 MR. LOCKWOOD: Thank you, Mac. My

15 name is George Lockwood. I'm the chair of the

16 Aquaculture Working Group, and joining me is

17 my colleague Sebastian Belle.

18 We greatly appreciate this

19 opportunity to address the National Organic

20 Standards Board today. It's been about five

21 or six years since we last appeared.

22 What I would like to do this
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1 morning is show some slides of typical

2 aquaculture systems, so that you have a better

3 idea as you process our petitions for

4 materials, how these materials will be used. 

5 After the slide show, we will -- I

6 will then have a PowerPoint presentation of

7 how we are, the proposal from the National

8 Organic Standards Board that's now in final

9 rulemaking is substantially different than

10 conventional aquaculture.

11 The Aquaculture Working Group was

12 appointed in 2005 by the program and by the

13 Board. It consists of 12 people. I'll just

14 go quickly through. Sebastian Belle is the

15 Executive Director of the Maine Aquaculture

16 Association.

17 Bob Bullis is a veterinarian. 

18 Ralph Elston is a Ph.D. in Veterinary

19 Medicine. Rebecca Goldburg, when she joined

20 us, was with the Environmental Defense Fund.

21 She's now with the Pew Memorial Trust.

22 Ron Hardy is the Director of the
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1 University of Idaho Aquaculture Program. He

2 is probably the leading feed scientist in

3 aquaculture. John Hargreaves is a scientist

4 formerly with Louisiana State University. 

5 Robert Mayo is a catfish farmer. 

6 Christopher Nelson is an oyster processor. 

7 Bart Reid is a shrimp grower. Albert Tacon is

8 a feed scientist. Kwemena Quagrainie is an

9 economist with Purdue University and I was the

10 chair.

11 As a way of background for

12 aquaculture, the world's capture fisheries are

13 at their limits. One-half of all seafood

14 today is from aquaculture. It's amazing. The

15 last 40 years, 30 years, aquaculture has grown

16 to what it is. Half of the food that's eaten

17 today, seafood eaten today, is farm grown. 

18 That's true in the world and it's true in the

19 United States.

20 Any growth in seafood consumption

21 is going to have to come from aquaculture. 

22 This last year or in 2010, the USDA and the
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1 Health and Human Services agency published

2 dietary guidelines for Americans, recommending

3 increased consumption to at least two servings

4 per week of seafood.

5 Farm seafood is the only major

6 animal protein without USDA organic standards,

7 and contrary to the intent of the Organic Food

8 Production Act for single and consistent USDA

9 standards, we have today salmon, shrimp,

10 tilapia, oysters and perhaps other seafoods

11 that are illegally marketed in the United

12 States with organic claims, and some are not

13 even certified to any standards.

14 The chronology of the development

15 of our standards, in 1999 was the first

16 proposal to this Board for aquaculture

17 standards that simply wouldn't work.

18 Several of us went and asked the

19 Board to postpone consideration of organic

20 standards for aquaculture until the industry

21 and the aquaculture community could come

22 together, which we did at a conference at the
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1 University of Minnesota, where we had people

2 from the organic community and from the

3 aquaculture community that began discussing

4 what organic aquaculture standards might look

5 like.

6 Margaret Wittenberg, who was then

7 a member of NOSB, chaired a group of about 25

8 of us, that in essence did a feasibility

9 study. Would organic aquaculture match, or

10 would aquaculture match organic principles? 

11 In 2003 and 2004, an independent

12 ad hoc group called the National Organic

13 Aquaculture Working Group, came up with a

14 proposed set of standards, and in 2005, was

15 the official appointment of the Aquaculture

16 Working Group to advise the Board and the

17 program on the advancement of such standards.

18 We work closely with the NOSB, and

19 in 2006, we produced our interim final report

20 that excludes mollusks. This was a

21 comprehensive set of standards for

22 aquaculture, except for mollusks. 
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1 In the Spring of 2007, the NOSB

2 recommended that the bulk of what we were

3 recommending but held back for further

4 consideration are matters of feed and

5 facilities, particularly net pens. 

6 In Fall 2008, the second NOSB

7 recommendations came out for feed and for

8 facilities. The only work we had left to do,

9 then, was for bivalves, which we completed in

10 the Spring of 2010. Since then, we've been

11 awaiting final rulemaking, which is beginning

12 now. Sebastian.

13 MR. BELLE: Hello, and thank you

14 for giving us the opportunity. We're going to

15 show you a series of slides of aquaculture

16 operations. We have a problem, which is that

17 we can't show you slides of organic

18 aquaculture operations. 

19 So what we're going to try to do

20 is show you slides of what's out there now,

21 and then George will wrap up with some points

22 about how what is being proposed under the
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1 current standards is really fundamentally

2 different than what's happening right now.

3 But I want to just leave you with

4 one thought. My organization represents 180

5 farms. Most of them are shellfish farms, but

6 we also have finfish farms, and right now we

7 are competing in the marketplace against

8 organic seafood which is being certified under

9 programs overseas, being brought into the

10 United States, and we're competing against it.

11 I can tell you that particularly

12 for our finfish growers, that is very

13 difficult. We are competing against, for

14 example, salmon that's certified in Europe

15 under European standards, which allow for the

16 use of antibiotics.

17 We have not used antibiotics in

18 the State of Maine for eight years. So that

19 gives you an idea of what it means for us as

20 domestic producers, as to whether or not we

21 can get those standards out there and we can

22 begin to start to work towards achieving them.
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1 This is a picture about what's

2 called a polar circle cage. This is kind of

3 a standard finfish technology right now. 

4 There's a net bag that hangs down underneath

5 that, and that's obviously one of the -- this

6 is one of the production methods which has

7 drawn a lot of fire.

8 It's open to the ecosystem. There

9 is a linkage between the ecosystem and the

10 farm itself, and when we developed the

11 standards, we worked very hard to recognize

12 that linkage, and to make sure that the

13 farming methods that were being allowed under

14 organic standards, were those that asked a

15 farmer, that required a farmer to farm in

16 synergy with the ecosystem around that farm,

17 as opposed to trying to dominate that

18 ecosystem.

19 This is a picture of a larger

20 farm. Again, these cages are moored in the

21 ocean. One of the things that we proposed in

22 the standard was a system whereby farms would
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1 be rotated and fallowed between sites. There

2 would be a fallowing period, and that was a

3 very -- we have used that in Maine for now

4 eight years, and it's been a tremendously

5 effective way to break infection cycles.

6 That's one of the reasons we

7 haven't used antibiotics, is by using what is

8 called "all in, all out by year class

9 rotation" and site fallowing.

10 This is the only picture I have of

11 an organic farm currently in this slide, and

12 this is a picture about a farm called Lock

13 Duart in Scotland. The reason I put this in

14 here is this is an example of one of the

15 differences between what is proposed under the

16 organic standards and what a conventional farm

17 would be.

18 This farm is farming at about a

19 tenth of normal density of what a typical,

20 conventional salmon farm would be farming, in

21 terms of the number of fish in a cage.

22 You can -- a typical salmon farm
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1 cage is this, the size of this room or larger. 

2 You can sit as a diver on one side of that

3 cage underwater, and not see the fish on the

4 other side or even in the middle of the cage,

5 in an organically certified farm.

6 This is an example of something

7 called integrated multitrophic aquaculture. 

8 This farm, in the foreground, you see what

9 look like salmon cages. They're actually

10 mussel rafts. So they're using shellfish,

11 aquatic plants and then finfish together, all

12 in one farm. 

13 The way they deploy them is the

14 plants and the shellfish are downstream from

15 the salmon. So the nutrients coming out of

16 the salmon are being recycled by both the

17 aquatic plants and the mussels. 

18 One of the most exciting things

19 that we found in Maine about this is that

20 mussels actually denature a number of the

21 viruses which attack salmon. So we are using

22 mussel rafts around the salmon cages as a
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1 biological fence, to stop wild pathogens

2 coming into the farm.

3 It's a very new technique. It was

4 discovered in Maine actually four years ago,

5 and we're still trialing it. But it appears

6 to be very effective, based on the trials

7 we've had so far.

8 This is a slide of some mussels

9 that are raised on a mussel farm. If you look

10 in the background, there's a steel cage there. 

11 That's the old kind of salmon farms that a

12 number of people are still using. So what

13 we've done is we've taken those old farms,

14 converted them to a mussel farm.

15 You have salmon and mussels being

16 grown side by side, and interestingly, the

17 growth rates we get on our mussels that are

18 located next to a salmon farm are two or three

19 times what they would be if they were located

20 away from the salmon farm.

21 This is kelp. We have a very

22 innovative company in Maine called Ocean
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1 Approved. They were also growing kelp both

2 beside salmon farms and in other areas, and

3 they have just been very successful, and

4 they've built a product which Whole Foods now

5 sells in their frozen -- if you go to the

6 frozen pea, the frozen vegetable section and

7 you look next to it, you'll find Ocean

8 Approved kelp from Maine there.

9 These are some salmon eggs, just

10 so you know what they look like. That's what

11 a typical salmon hatchery looks like. In each

12 of those trays are the eggs from one female. 

13 They're all kept separately and incubated for 

14 period of time, and then they hatch out.

15 That's what a yolk sac larvae

16 looks like. One of the challenges we have in

17 finfish aquaculture, and this is true in

18 shellfish as well, is the period from the

19 hatchery to the nursery is what we call the

20 critical phase, when they're transitioning

21 from internal sources of food to external

22 sources of food.
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1 This is true both for shellfish

2 and finfish, and this is the period in time

3 when the farmer has to be incredibly vigilant,

4 because your mortalities can be very high if

5 you don't do things right.

6 These are small salmon juveniles

7 in the hatchery before they're put out into

8 the ocean. This is what a typical feed looks

9 like. 

10 This is actually catfish feed, but

11 there are a lot of different types of feed,

12 and if you look at the standards that were

13 proposed, I know one of the controversial

14 pieces of it was the use of fish meal and fish

15 oil as ingredients in fish feed.

16 We were lucky to have both Albert

17 Tracon and Ron Hardy on our working group, and

18 they really led us to a different place from

19 a feed formulation and manufacturing point of

20 view.

21 I think that anybody who has ever

22 been -- the standards that are proposed
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1 underneath the NOSB recommendations are by far

2 the strictest in the world, and frankly there

3 are a number of people who have questions, in

4 terms of whether or not they're achievable or

5 not from a feed point of view.

6 But I think it's okay to set the

7 bar high, and see what we as human beings can

8 do from a creative and innovative point of

9 view.

10 This is monitoring of feeding on

11 the farms. One of the things that a lot of

12 people are doing now, not everybody, but a lot

13 of people, but one of the things which is

14 required under the standards is some form of

15 active feed monitoring, and basically that can

16 either be underwater video cameras or a

17 Doppler sonar sensor, which senses whether or

18 not the feed is coming down through the school

19 of fish, and coming out below the school of

20 fish. 

21 If that happens, it automatically

22 cuts the feeding off. The reason for that is
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1 because if feed is wasted on a farm, not only

2 is it expensive for the farmer, but it's also

3 a potential threat to the environment around

4 it. It can discharge nutrients directly into

5 the environment, and enrich the environment

6 around that.

7 If you're a bad farmer, you can

8 exceed the carrying capacity of the ecosystem

9 around the farm and crash the site, as they

10 say. So video monitoring is very important. 

11 We require it in the standards, and it's a

12 technology which has really revolutionized

13 open net pen production.

14 This is another thing that we have

15 in the standards is the requirement for humane

16 slaughter, and this is a place that people

17 sometimes get uncomfortable about. But the

18 reality is on the finfish side of things, for

19 many, many years we were slaughtering fish in

20 what many of us viewed as a very inhumane way.

21 This is what's called a percussive

22 stunner. The fish go through and are hit
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1 basically between the eyes with a bolt, the

2 way a veterinarian would kill a large animal,

3 and it is instantaneous and has been approved

4 by, for example, the British Humane Society as

5 being the way to slaughter and harvest fish.

6 This is again required in the

7 standard. It's not something that everybody

8 uses in the world of conventional, and I think

9 it's great that it's in the standard.

10 That's what we're competing

11 against right now. This is stuff being

12 imported from Scotland and currently sold in

13 the U.S. as organic.

14 MR. LOCKWOOD: This is a trout

15 farm in Idaho. I'll go rather rapidly through

16 these slides. These are raceways, where water

17 enters at the top of the picture and flows out

18 the bottom. Those conical things are how the

19 animals are fed. 

20 Here's a trout farm in Hawaii. 

21 You can see the water cascading down, which

22 produces, puts out fish into the water. 
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1 Here's Jim Pierce. Some of you may know Jim,

2 and you may know that at one time he was --

3 for 12 years he was growing trout in

4 Wisconsin.

5 This is his trout operation. He's

6 crowding the fish towards the camera. This is

7 his wife Cathy feeding some very small fish in

8 this particular tank. 

9 Moving on to oysters, these are

10 oysters being grown in bags held off the sea

11 floor. The tide comes in and brings food, and

12 oysters consume the food and then -- and the

13 water goes out and they get exposed like this.

14 Here's a typical bag. When I've

15 used this system, we would start out with five

16 pounds of oysters and come back a few months

17 later and we have 35 pounds. The bag would be

18 completely filled. We'd have to thin it out

19 and restock it five pounds per oyster.

20 Here's another way of growing bags

21 or growing oysters in suspended bags. This is

22 a very important slide. The picture, the
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1 oysters over at the left are natural oysters. 

2 The ones at the right are triploid. We

3 proscribe triploidy, and but you can see here

4 what technology allows them to grow much

5 faster, and as a consequence, most of the West

6 Coast operations for growing oysters are going

7 to be precluded from organic certification,

8 because triploidy is the standard here.

9 But nevertheless, we have felt

10 that triploidy is a natural way of growing

11 fish and shellfish. 

12 Here are oysters at the seed

13 stage. These oysters are probably a month old

14 or so. They're fed in what are called

15 upwelling silos. In other words, there's a

16 tent to the water.

17 That's cultured algae, that feeds

18 the algae or feeds the oysters. They sit on

19 a screen, in this silo in the water flows from

20 the bottom to the top. Microalgae and

21 microalgae are very important in aquaculture.

22 Here's, I'm going to show a
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1 progression of how cultures, algae is

2 cultured. Here's a library where small

3 cultures now grow into bigger cultures, and

4 finally into operations like this.

5 Now you notice this is a red,

6 pigmented culture. Astaxanthin, which is a

7 required nutrient of salmon, is where they

8 actually get their pigment. We will require

9 that the astaxanthin is used, the organic, and

10 this is a candidate operation.

11 Here's a macroalgae. This is a

12 kelp plant. If you go to the ocean here,

13 you'll see kelp growing. This is about a

14 week-old plant.

15 Here's a full grown kelp plant,

16 macrocystis pyrifera, which grows here on the

17 west coast, and yes, those are salmon swimming

18 with the kelp.

19 Here's a young abalone about two

20 months old. Here is abalone going off to

21 market and a very happy abalone farmer,

22 because he's about to have this dinner. Here
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1 we have catfish. Catfish, until recently, was

2 the biggest aquaculture crop in the United

3 States. 

4 It's declined substantially in

5 recent years due to the increased cost of corn

6 and foreign competition. This is a typical

7 catfish farm, 150 to 200 acres. Catfish is

8 big in Mississippi, Arkansas, and Alabama. 

9 Here's Rob Mayo's catfish farm. This picture

10 shows how waterfowl is attracted to the

11 habitat that's being provided.

12 We estimate there's probably four

13 or five hundred thousand acres of waterfowl

14 habitat that's been developed in the United

15 States for growing catfish. Here's a catfish

16 nursery. These are catfish that are maybe a

17 couple of days old, a little bit older.

18 Here's one taking feed at the

19 surface. Aeration's very important,

20 particularly in hot summer nights, and this is

21 a farmer who's aerating his pond. Harvest

22 time, the catfish are all crowded. They can
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1 be netted, excuse me, I went too fast. 

2 Loading into a transport truck, off to the

3 slaughterhouse.

4 Now we have standards for

5 transporting our livestock, and here is a

6 typical fish hauling truck. Not a very good

7 picture. In the back, you'll see oxygen

8 canisters to keep the oxygen. We have

9 standards for maintaining water quality. 

10 In one case I'm familiar with,

11 fish were hauled for 36 hours in apparatus

12 like this and greatly stressed. We don't want

13 our fish to be stressed. 

14 Here's tilapia. Tilapia is the

15 second-most consumed fish in the world now. 

16 Here's a very innovative tilapia-growing

17 operation. The tanks you see in the

18 foreground are growing fish, and in the

19 background you'll see hydroponics. In this

20 case it's okra. This is at the University of

21 Virgin Islands. The flop here in the

22 background and okra here is in the foreground.
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1 Now obviously the hydroponic crops

2 can't be certified organic, but the fish can. 

3 Here's a conventional high density tilapia

4 operation. We would not allow that high of a

5 density. Another way of growing tilapia, also

6 shrimp.

7 Here's harvesting of tilapia. 

8 Obviously, there's a tour going on. That's

9 what you get in the fish market. Here's a

10 shrimp operation where shrimp are being

11 crowded for harvesting, a number of men in the

12 water pulling a net.

13 Now here's a novel shrimp

14 operation in Florida, which probably will

15 qualify once standards are adopted for growing

16 shrimp. Again, organic shrimp in the United

17 States are common.

18 Here's a recirculating system

19 indoors. This is Bell Aquaculture in Indiana,

20 growing lake perch, and here's how they're

21 killing their fish. This would not be legal

22 or allowed under our proposed standards. 
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1 They're using ice, and as Sebastian mentioned,

2 we have very strict humane slaughter

3 standards, a standard processing line.

4 Now let me go into how our

5 standards are -- the NOSB proposed standards

6 are different. The organic system plan must

7 include an environmental assessment with a lot

8 of detail, and when we proposed this to NOSB,

9 they said you know, we ought to require this

10 for all of our farming operations, fresh as

11 well as aquaculture.

12 We require that aquaculture

13 operations include recycling and consider such

14 things as polyculture and integration. I

15 missed one here. 

16 Origin of aquatic animals. 

17 Triploidy, as I mentioned, is prohibited. 

18 Monosex stocks by chemical and other means are

19 prohibited, and that is a great hardship for

20 the tilapia people, because they want to grow

21 only males.

22 Genetically modified plants and
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1 other excluded methods are prohibited. We

2 require traceability. We require that the

3 animals be under continuous organic

4 management, beginning no later than five

5 percent of their total market weight.

6 There is no way that we could have

7 standards written that would cover the

8 multitude of hatchery techniques that are

9 used. Feed must meet the minimum nutritional

10 needs. Antibiotics, hormones, mammalian and

11 poultry slaughter products are prohibited,

12 along with synthetic solvents and processing

13 feeds.

14 Fish meal and oil may not be

15 sourced where government agencies or FAO

16 report the fishery is over-exploited, has a

17 reduced reproductive capacity, old fish and so

18 forth. Fish must be from regions in the world

19 with the lowest levels of persistent

20 biocumulative toxins, and the fish oil must be

21 treated with activated carbon to remove any

22 toxins.
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1 Now here's a standard that the

2 NOSB has recommended for the use of fish meal,

3 which is to scale down from a maximum of 25

4 percent initially over 12 years to nothing. 

5 This is proposed by NOSB to be on the National

6 List, and the reason for that is there are

7 serious questions, if we can ever get away

8 from some fish meal and fish oil being used in

9 fish.

10 Fish have evolved to eat other

11 fish, in which case the Board would -- when

12 this would come up for sunset review, would be

13 able to continue some sort of use of fish meal

14 without having to go through final rulemaking. 

15 Why don't you take it?

16 MR. BELLE: You can tell we're

17 farmers, not presenters. So in terms of

18 aquatic animal health care, there was a lot of

19 discussion in the group about what the, the

20 way to move forward with this is. It's a

21 field which is moving very rapidly.

22 The veterinary community, the
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1 pathology community has been involved in

2 aquatic animal health for about 100 years,

3 from a diagnostic point of view. The

4 veterinary community, from the point of view

5 of treating disease on farms from a clinical

6 point of view, has only really been involved

7 in aquaculture for somewhere on the order of

8 about 15 or 20 years.

9 So it's a field which is moving

10 very rapidly, evolving very rapidly, and the

11 science behind it is evolving very rapidly. 

12 Again, we have the privilege of having a

13 number of world-recognized experts on the

14 working group when we debated this and went

15 back and forth.

16 We have, we struggled with minimum

17 nutritional needs, and this was really focused

18 around the fish meal/fish oil piece,

19 principally for marine finfish ironically, not

20 salmonids.

21 Marine finfish are species which

22 are not salmon, but they're the marine fish
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1 which are being brought into culture now, and

2 many of their nutritional requirements are not

3 currently known. So we established basically

4 a basis when we said you have to try to

5 minimally meet the nutritional requirements of

6 the animal that you're growing. This is your

7 responsibility as a farmer.

8 We had requirements to monitor,

9 record and maintain water quality, to

10 establish biosecurity measures. That's really

11 one of the places where I think the organic,

12 the proposed organic standards are way ahead

13 of anybody else in the world.

14 The biosecurity measures and the

15 way to go at that are probably some of, I

16 think, the most progressive standards in the

17 world. 

18 And indeed, in many cases, way

19 ahead of some of our terrestrial colleagues,

20 because it particularly -- we don't have the

21 ability to control, in open systems in

22 particular, what our animals are exposed to or
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1 what our plants are exposed to.

2 So we have to think about

3 preventative risk management, as opposed to

4 responsive therapeutic response. The

5 administration of vaccines or other biologics. 

6 If they make it through the system, if you

7 will, those will be allowed.

8 Vaccines have turned out to be

9 tremendously beneficial for our finfish folks. 

10 When the emergence of effective vaccines came

11 out about 10 or 15 years ago, antibiotic use

12 was significantly reduced in many of the farms

13 around the world. We think that vaccines are,

14 as long as they meet the organic principles

15 and standards, they're a good thing.

16 We wanted to employ a lot of non17 therapeutic, non-chemical management methods. 

18 So site rotation, fallowing, biological

19 control and integrated pest management. Those

20 were things that we really emphasized in the

21 standards, and there are a whole series of

22 things that you can't do.
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1 Obviously administer antibiotics,

2 hormones. You can't sell clinically diseased

3 fish. You can't administer synthetic

4 parasites, parasiticides, sorry. You can't

5 administer medications in the absence of

6 illness.

7 Just as an interesting sideline, a

8 lot of people have a misconception about the

9 use of antibiotics in aquaculture. 

10 Antibiotics do not work as a growth promoter

11 for cold-blooded animals. It's just a

12 physiological fact. You can't, in a cold13 blooded animal, administer antibiotics and get

14 them to grow any better, unlike poultry or

15 beef.

16 So even if you wanted to as a

17 farmer, antibiotics are not effective as a

18 growth promoter. And then you can't withhold

19 treatment for illness.

20 MR. LOCKWOOD: Here are living

21 conditions, and we get into containment. We

22 must provide for the adequate exercise and
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1 swimming behavior, minimize potential injury. 

2 Biomass density, it must be appropriate for

3 the animal, and as you saw earlier in one of

4 the slides, organic systems have reduced

5 animal densities.

6 But they're also, you can have,

7 since fish tend to school, you can have too

8 low a density in some cases. We require a

9 predator management plan without the use of

10 lethal measures. 

11 Aquaculture facilities. Pond

12 berms must withstand a 100 year flood. 

13 Effluents must be assimilated between a 25

14 meter distance of the facility. A waste

15 management plan must include recycling. It

16 must have an escape prevention plan.

17 Net pens in public waters must

18 avoid migratory routes of native species, must

19 grow in strains of native species, be spaced

20 from conventional salmon or conventional net

21 pen operations. The control of fallowing must

22 be by physical or biological and not by
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1 chemical means.

2 Nets that are in the water have

3 all sorts of other things that grow on them. 

4 We can't use chemicals to do that. We cannot

5 -- we require the use of multiple species

6 outside the pens for recycling, as you saw on

7 the earlier slides, and for the net pens, we

8 require a conversion period of less than one

9 year or one growing cycle. Earth ponds have

10 a conversion of 36 months if prohibited

11 substances have been applied.

12 The bivalve mollusk standards are

13 very complex in themselves. One of the

14 challenges we had was to prove that we have a

15 managed system. Some bivalves are harvested

16 from the wild, and we certainly don't want

17 those coming into organic markets.

18 Again, a detailed environmental

19 assessment with maps is required. An

20 oceanographic technique of defining the

21 hydraulic zone of influence is required, which

22 really describes the whole hydrodynamics of
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1 the growing area. We require an expanded

2 sanitary sewer survey. We require hatchery3 produced seed only, with one exception.

4 Monitoring requirements for

5 indicator organisms, and we use sentinel

6 animals. In the case of sentinel animals, we

7 require four times a year that these animals 

8 be sent off for evaluation of about 200

9 different contaminants that exist in the wild.

10 Chemicals that control predators

11 are prohibited, and we have restrictions on

12 how bivalves are harvested, and we require

13 extensive traceability. 

14 Aquatic plants, again earth ponds

15 must not have prohibited substances for 36

16 months. Dissolved nutrients must not exceed

17 the minimum nutrients that are necessary for

18 that particular crop. Berms, boundaries and

19 buffer zones are all required to prevent

20 contamination. Organic starter cultures are

21 required when available. Right now, there are

22 none, but hopefully that will develop.
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1 Compost manure is allowed if it

2 complies with Section 205.203, but prohibited

3 in public waters, and again we have continuous

4 organic management after five percent.

5 As Sebastian indicated earlier, a

6 unique contribution from our standards,

7 compared to terrestrial, is the humane

8 slaughter of our fish. We want to minimize

9 stress to the animals and minimize

10 environmental impacts during harvesting.

11 Transport conditions must consider

12 water quality, duration of the trip, density

13 of the animals and metabolite formation, to

14 minimize adverse effects. This, we think, is

15 very critical. 

16 Usually before slaughtering fish,

17 they are fasted, and that period must be

18 limited to that necessary to provide good

19 clearance and can be no longer. Finfish must

20 be stunned to be instantly rendered insentient 

21 and maintain insentient until death by

22 concussion to the head, which you saw
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1 apparatus that does that, electrical stunning

2 or electrocution.

3 Prohibited means of slaughter

4 include ice slurry. You saw ice slurry in

5 that Bell Aquaculture picture. This will be

6 allowed for warm water fish for five years,

7 because the enhanced methods aren't quite

8 there for catfish, for instance. 

9 Carbon dioxide suffocation has

10 been a standard practice. That causes stress

11 and we are proscribing it. Suffocation,

12 letting fish die in the air is proscribed,

13 synthetic anesthetics and bleeding without

14 stunning is all proscribed. Ice slurry is

15 allowed for animals that are non-sentient,

16 such as shrimp. 

17 Well that ends our presentation,

18 and we've allowed for questions, comments you

19 may have, Mac.

20 CHAIRMAN STONE: Okay, very good.

21 MR. LOCKWOOD: Thank you for your

22 attention.
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1 CHAIRMAN STONE: Thank you. I

2 think the images helped me to see, just to

3 have a little bit of a visual to go along

4 with. So just to remind the Board, so that

5 aquaculture working group represented here was

6 appointed by the program back in the day.

7 So they are agents of the USDA, if

8 you will. They work, there's 12 members, I

9 believe George, of the working group,

10 representing the various aspects of the

11 industry. So they've made their

12 recommendation. The program has accepted that

13 and the program has a proposed rule to come

14 out. 

15 So we thought that this would give

16 us an image and get our thought process

17 working. So I think that now our work has

18 revolved around the petition materials, which

19 is primarily vitamins, minerals, which are

20 exactly the same as in terrestrial feeds and

21 a few other items.

22 So first before, and I know Tracy
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1 or Jean or some on the Livestock Committee may

2 have some questions. It would be nice if we

3 could have a copy of this PowerPoint maybe, so

4 that we can provide that to the committee

5 members or anybody on the Board, just in

6 referencing some of this. 

7 So does any members of the Board

8 have specific questions for George or

9 Sebastian?

10 MEMBER FAVRE: I noticed on the

11 terrestrial-based system you have a

12 requirement for the effluent to be assimilated

13 within 25 meters. Describe a little bit about

14 what that process would be for assimilation.

15 MR. LOCKWOOD: Do you understand

16 that?

17 MR. BELLE: Yes. Actually, that's

18 a requirement that applies to all systems,

19 including net pens, and basically depending on

20 what your culture method is or what your

21 containment method is, if you will, there are

22 different ways to handle that.
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1 In land-based, you can actually

2 capture solids and compost, and then for

3 dissolved nutrients, there are a number of

4 other ways that you can deal with that. But

5 it's basically, what we're seeing is within 25

6 meters of the facility, the nutrients that are

7 coming out of that farm have to be assimilated

8 or handled some way.

9 So in the case of net pens, which

10 would be the worst case scenario, where you've

11 got an open system, whatever is coming out of

12 that farm has to be assimilated either by the

13 mussels or the kelp or the carrying capacity

14 of that site.

15 So when you, and again, in the

16 case of net pens, when you begin to work a

17 site with a net pen, just like a field when it

18 begins to have cows on it, you begin to have

19 an ecosystem evolve locally in that farm. 

20 What we're seeing is that that

21 ecosystem, including the kelp or the mussels

22 that you have on that farm, have to be able to
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1 process the nutrients that are coming out of

2 that farm, within the 25 meter distance.

3 MEMBER RICHARDSON: Morning. 

4 Question for Sebastian. One of the standards

5 that we need to be thinking about and, you

6 know, just for us to know how we're going to

7 be dealing with these petitions, is that we

8 have to be able to verify that biodiversity on

9 the farm, which is one of our criteria, is

10 being appropriately addressed.

11 That means because we're using,

12 you have wild fish feed included, as well as

13 just the location, which is some distance from

14 your farm per se. How will the issues of

15 biodiversity be able to be measured by the

16 inspector who comes around to do the

17 inspections once a year or whenever?

18 MR. BELLE: You've said -- you've

19 used the key word, which is near and dear to

20 my heart, which is inspection. I'm very

21 involved in auditing of best management

22 practices for a bunch of other groups, and you
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1 can have the best standard in the world, and

2 if it's not auditable, it's worthless.

3 So I think that's, and you've

4 actually put your finger on probably the most 

5 difficult piece of the standard to audit, the

6 biodiversity piece.

7 There is a requirement -- on the

8 finfish side, there's a requirement about the

9 fish meal and fish oil inputs, and if you

10 actually sit down and kind of do the

11 calculations of what those ingredient levels

12 are, and what the conversion levels are. 

13 You'll see that we end up in a place where

14 you're actually producing more marine protein

15 than you're consuming.

16 So that's -- we're actually

17 driving the farmer in a direction where they

18 are actually forced to use other protein and

19 lipid sources in their feeds, and that will

20 mean they will use less and less to

21 eventually, under the current proposed

22 standard, virtually no fish meal and fish oil. 
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1 So that would, from the biodiversity point of

2 view, that would be one piece.

3 But the other piece, I think, is

4 particularly by forcing open system farmers to

5 go to a multitrophic approach, you're actually

6 -- you can actually document the numbers of

7 species both in the sediment around the farm,

8 and in the water column around the farm, and

9 it's a very -- we have been doing this in

10 Maine for 15 years. It's a very predictable

11 evolution, if you will, of the farm.

12 What happens is initially when you

13 start the farm, biodiversity actually goes up,

14 not down, and you go and basically as a

15 manager of that farm, you are looking at the

16 numbers of species, flora and fauna, both in

17 terms of the numbers of family and taxa, but

18 also in terms of the numbers of individuals

19 with each, within each of those categories.

20 You manage the farm to maximum

21 biodiversity. If you go beyond that, you're 

22 actually in the process of crashing that site,
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1 and you would have exceeded the standards. So

2 there will be -- you will have to have, as a

3 farmer, you will have to have data that the

4 auditor will look at, to show numbers of

5 species, taxa and what's happening around the

6 farm.

7 MEMBER RICHARDSON: That actually

8 is very reassuring and really interesting, and

9 I was fascinated to see -- one of the

10 questions I had asked during our many

11 conference calls was to see if there were any

12 of the fish farms that were using a range of

13 species being grown on the farm, and that

14 would certainly make a difference.

15 So just to clarify, so before --

16 if we, if there's a fish farm that starts up

17 that's organic, will there be an analysis of

18 the biota in that area prior to the beginning

19 of it, that will then show up in the organic

20 system plan as the months, years go by, so

21 that the inspector can then verify that there

22 have been no radical changes in the benthic
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1 biota, and that the combination of taxa remain

2 relatively --

3 I mean they're going to change

4 obviously, but that they remain a relatively

5 sustainably balanced way.

6 MR. LOCKWOOD: The organic system

7 plan requires an environmental assessment,

8 with all of the detail that you just

9 mentioned, before the organic production can

10 begin. It's a comprehensive environmental

11 assessment.

12 MR. BELLE: So you have a baseline

13 to compare it against over the evolution of

14 the farm.

15 CHAIRMAN STONE: Tracy.

16 MEMBER FAVRE: Talk to me about

17 the difference in density between conventional

18 versus organic in, for instance, a net pen

19 system?

20 MR. BELLE: Typically, at least

21 overseas in currently certified organic farms,

22 the densities on organic farms are probably a
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1 third of what you would see. Ironically, and

2 this is -- I may open a can of worms here, but

3 ironically, there are many people who believe

4 that net pen systems should not exist, and

5 that they should -- and those finfish

6 production units should be moved to land.

7 The densities in land farms are

8 several orders of magnitude. You might have

9 90 kilos per cubic meter in a land farm,

10 versus 25 in a conventional salmon farm, and

11 versus 15 in an organic farm.

12 So as with anything, there are

13 tradeoffs you have to make as a farmer, and

14 the density issue, I think, is going to be a

15 much bigger issue for land-based farms than it

16 is for ocean-based farms.

17 MR. LOCKWOOD: Tracy, there was a

18 study a few years ago done in Norway of salmon

19 density in net pens, and they stocked salmon

20 at 30 kilograms per cubic meter, at 20

21 kilograms per cubic meter and at 10 kilograms

22 per cubic meter. Some standards in Europe
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1 required ten.

2 Turns out that the optimum,

3 measuring a number of variables, was 20. So

4 you can get too low, and of course you can be

5 too high. 

6 MR. BELLE: Can I just add one

7 thing? You have to remember in the case of

8 fish, they are social animals. These are

9 schooling animals. So if you have one fish in

10 a cage this size, that is not a very happy

11 fish. It is a very nervous, very stressed out

12 fish. 

13 There is a -- there's a minimum

14 density which you don't want to go below,

15 because it is unnatural for them.

16 CHAIRMAN STONE: Zea.

17 MEMBER SONNABEND: Thank you. 

18 Switching gears just a bit, we on the Crops

19 Subcommittee have been tasked with approving

20 some of the petitions for aquatic plant

21 culture.

22 The Department has told us that
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1 while they're working on aquaculture standards

2 for fish, they're not planning to do separate

3 standards for plants, aquaculture plants, and

4 they think the existing standards should be

5 able to cover plant culture.

6 So we're grappling with things

7 like petition for micronutrients to use, and

8 I'm assuming that aquatic plants is primarily

9 algaes and kelps in both open and closed

10 systems. 

11 The micronutrients annotation says

12 "must be a documented deficiency." So we're

13 going to be grappling with how do we apply

14 that type of annotation to the situation for

15 organic plants, aquaculture, and could you

16 comment a little bit about how you perceive

17 that would work?

18 MR. LOCKWOOD: Well, I've not

19 heard that the program is not proposing

20 aquatic plants. It would be very difficult to

21 grow many species without having organic

22 microalgae, for instance, or macroalgae.
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1 MEMBER FAVRE: Well, they didn't

2 say that they weren't going to allow organic

3 plant aquaculture. They just said they

4 weren't going to write a separate standard for

5 it, and we have to accommodate it into the

6 existing plant standards. 

7 MR. LOCKWOOD: Well, we don't know

8 what the program's final rule proposal is

9 going to be. Nobody knows except the people

10 working on it. But I can't imagine having

11 organic shellfish, for instance, without

12 having organic feed to feed those shellfish.

13 So they're probably, I don't know. 

14 I would guess that they are going to

15 accommodate that somehow, that we have to have

16 organic feed to grow organic animals.

17 MEMBER FAVRE: Right, they are. 

18 But for instance, you know, my example of a

19 micronutrient. How, like do you test your

20 algae to make sure, to see if it's deficient

21 in nutrients, you know, before applying a

22 micronutrient and are there steps so you don't
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1 apply too much in an open system so it gets

2 out? 

3 Like we're concerned about copper

4 or zinc or something getting into the

5 environment at too great of a concentration,

6 and what checks and balances are there for

7 that?

8 MR. LOCKWOOD: All right. In our

9 proposal, we contemplated -- we did not

10 contemplate open algae growing, other than

11 what you see around the net pens.

12 MEMBER FAVRE: What about kelp?

13 MR. LOCKWOOD: Those are not been

14 providing nutrients, other than coming from

15 nature or from the pens themselves. 

16 MEMBER FAVRE: Okay.

17 MR. LOCKWOOD: But the kinds of

18 ponds you saw, that is the type of algae

19 growing that we are contemplating. Yeah,

20 sure.

21 MR. BELLE: Just to take a little

22 different tack on that, there was an awful lot
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1 of work put into, at the working group level,

2 put into the standards for aquatic plants, and

3 so, you know, if the Department is choosing to

4 go a different route, at a minimum I would

5 hope they would look to what came out of that

6 working group, and use that to guide how they

7 develop what they're going to propose.

8 I think that would be -- because

9 it was a pretty thoughtful group that included

10 a bunch of folks who had aquatic plant

11 expertise, and they did look at the whole

12 issue pretty carefully.

13 MEMBER FAVRE: Okay. Do you think

14 it was the intention to eventually allow kelp

15 culture in the open oceans to be certified

16 too, or in some sort of controlled way?

17 MR. BELLE: Yeah. No, I think it

18 was. You know, in an open ocean situation, I

19 can't think of a situation where you would

20 actually be physically adding nutrients to the

21 water for those plants. That's not a -- to

22 me, it's a very unlikely scenario, because how
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1 would you -- first of all, how would you

2 control that?

3 Second of all, how would you know

4 whether you were having the appropriate effect

5 on the plants in an open system or not? It

6 might be very difficult. It would be very

7 difficult to literally operationalize it, I

8 guess is what I'm saying.

9 MEMBER FAVRE: Thank you.

10 CHAIRMAN STONE: Colehour.

11 MEMBER BONDERA: Yes, thank you. 

12 I do want to thank George and Sebastian for

13 what you've presented, and the working group

14 for all of the time and energy, and I don't

15 want to be beating a tired drum.

16 However, I would like to raise a

17 question that I have tried to bring up before,

18 but to be frank, for me at least, isn't, I

19 guess, answered yet.

20 I guess from a background

21 perspective, I'd just like to comment that I

22 am a farmer, but I just want to point out that
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1 all of these members of the NOSB that are

2 sitting here, like George said, we're all new

3 in terms of this whole topic. 

4 That's one of the reasons that you

5 were invited here and that we're doing this,

6 because after Barry Flamm left, nobody that

7 was on the NOSB had dealt with any of the

8 Aquaculture Working Group's presentations and

9 discussions, even though many members had.

10 That leads to my question, which

11 is related to getting us up to speed. But

12 it's something that came up in both of your

13 comments in different ways, and I think

14 Sebastian, I even wrote down, when he said

15 this is evolving very rapidly.

16 I think that we're all aware of

17 that, but I think that it leads me from a, I

18 think, I don't like to describe myself as

19 conservative, so I won't use that word, but

20 from an understanding perspective, to try to

21 say, to think are we -- 

22 Do we have our brains around this
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1 whole picture well enough to really be making

2 judgments about specific petitions or -- and

3 I guess that I'm slowly getting to the

4 question.

5 But I think the question is what

6 has changed research-wise or information-wise

7 since the working group put forth its

8 conclusions? I think that frankly, I am aware

9 that some things have happened. There are

10 published studies on some of these things that

11 did not exist when the working group did its

12 work.

13 I'm just wondering from the

14 perspective of us all being able to understand

15 this, if you could either direct us or tell us

16 or summarize for us the changes in information

17 and understanding that have occurred, how they

18 could or should be affecting either the NOSB

19 or the NOP or this rule that isn't even

20 finished, in terms of, you know, is there

21 reconsideration necessary of some of the

22 details, that kind of thing. 
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1 Because you're presenting things

2 that are at this point old, and so -- and I

3 don't know. I hesitate to use the word "old,"

4 but we have a sunset system where five years

5 is considered, we are forced to reconsider

6 things every five years.

7 So I just want to bring that topic

8 up and ask you to respond as you can. Thank

9 you.

10 MR. LOCKWOOD: Let me just touch

11 on a couple of areas, Colehour. The area of

12 fish nutrition is an advancing science, and

13 one of the objectives is, in conventional

14 aquaculture as well as organic, to get away

15 from fish meal consumption for a number of

16 reasons.

17 So the frontier has been to

18 replace more and more fish protein with plant

19 grain proteins, for instance. Right now, the

20 state of the art is such you can grow fish

21 without fish meal, for instance, if we could

22 use poultry byproducts or mammalian
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1 byproducts, or synthetic methionine.

2 The simple facts is those aren't

3 compatible with organic principles. So that

4 is one frontier. There are serious doubts, if

5 we can ever get completely away from fish

6 meal, but people are working on that. 

7 There certainly are advances in

8 animal health. One area where there are new

9 discoveries is in the growing of aquatic

10 plants, particularly oceanic plants. There

11 are certain trace minerals that have been

12 identified for many, many years, that are

13 essential for plant culture.

14 Another finding is they go out

15 into the, further out to sea. There are some

16 species that have additional trace element

17 requirements.

18 That's one of the reasons why we

19 want to remain flexible with the petition we

20 have for trace elements, that there are new

21 discoveries being made in those areas. Maybe

22 you have something to add.
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1 MR. BELLE: Well, the only thing I

2 would say is that, you know, you can draw a

3 line in the sand at any point in history, and

4 look backwards and say things have changed. 

5 I think that's true for any field, and one of

6 the things we did, we were very cognizant of

7 when we were discussing and developing and

8 working on the standards, was that the

9 standards had to be constructed in a manner

10 that allowed for innovation, but was true to

11 the organic principles.

12 So we worked very hard to try to

13 recommend standards that achieved that, and I,

14 you know, I mean I'm sure that terrestrial

15 organic sciences is evolving probably as

16 rapidly as aquaculture sciences. I suspect

17 they're both very dynamic, very innovative

18 fields.

19 So we did, we recognized that when

20 we were working on it, but we really tried to

21 make sure that we were allowing for

22 innovation, but not drifting from the
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1 fundamental principles.

2 MEMBER FAVRE: Thank you for your

3 forbearance. I'm sure this has felt somewhat

4 like an interrogation. But I think mostly

5 it's that we're so eager to capture the

6 knowledge in your heads while you're here.

7 One last question. I know we've

8 got a very compressed schedule. I noticed in

9 your slide presentation, one of the photos

10 showed a fairly arid landscape in the

11 background of a pond siting. 

12 So when you're doing an

13 environmental assessment, are you taking into

14 account the siting of a location, based on

15 things like water use and its impact on the

16 local area?

17 MR. LOCKWOOD: Yes, and a lot

18 more. It's a very comprehensive requirement. 

19 CHAIRMAN STONE: Calvin.

20 MEMBER WALKER: Thanks for y'all

21 presentation. Could you share with the group

22 and those who are in the audience the
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1 importance of materials that the Livestock

2 Committee have, the importance for those

3 materials being passed, like the vitamins,

4 minerals --.

5 MR. LOCKWOOD: Well, in the case

6 of aquatic animals, we have vitamins. 

7 Vitamins are well-established for health

8 requirements, trace elements. We have

9 petitioned for a disinfectant, chlorine,

10 chlorine materials, vaccines. 

11 A major revolution in terms of

12 technology has occurred in the last 30 years

13 with the development of vaccines for specific

14 diseases that otherwise had to be treated with

15 antibiotics. But all our petitions, you know,

16 are directed towards raising healthy fish, so

17 that they don't have to be treated.

18 That's a principle of organic

19 management that we've copied, and we want to

20 remain faithful to it. 

21 MR. BELLE: I think when we, as a

22 group, looked at what should be petitioned and
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1 recall that we were asked to be petitioners,

2 it wasn't our idea to be petitioners. We were

3 asked to be petitioners.

4 We went through the list of things

5 that are currently approved on the National

6 List, and then we looked at what would be the

7 bare minimum that we would need, in order to

8 maintain animal welfare, plant health, the

9 things that we as farmers felt we had a

10 stewardship responsibility about.

11 That was how we came up with that

12 list, and there was a lot of debate about what

13 we should or shouldn't petition for. I have

14 no doubt that we probably haven't got it

15 totally right the first time through. I'm

16 sure we haven't.

17 But it was our best effort at the

18 time to match what was already currently

19 approved for other uses, and then also what we

20 felt we needed as a bare minimum from a

21 stewardship point of view.

22 MR. LOCKWOOD: And when we started
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1 out with the list, we had 30 different

2 substances that we were going to petition, and

3 we whittled it down to ten. 

4 CHAIRMAN STONE: Jean has an itsy5 bitsy, teeny-tiny little-bitty question, I

6 think.

7 MEMBER RICHARDSON: Very small

8 question. As you phase out -- in terms of

9 fish food, as you phase out of using wild fish

10 and fish oil and fish meal, will you be

11 replacing those oils primarily with things

12 like soy and corn and what else?

13 MR. LOCKWOOD: Well, soybean oil

14 is made of omega-6 fatty acids. Fish oil is

15 omega-3 fatty acid. In human physiology, they

16 are entirely different. In fact, there's a

17 number of scientists who believe we have an

18 overload of omega-6's.

19 It's going to be very difficult to

20 find other sources of omega-3 fatty acids than

21 fish oil. There may be algae developments in

22 the future that will do that.
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1 But right now, the world supply of

2 fish oil is limited, and if we're going to be

3 selling salmon with omega-6s, it's really

4 fraud, because people expect the healthy

5 components in the fish.

6 CHAIRMAN STONE: Miles.

7 MR. McEVOY: Yeah. I just wanted

8 to clarify a few things that were brought up. 

9 Let's see.

10 First of all, we have many old

11 NOSB recommendations that we haven't gotten

12 to, that are older than these aquaculture

13 recommendations that we're still working on,

14 with either rulemaking or guidance that will

15 go forward with notice and comment.

16 Whether it's a rulemaking or

17 guidance, that's part of the process. So more

18 comments will be necessary for some of the

19 older NOSB recommendations.

20 The other thing, on the farmed

21 aquatic plants, when we've looked at that, we

22 already have existing certified organic
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1 operations that are certified under the USDA

2 organic regulations, that are doing farmed

3 aquatic plants.

4 We haven't seen a need for

5 rulemaking around this. There might be a need

6 for some guidance around farmed aquatic

7 plants.

8 We'll continue to evaluate that,

9 to see if we need to change our perspective on

10 that. But there's already currently certified

11 organic operations that are doing farmed

12 aquatic plants.

13 Then on the issue of organic

14 aquaculture labeling in the U.S., in the past

15 the NOP had a fact sheet that indicated that

16 if aquaculture products were certified to a

17 third party standard, that they could be sold

18 in the U.S., as long as they didn't reference

19 the USDA organic regulations or use the USDA

20 organic seal.

21 That fact sheet has been removed

22 from the website and archived. We had looked
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1 into potentially doing an interpretive rule,

2 which would prohibit the labeling of organic

3 aquaculture/organic seafood in the U.S., until

4 we established organic aquaculture standards.

5 That project has been stalled. 

6 We're still considering that possibility, that

7 under the existing regulations, we could issue

8 an interim rule to prohibit organic seafood

9 labeling until we have standards.

10 Then we have taken enforcement

11 action against operations making organic

12 seafood claims that are not certified to any

13 standard whatsoever, and we'll continue to do

14 that.

15 So if you're aware of any organic

16 seafood claims that are being made, that are

17 not certified to any standard, then please

18 file a complaint so we can take enforcement

19 action against that.

20 CHAIRMAN STONE: Okay. Just one

21 really itty-bitty question, Gene. If you'd

22 like to make a couple of closing remarks, we
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1 are out of time. But what percentage of these

2 farms do you think might go organic, based on

3 the marketplace, feed costs, changes that they

4 would have to institute to meet the organic

5 standards?

6 MR. LOCKWOOD: Well, that's an

7 interesting question, Mac. Obviously, we have

8 no real knowledge of what will happen. My

9 guess is one or two percent of the farm fish

10 will be, will qualify for organic

11 certification. Of course, that will depend on

12 the species too, and the growing systems.

13 But it's not a large number that I

14 anticipate. The additional costs are very

15 high to meet our standards.

16 CHAIRMAN STONE: Thank you very

17 much. Would you like to make quick closing

18 comments. We appreciate your time to be here,

19 but you're welcome to make a closing comment,

20 if you'd like.

21 MR. LOCKWOOD: No. Not other than

22 we are prepared to work closely with your two
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1 committees that are working on our petitions. 

2 As we developed, as the NOSB developed their

3 recommendations, they work very closely with

4 the Aquaculture Working Group, and we are

5 prepared to continue to work with you as we

6 can provide information you need.

7 MR. BELLE: I'd just say come to

8 Maine. Come to Maine and visit our farms. 

9 Any one of you that wants to come to Maine and

10 go for a bunch of farm tours, more than

11 willing to do that.

12 We'd love to have you down. The

13 farmers would love to have you down, and we'd

14 be delighted to show you through the

15 operations. None of them are organic yet, but

16 we hope some day they will be.

17 CHAIRMAN STONE: All right. Thank

18 you very much.

19 MR. LOCKWOOD: Thank you very

20 much, Mac. We appreciate this opportunity.

21 CHAIRMAN STONE: Very good. So

22 I've got 12 -- not 12:48. That would be 9:48. 
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1 We're pretty much right on schedule. We'll

2 come back at five after 10:00 for the

3 Livestock Committee. Promptly five after

4 10:00.

5 (Whereupon, the above-entitled

6 matter went off the record at 9:48 a.m. and

7 resumed at 10:06 a.m.)

8 CHAIRMAN STONE: We're going to

9 call the meeting back into session. We're

10 moving into the Livestock Subcommittee place

11 on the agenda. The plan is this will last up

12 until the lunch break. We have several people

13 to present, public comment as well.

14 So as Tracy settles into her seat, 

15 I'll turn it over to Ms. Tracy Favre.

16 Livestock Subcommittee

17 MEMBER FAVRE: Thank you, Mac. 

18 Livestock Subcommittee, as you might imagine,

19 we've been spending a fair amount of time on

20 aquaculture.

21 But for this meeting, we have one

22 proposal and one interim report. I would like
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1 to go ahead with no further delay and turn it

2 over to Mac for the pet food amino acids

3 petition.

4 CHAIRMAN STONE: All right. The

5 Board was petitioned by the Pet Food Institute

6 to allow the essential synthetic amino acids

7 to be allowed in pet foods. Just sort of a

8 brief rundown. 

9 So the pet foods currently, there

10 are organic pet foods being marketed. First

11 let me say the program, as Melissa said, the

12 program is working on pet food standards. I

13 think they're going to be out December the

14 3rd.

15 But currently, they're being

16 produced under the livestock standards and

17 labeled under the handling standards. So it's

18 consistent with the existing rule. It's a

19 great way for, you know, to utilize byproducts

20 and add a little value to certified organic

21 agricultural ingredients.

22 MEMBER FAVRE: Excuse me, Mac?
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1 CHAIRMAN STONE: Yes.

2 MEMBER FAVRE: Not to interrupt

3 your flow there.

4 CHAIRMAN STONE: Yeah.

5 MEMBER FAVRE: But I think what we

6 were going to do for the petition materials

7 was have Dr. Brines introduce them first.

8 CHAIRMAN STONE: Oh yeah. Excuse

9 me, that's right. Yeah, sorry.

10 MEMBER FAVRE: And then go on, if

11 that is okay with you.

12 CHAIRMAN STONE: Forgot that part,

13 very good.

14 MEMBER FAVRE: Okay, thanks.

15 CHAIRMAN STONE: Thank you. Ms.

16 Lisa.

17 DR. BRINES: Thanks, Mac. I'll

18 keep it brief. The petition for amino acids

19 in pet food was submitted by the Pet Food

20 Institute on January 30th, 2012, and it

21 requests the inclusion of 13 individual amino

22 acids to Section 205.603 of the National List,
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1 for use in organic pet food.

2 In support of the review of this

3 petition, the Livestock Subcommittee did

4 request the development of a third party

5 technical report, and that report was

6 completed in 2012, and both the petition and

7 the technical report were posted on the NOP

8 website in advance of the opening of the

9 public comment period for this meeting, and

10 this petition was also on the agenda for the

11 last meeting, although there was not a vote at

12 that time. Thank you.

13 CHAIRMAN STONE: Thank you. Sorry

14 about that. I made a note here for later this

15 afternoon or tomorrow.

16 So the -- in the petition, the Pet

17 Food Institute noted that many of these

18 essential amino acids can be derived from

19 agricultural ingredients, but there are

20 certain amino acids that are not readily

21 available through normal agricultural

22 ingredients.
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1 So the committee spent,

2 Subcommittee spent a fair bit of time working

3 on the sentiality. It's known that in the

4 normal manufacturing process, the heating

5 especially of dry dog foods or cat foods can

6 degradate the amino acids that are within

7 these agricultural ingredients, so they may

8 not make it through the processing phase of

9 the, in the production cycle.

10 There also are issues of

11 seasonality and geographic availability of

12 some of these ingredients, to make the organic

13 ingredients to make these pet foods. So

14 through the public comment period at this

15 time, so the committee -- back up one step.

16 So pet foods are regulated. It

17 seems that I would want to get into it. Maybe

18 Dave will respond. So there's a National

19 Research Council that establishes the

20 baseline. It's administered or regulated

21 through AFCO, American Association of Feed

22 Control Officials.
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1 So it's odd that it's a little bit

2 outside of a true government regulation, but

3 the states agree to this Association of Feed

4 Control Officials, so that the interstate

5 commerce is facilitated.

6 But each state, because of their

7 legislative and regulatory systems, administer

8 it a little differently, but they do have one

9 standard that they all agree to.

10 So the committee looked at, we

11 looked at lots and lots of pet food labels,

12 ingredient panels on labels, and seemingly,

13 and again maybe public comment and written

14 comment told us this as well, but there's

15 variability of what synthetic amino acids we

16 were seeing on the ingredient panels.

17 Seemingly, the rations that had

18 more grain, foreign grain of some sort, they

19 were adding synthetic methionine or lysine. 

20 Several of the products had synthetic

21 threonine. Several had taurine, and

22 carnitine, which I guess is not actually an
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1 amino acid but it's also a fifth, sort of

2 often-added synthetic amino acid, if you call

3 it that.

4 So in our investigation, in

5 looking and discussing seemingly the higher

6 end, if you will, pet foods that mimic the

7 natural diet of dogs and cats, had less

8 addition of the synthetic amino acids. But

9 there was one dramatic trend that all cat

10 foods had synthetic taurine added, essentially

11 all cat foods.

12 We obviously didn't see every one,

13 but essentially all cat foods had synthetic

14 taurine because they can't be synthesized by

15 the animal, and they do get overly degraded in

16 the manufacturing process.

17 So in the public comment, written

18 comments, the Pet Food Institute reiterated

19 what was in the petition, that taurine for

20 dogs was also problematic or lack thereof

21 would be problematic, especially in the large

22 breed dogs. Many of the pet foods, they do
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1 sort of market as young animals, older

2 animals, large breed, small breed, et cetera.

3 But the large breed dogs were sort

4 of particularly, they have bigger concerns,

5 that those would not be -- manufacturers

6 couldn't have a uniformity in the dog foods. 

7 They also asked that, said the methionine,

8 lysine and threonine were the other three that

9 were particularly problematic, again getting

10 back to this availability of organic

11 ingredients.

12 The written comments also referred

13 to that raw diets, that raw diets are not

14 functional, if you will, in the marketplace. 

15 Homeowners can in fact, could put together

16 their own raw diet, but in the marketplace it

17 would be very problematic and food safety

18 issues and animal health could be compromised

19 as well.

20 We did receive one public comment

21 of a pet food manufacturer that said they can

22 source and supply these complete diets without
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1 synthetic amino acids, and several public

2 comments from individuals that said keep

3 synthetic amino acids out of pet foods.

4 The basic difference here these

5 are not food animals, so is there a slightly

6 different standard. That's why the program is

7 putting together a separate standard, whereas

8 now, as I said, they're being produced under

9 the livestock standard as far as vitamins and

10 minerals, et cetera, and labeled under the

11 handling standards for marketplace as far as

12 made with and use of the organic seal.

13 I guess that's my summary. If

14 there's any questions from the Board.

15 MEMBER FAVRE: Thank you, Mac. We

16 had some conversations about, as Mac

17 indicated, some of the other amino acids, and

18 I think we would prefer to wait on voting on

19 this proposal until after we've had a chance

20 to hear the public comments, if the Board is

21 agreeable to that. Okay. So we will come

22 back to that.
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1 Thank you, Mac. Next on our

2 agenda is a report, the interim report for the

3 vaccines made with excluded methods. So Jean.

4 MEMBER RICHARDSON: Thank you,

5 Tracy. I will not be going through the entire

6 report in minute detail, since it's highly

7 complicated. But let me just sort of review

8 where we are headed with this work, in order

9 to help producers be able to know which

10 vaccines are made with excluded methods and

11 those which are not.

12 So just as a reminder is that

13 those producers that are growing livestock

14 must take care of their animals. It's

15 required in the rule, and biologic vaccines

16 are permitted. However, it is important to

17 note that the regulations prohibit the use of

18 excluded methods.

19 However, there is specific

20 reference to vaccines in the section on

21 excluded methods. The regulations provide an

22 allowance for vaccines produced through the
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1 use of excluded methods if, and please note

2 the word if, those vaccines have been reviewed

3 and recommended for addition to the National

4 List by the NOSB.

5 The review needs to be conducted

6 in accordance with Section 205.600 in the

7 regulations, and those specify the criteria

8 that the NOSB would have to follow, in order

9 to allow prohibited substances or methods in

10 the ingredients.

11 To date, the NOSB has not

12 recommended any vaccines made with excluded

13 methods to be added to the National List. 

14 This provides a real challenge for producers

15 out there, because farmers and certifiers

16 still need to determine if the vaccines

17 they're using are made with excluded methods

18 or not.

19 And as we all know, the general

20 practice is just to use the vaccines, without

21 really addressing those, either by the

22 certifiers or the farmers. So some farmers
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1 are using vaccines that probably include those

2 that are made with excluded methods.

3 So in a way, we're not really

4 enforcing what needs to be enforced, and it

5 turns out a lot of it is because of the

6 complexity of the way in which the vaccines

7 are listed, described and presented on the

8 marketplace. So we lack the necessary

9 information.

10 As you know, we've spent several

11 months with a working group that spun out of

12 the Livestock Subcommittee. We've been

13 working with members of -- Patricia Foley from

14 the Center for Veterinary Biologics, and

15 Melissa Bailey from our NOP staff, and Nick

16 Maravell and I from the NOSB, and Scott Updike

17 also from the program, to try to see what

18 light we can shed on this very complicated

19 situation, because there is not a clear

20 understanding of which vaccines the farmer and

21 the certifier could easily identify.

22 Obviously, vaccines are an
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1 extremely important of many organic farmers'

2 work protocols. So we put out the working

3 report that went out for public discussion. 

4 This is a document that has not gone through

5 the Livestock Subcommittee or been approved by

6 it, because it's only a working group

7 document.

8 We received some -- we came up

9 with a summary of findings, which is what is

10 being put up on the screen there by Michelle. 

11 We came up to summarize our findings is what

12 we saw, was that it is you can't identify

13 certain vaccines as being produced by excluded

14 methods with wood, such as chimera, vector or 

15 subunit.

16 But these are not always clear to

17 the producer or to the farmer, or to the -- in

18 terms of the marketplace. And we know that

19 the scientific veterinary biologic society

20 product codes of D to DNA vaccines and R to

21 recombinants.

22 However, there is an enormous
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1 amount of confidential business information

2 involved in going into minute detail, that

3 would essentially end up in a way with

4 labeling, labeling one product as being "GMO,"

5 which is not a word we use for these, but is

6 one genetically modified and one isn't.

7 And so because there's a

8 considerable amount of manufacturer

9 confidential business information, we could

10 not, the working group could not end up with

11 getting this list that we would like to have

12 for producers, that would allow them to easily

13 identify which vaccines to use and which not.

14 We then explored it further, and

15 as gone into in an enormous detail on our

16 conference calls as to what in fact

17 constitutes an excluded method. It got more

18 and more complex as we went into it in more

19 and more detail, and I do not have my Ph.D. in

20 Cytology or Cytogenetics. 

21 So like many of you here, I also

22 have to work through to try to understand what
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1 it all means. The bottom line is that the

2 definition of excluded methods really no

3 longer fits, as Zea said, in the GMO Ad Hoc

4 Committee, no longer really fits what our

5 level of sophistication, ten years after the

6 rule, is in place. 

7 So we need to almost certainly

8 work on a new definition of excluded methods,

9 and the challenge even becomes more complex,

10 is how far back in history do we go, in order

11 to start the analysis of which vaccines

12 presently on the market are okay and which are

13 not.

14 Do we take a deadline of 1969 or

15 1975 and then work forward from there? We

16 don't know. We didn't come up with an answer

17 to that question. We simply got more and more

18 complicated as the weeks went by, talking

19 about genomes and transposons and stuff like

20 that.

21 So we did come up with two ideas

22 that we would have a proposal that we could
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1 look at all technologies that could be used to

2 create a targeted change or mutation in the

3 genome, that would be considered excluded

4 methods.

5 The second proposal, we would look

6 at every technology on a case by case basis. 

7 So that if a given technology can induce

8 genetic mutations randomly or targeted, that

9 technology would be allowed, if mutations were

10 random for the material in question. So those

11 were the two sort of general concepts that

12 came out of that discussion.

13 So we sent this material, as you

14 know, out for public discussion and comment,

15 and we got some excellent and detailed

16 feedback from a number of organizations. We

17 got eight detailed responses that had a

18 certain amount of consistency in them, from

19 crop, NODPA, OMRI, MOSA, Northern Vermont,

20 Beyond Pesticides. Cornucopia will be

21 submitting detailed comments later, and some

22 from poultry folks. 
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1 There was a general consensus that

2 indeed yes, the working group needs to really

3 look at the definition of excluded methods and

4 to continue its work to try to develop a new

5 definition that would be more appropriate for

6 our modern understanding of what excluded

7 methods are.

8 Let's just look at some of these

9 comments. OMRI made an important point, I

10 think, that as we -- assuming we go forward

11 with the working group, manufacturers and the

12 NOP to look at a definition, that we consider

13 the international implications of whatever

14 recommendations that we come up with, because

15 we need to be able to work in the global

16 marketplace, especially with all the

17 equivalencies.

18 I think all of them, all their

19 comments included the need to look at this

20 definition. The Crop Cooperative considered

21 that the second proposal, of taking every

22 technology on a case-by-case basis, they
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1 thought that that was the best of our options

2 for the proposals to be looked at, and

3 everyone understood the problem of going --

4 how far back do we go in the development of

5 manufacturing, to look at the excluded method

6 issue. Crop Cooperative commented on that in

7 some detail.

8 Other of the comments, definitely

9 they wanted us to be sure that we, the NOSB

10 definitely understands that vaccines are an

11 important part of the tools used by many

12 producers, and indeed we certainly recognize

13 that. 

14 I'm just looking at some of these

15 other comments. Is it MOSA had one. Oh, and

16 OMRI also considered that it was logical to

17 look at, to suggest that a given technique

18 should be declared excluded or allowed, and

19 the International did that. Other things. 

20 Okay. There is also the issue to

21 be sure that we keep on the table and that is

22 the concern for the fact that we know that the
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1 salmonella vaccine for poultry is genetically

2 modified vaccine.

3 We're aware of that, and that that

4 certainly is one of the serious issues that we

5 have to keep in mind, no matter what

6 recommendations we come up with over the next

7 few months.

8 So where does this leave us? It

9 leaves us that we still don't have a good list

10 for producers to be able to determine whether

11 the vaccines they're using are made with

12 excluded methods or not.

13 We heard the other day that dairy

14 farmer Strauss, who has a, I believe he has a

15 closed herd, manages to determine by his own

16 actions, to determine which vaccines are

17 appropriate or not made with excluded methods.

18 Although I didn't ask him in

19 detail exactly how he's doing that, we know

20 that some farmers try to do it, but the

21 majority still it's so complicated that they

22 can't do it. So we still don't have that list
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1 and we need, we do need it. It is something

2 that's very important.

3 We hope over the next few months

4 that we can continue work with manufacturers,

5 to look at how such a list may be developed,

6 and also to work on the how we can develop an

7 updated definition of what made with excluded

8 methods really means, and probably some of

9 that work will overlap with what Zea's group

10 is doing with GMO, because obviously there's

11 an overlap there in how we'll come up with a

12 definition over the long run.

13 So hopefully this working group

14 report can now be absorbed and be part of the

15 work plan of the Livestock Committee over the

16 next few months, as we see what, if anything,

17 we can do to move this along more quickly.

18 Melissa, is there anything from

19 the program point of view that you'd like to

20 add at this point.

21 MS. BAILEY: Sure. Thanks Jean

22 for that background and information. So last
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1 night at dinner, Jean said to me well Melissa,

2 you're going to come up with something

3 brilliant to say on this topic tomorrow, and

4 I said well, I'll think about it. 

5 So I don't think I have something

6 brilliant, but I guess what I would share with

7 you is my experience working on this group,

8 which has been a collaborative process, and

9 this topic area is something that I often have

10 posted in my office, which is nothing is ever

11 simple.

12 As we know, and if you look at the

13 information in the interim report, this is a

14 technically complex and complicated issue, and

15 I guess I would have three points that I'd

16 like to share with everybody, the first being

17 about the process; the second about

18 implementation; and the third being about

19 collaboration and kind of where we go next.

20 So the first on the process is,

21 you know, we've been working as a team on this

22 issue, on calls kind of around the table. I
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1 think it was appropriate to move into this

2 phase, to kind of break out from that vacuum,

3 put something in front of the public for them

4 to react to, rather than trying to solve this

5 issue independently in this group.

6 So from that standpoint, I'm glad

7 we got something out that folks can react to. 

8 I imagine people will want to provide us

9 additional feedback, given the technical

10 complexity of the document. We've worked with

11 people all along.

12 We've had great collaboration from

13 some of the poultry folks, kind of letting us

14 know where they're at in their production,

15 what kind of vaccines they're using.

16 So I would just like to say that I

17 think this, and I hope it continues in the

18 spirit of collective problem-solving. 

19 The second thing about

20 implementation is wherever we end up on this

21 issue, I would say the key is going to be

22 implementation. Whatever we do, I would hope
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1 that we try to embrace the concept of sound

2 and sensible implementation, that we do so in

3 an orderly fashion to minimize the burden on

4 the producers.

5 As Jean said, the ideal outcome

6 would be some sort of list, so they're not

7 pouring over labels on vaccines, which can be

8 quite burdensome and kind of against the

9 principles that we're trying to move toward.

10 The consideration of foreign

11 operations is important, as Jean mentioned. 

12 So people operating -- this is a global

13 program. People operating in other countries

14 may have additional concerns from their own

15 foreign governments about what are being used.

16 So that should be considered, as

17 well as I appreciated Mr. Strauss' comment

18 yesterday about his dairy operation. We'd

19 like to learn more about that and what

20 verification is going on.

21 But we do need to remember that

22 this will cross species as well. So dairy,
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1 poultry, goat, sheep. All of those things

2 need to be considered in whatever

3 implementation we do.

4 The last point is on sort of

5 personnel and collaboration. So I do want to,

6 even though he's not here, give a great thanks

7 to Scott Updike, who's on my staff. He's

8 done, has a background in some of the

9 technical aspects of this issue and has been

10 really able to provide that input to the

11 group. So that's been valuable.

12 The working group members,

13 including the staff from APHIS, and in terms

14 of next steps in this collaboration, I think

15 having the Livestock Subcommittee take a look

16 at the interim report, since this was sort of

17 a passthrough, just to get it in front of the

18 public, would be a logical next step, to have

19 those members be able to react to some of

20 what's in there, as well as to continue to

21 work with the GMO Ad Hoc Committee on their

22 work about sort of what those excluded methods
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1 mean.

2 We'll also put this in front of,

3 as I do with a range of things we worked on,

4 to the USDA Biotech Coordinating Group, who is

5 a coordinating group across the Department, of

6 people involved in biotech issues. So any

7 input we get from that group could be shared

8 as part of this process.

9 So that's all I have to say, and

10 thanks very much for the NOSB's participation,

11 Nick as well, on this issue. 

12 MEMBER FAVRE: Thank you, Jean and

13 Melissa. I think that's actually a good plan

14 for the Livestock Subcommittee to take it up. 

15 I'm fairly certain we're all going to need

16 further advance degrees and a science to

17 English dictionary to be able to interpret the

18 report, but we will do our best to do that.

19 That concludes the report from the

20 Livestock Subcommittee at present. Yes. 

21 Nick, you had a comment? Go ahead.

22 MEMBER MARAVELL: Yes. I'd just
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1 like to acknowledge some of the comment we got

2 said that we should have additional

3 stakeholders participating in this process,

4 and what I want to say is that this is not a -

5 - this group here is not an NOSB committee or

6 ad hoc committee. 

7 This is a working group of the

8 Department, and I fully endorse additional

9 stakeholder participation. That would have to

10 come at the appropriate time in the

11 appropriate way.

12 Sometimes industry forms its own

13 working groups, which I think would be fully

14 appropriate in my personal opinion. But I

15 have not checked that out with the Department,

16 and the industry may wish to approach the

17 Department and see how they could best

18 participate in this working process.

19 But so far, I've been encouraged

20 that we've gotten nothing but positive support

21 from industry in trying to address this issue,

22 and they have a lot of the information that
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1 would be helpful to sorting it through.

2 So I simply pass that comment onto

3 the Department and to the Board that, you

4 know, we may find that's an appropriate thing

5 to do.

6 MEMBER FAVRE: Thank you, Nick.

7 CHAIRMAN STONE: Thanks, Tracy. I

8 believe we have nine people signed up for

9 public comment in this section of the agenda. 

10 So I have Leslie Hancock is up first and Dave

11 Carter is on deck.

12 Public Comment/Livestock Subcommittee

13 MS. HANCOCK: Well thank you so

14 much for allowing us to make public comment

15 here as we get the presentation together. 

16 Just a brief history of who I am and why I'm

17 speaking here today.

18 I'm a veterinarian from the

19 University of Georgia, and I have a

20 postdoctorate in clinical nutrition from the

21 University of California-Davis. I have ten

22 years in clinical experience and six years in
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1 cell animal health nutrition, and I'm

2 currently the Director of Global Scientific

3 Affairs and Research and Development with

4 Natural Balance Pet Food.

5 Thank you for inviting the

6 comment, so I can share with you why I feel it

7 is incredibly important that amino acid

8 supplementation is permissible in all pet

9 food.

10 So certainly we recognize that

11 methionine is an essential amino acid for dogs

12 and cats, and if you're paying attention to

13 the recommendations by the NRC and

14 idiosyncracies within food, the requirements

15 are going to be elevated over the next year. 

16 So I'd encourage you to pay attention to that,

17 as well as taurine.

18 We know taurine is essential in

19 cats. Culmination of data over the last ten

20 years shows taurine is also conditionally

21 essential in dogs.

22 It's been staged from a non-
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1 essential amino acid to a conditionally

2 essentially amino acid, without which we'll

3 see heart disease, blindness, reproductive

4 failure and death, and as a veterinarian, I've

5 seen many, many sick animals and I've

6 nutritional deficiency far too many times. We

7 know better. This is a preventable disease.

8 All right. So how can we have

9 complete and balanced pet foods that have

10 complete -- that meet those requirements set

11 forth by regulators, and we still see disease?

12 The issue there is we're trying to

13 meet litmuses for each individual ingredient,

14 as opposed to looking at -- I know this is a

15 crazy -- a holistic approach to nutrition,

16 where we look at how the different nutrients

17 interact with each other.

18 So we're seeing trends in pet food

19 formulation, what the consumers are looking

20 for. Whole grains, high fiber. Guess what? 

21 That reduces sulfur amino acid

22 bioavailability.
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1 We're using different ingredients,

2 compared to what traditional AFCO

3 recommendations and NRD, and the research and

4 what the NRC based their recommendations upon. 

5 We're using ingredients with lower

6 bioavailability. 

7 We know that meats, such as

8 ruminant, beef, venison and bison have lower

9 sulfur amino acid content and lower

10 availability. So we need to take this into

11 consideration.

12 When you're looking at a formula,

13 it might meet the requirements on paper, but

14 what happens if you put it into the chaotic

15 system of the body? The biology is very

16 different.

17 Vegetable diets, a trend away from

18 byproducts. Guess what? That's where these

19 sulfur amino acids, are highest concentration,

20 the heart, the liver, lung, brain. Certainly,

21 as the trend goes towards formulating for

22 higher protein diets, that higher protein also 
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1 relatively increases the methionine

2 requirement.

3 So we have a very complex system

4 here that's not being taken into consideration

5 when you look at have you reached a benchmark? 

6 Have you formulated to meet a diet that hits,

7 you know, .33 percent methionine. Yep, I hit

8 it. The science is going to be fine.

9 We know that doesn't work. In the

10 mid-80's, a diet was formulized, a standard

11 AFCO diet, and guess what? We saw lots of

12 nutritional deficiencies, zinc deficiency,

13 copper deficiency, amino acid deficiency. 

14 So we need to be able, as

15 formulators, to look at a diet and understand

16 the way we're formulating, understand the

17 biology of the different animals and ensure

18 that that one meal is going to provide

19 consistent nutrition and not hurt the animal.

20 The pictures of the dogs here, and

21 you notice they are all large breed dogs,

22 these are cases that I treated myself from a
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1 taurine deficiency on complete and balanced

2 dry, expanded diets. So I want you to take

3 that into heavy consideration as we this

4 disease all the time.

5 My fear is my colleagues, my

6 friends that are still in practice at

7 universities, if we prohibit sulfur amino

8 acids from being in pet food, they are going

9 to see more disease. They see it enough. It

10 rarely comes to the attention of the

11 nutritionist, because the cardiologists deal

12 with it enough. They know how to handle it.

13 All right. We know that there was

14 a major problem in commercial kibble using an

15 exotic meat and a whole grain back in the late

16 90's. Sorry. So that's my four minutes. I

17 tried to get through it, but again to

18 summarize, we have to prevent disease and

19 suffering.

20 We see it and I think it would be

21 a huge mistake to prohibit sulfur amino acids

22 in pet food, and I won't show you the case
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1 reports of ones that I've seen. 

2 CHAIRMAN STONE: Thank you. Is

3 there questions from the Board? Jay.

4 MEMBER FELDMAN: I'm trying to

5 sort through the technical review document

6 that we received in look at this, and they do

7 cite manufacturers who sell cat food made

8 without synthetic amino acids, and then there

9 is a company there that apparently does this

10 as well, that actually produces, I guess, a

11 high quality protein, animal protein product.

12 So when you're talking about

13 adverse impacts on pets, are you talking about 

14 specific diets, or are you talking about high

15 protein diets as well, animal protein diets?

16 MS. HANCOCK: Yeah. So we do see

17 a trend. I believe one of my colleagues has

18 a report of the taurine status, plasma taurine

19 status and whole blood taurine status on

20 different diets of different protein level

21 inclusions.

22 But you know, you start doing a
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1 product comparison when you try to look at it

2 outside of the box that way. I know that

3 there are certain diets that we do have more

4 attention, because we have seen an increased

5 number of dogs with taurine deficiency on

6 them.

7 But as a general rule, as you

8 increase protein intake, because you need

9 methionine and the methionine products of the

10 sulfur donors or methyl donors to run the

11 metabolic protein metabolism, those

12 requirements are duly increased.

13 You can see how if you meet the

14 benchmark, you know, of accrued protein

15 requirement, you don't have a sliding scale

16 for all the other nutrients. Does that make

17 sense?

18 MEMBER FELDMAN: Thank you. 

19 CHAIRMAN STONE: All right, thank

20 you. I guess I should declare an interest in

21 going through this and evaluating this

22 material.
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1 I recognize that my wife and I

2 feed two Great Pyrenees an organic diet that

3 has synthetic taurine added. Dave, you're up,

4 and Sharon Sherman is on deck. So before you

5 start, Dave, and I'm sorry I didn't do this

6 before for Leslie.

7 The green light goes for three

8 minutes; the yellow light goes for one; and

9 then the obnoxious red beep.

10 MR. CARTER: All right, thank you. 

11 Just figure thanks to you friend, a little

12 levity here. Mr. Chairman and members of the

13 Board, I'm Dave Carter, a refugee of this

14 group. For a time with National Bison

15 Association, itinerant consultant here today

16 on behalf of the Pet Food Institute.

17 I don't want to go through the

18 whole ten-year history of where we've been,

19 but let's go to 2008, when the NOSB

20 unanimously adopted the Pet Food Task Force

21 report, and as a part of that, there was a

22 list of ingredients that would likely have to
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1 be petitioned.

2 On that was essentially the list

3 of amino acids, and that was really the

4 genesis for us taking a look at if those amino

5 acids were going to have to be petitioned,

6 could we petition them as a category,

7 particularly knowing that the pet food

8 standards, when they come out later this year,

9 would be in the livestock area, and in

10 livestock you are allowed vitamins and

11 minerals which FDA allowed.

12 So that was sort of the genesis of

13 trying to approach that as a category. 

14 Obviously, the TAP report and the Livestock

15 Subcommittee took a different view of that,

16 much narrower view, and the recommendation for

17 taurine only for cats came forward.

18 When we saw that, we convened,

19 then, a group of nutritionists and

20 formulators, to really say okay, if it's not 

21 going to happen as a category, what really are

22 the ones that we got to, got to have, that we
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1 just are so essential that we would otherwise

2 be compromising the health of the pets?

3 That's where we came up with the

4 taurine, the methionine, the lysine and the

5 threonine as really the ones that are critical

6 to being able to make a complete and balanced

7 formulation.

8 I just want to go through the TAP

9 report. There were, you know, several areas

10 there. You're right. They did cite some

11 companies that make complete and balanced

12 formulas.

13 But if you look at those

14 companies, they are either a conventional

15 product or organic and are very limited for a

16 specific life stage of a specific species. 

17 They don't have a full range.

18 That's because specifically when

19 it comes to formulating pet food, the organic

20 industry has a lot more limited than the

21 conventional. It comes down to the fact that

22 there just isn't certified organic meat meal
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1 out there.

2 Chicken meal is the basis for a

3 lot of pet food formulations. It has a lot of

4 bioavailability. It's very dense. When you

5 formulate with fresh meat, you're starting off

6 with a product with 80 percent moisture, a lot

7 more seasonality. It's very difficult. 

8 The taurine for dogs, I think Dr.

9 Hancock mentioned that, that there's a lot of

10 literature that talks about large breed dogs

11 really having problems if they don't have

12 taurine in there. The amino acids have to be

13 bioavailable, and if you look at our written

14 comments, it goes through yes, the TAP report

15 lists the food sources.

16 But we go through there and talk

17 about they're either not available, or they

18 are not good sources, and that's very

19 difficult. It talks about the raw diet, and

20 if you look in the TAP report, it talks about

21 the fact that pets can die sometimes when they

22 eat that. That's not really a reason to move
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1 forward on that.

2 So formulators have to be able to

3 do the right balance or the right nutrients

4 for all sizes, for all life stages for both

5 species. That's where we feel that those four

6 amino acids at least provide the tools for

7 them to be able to do that.

8 We have to have a chance. Pet

9 food owners or pet owners have one chance

10 every day, one or two chances every day to get

11 it right. Those animals get all of their

12 nutrients from that bowl of food.

13 It's not like us, that if we eat a

14 product and it doesn't have everything we

15 need, we'll be eating a banana or an apple or

16 something later on in the day. That has to be

17 a complete and balanced nutrient-dense diet. 

18 Then finally, growth in the

19 organic pet food sector really helps all

20 organic farmers. As a livestock producer, you

21 can't make a living selling only organic

22 tenderloin strips and ribeyes.
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1 Unless you can get some premium

2 out of hearts, liver, trim, those other

3 things, you can't just make a go at it. So

4 it's very important for the pieces of the

5 puzzle. Thank you.

6 CHAIRMAN STONE: Thank you, Dave. 

7 Questions. Tracy?

8 MEMBER FAVRE: Is the situation on

9 amino acids mitigated at all you combined a

10 canned food with like a dry kibble?

11 MR. CARTER: The difficulty is the

12 most in the dry kibble, yeah, because of the

13 heat processing and the degradation. That's

14 where if you look at some of the products,

15 that it's very either limited, that it's not

16 for all life stages, or it's simply in a

17 canned product. So yeah, the degree of

18 difficulty is harder in a dry diet.

19 MEMBER FAVRE: Just to clarify. 

20 So you're saying if you combine a dry and a

21 canned together, you sort of offset some of

22 the impact of that?
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1 MR. CARTER: You offset some of

2 the impact of it, yeah.

3 CHAIRMAN STONE: Francis.

4 MR. CARTER: Some is the operative

5 word.

6 MEMBER THICKE: Thanks Dave. I

7 was looking on the petition. On page 44, it

8 lists the various ten essential amino acids,

9 and it has sources. I see that for threonine,

10 methionine, lysine that are plant sources. 

11 Can you explain what the difficulty is in

12 using those?

13 MR. CARTER: Well, if you look,

14 you know, those, some of the sources that they

15 have on there are the meals, the meat meals,

16 chicken meals that we have. Gluten is a

17 source of those, but if you take a look at our

18 written comments, we talk about the balance of

19 that, it's very difficult to achieve the right

20 balance.

21 You know, the problem that we have

22 is that not only do you have to have those in
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1 there; you have to have the right balance of

2 all of those, and that's the degree. The

3 other thing is that right now, and the reason

4 that we have focused on the NRC and not AFCO,

5 is that NRC is the basis for those.

6 There's six different tables in

7 the NRC that talk about different species and

8 different life stages. AFCO is being updated

9 as we speak to reflect the 2006 NRC. A lot of

10 what is in AFCO right now even goes back to

11 1974 NRC. It's being updated.

12 If you take a look at the proposed

13 updates, those levels are being increased, and

14 that's part of the reason we say yes, we need

15 to have that, because the levels of lysine and 

16 methionine and threonine are being increased

17 under the new proposed AFCO regs.

18 MEMBER THICKE: So it's easier

19 just to balance those if they're synthetic,

20 because you can just put the right amounts in.

21 MR. CARTER: You can put the right

22 amounts in and achieve that balance you need,
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1 because one some of the amino acids, not only

2 do you have to hit the minimum, but if you go

3 too high on them, you start to run into some

4 problems as well. 

5 So it's a real delicate balance

6 these folks are doing that and when they're

7 dealing with the, you know, the whole muscle

8 meats and those types of things rather than

9 the meals, it's really a challenge. By the

10 way, welcome to the NOSB. Congratulations on

11 your appointment.

12 CHAIRMAN STONE: Thanks, Dave. 

13 For those of you who weren't aware, Dave's the

14 former chair of this group. So again, I have

15 appreciation for what this little thing means

16 here. Sharon Sherman is up, and Mohamed Mousa

17 is on deck.

18 MS. SHERMAN: Thank you very much

19 for the opportunity to meet with you this

20 morning, and I want to tell you how much we

21 appreciate it.

22 I've been a member of the Pet Food
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1 Task Force since 2004. It's been my passion. 

2 Animals are my passion. In 1978, my husband

3 and I co-founded the first natural food pet

4 company, and we used as guidelines to create

5 our natural food the AFCO guidelines, because

6 we were of the mind of do no harm.

7 So we followed that information. 

8 Our ingredients were a little bit different,

9 in that we used no byproducts, that we wanted

10 to have whole foods, and we wanted to use

11 chelated minerals, an alternate source of

12 minerals, and keeping in mind it was always do

13 no harm.

14 With the complete understanding,

15 as Dave mentioned, this is their food. Like

16 an infant ingests this formula for a certain

17 period of time, or lucky enough to be breast18 fed. So it's a certain period of time.

19 But these animals, it's their

20 entire life. They must have a supplemented

21 diet, because they simply do not have the

22 ability to synthesize some of the amino acids.
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1 We seem to learn by our mistakes. 

2 In the 80's, many people came home. They

3 would have the spontaneous instances where

4 their cats had heart attacks or they were

5 going blind. In the 80's, they discovered

6 they have a taurine deficiency.

7 So automatically, it was the

8 demand of AFCO to add taurine to commercial

9 pet food. That was a mandate and we did it,

10 and it relieved those symptoms.

11 So I'm here today to basically say

12 the same situations exist today. We must have

13 these nutrients. Everybody knows that organic

14 is the gold standard and they moved towards

15 that. Why did they move towards that? 

16 Because they want a better diet for their pet.

17 A lot of people are having results

18 with the change to the organic diet. But we

19 just need to make sure that they're able to

20 have the essential nutrients, so that we don't

21 have a blow-up with a person that's committed

22 to using organic pet foods.
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1 So I'm just asking you to please

2 reconsider and study the use of the essential

3 amino acids in pet foods. Thank you.

4 CHAIRMAN STONE: Thank you. Are

5 there any questions? Sharon. Harold?

6 MEMBER AUSTIN: If the proposal

7 that we've presented were to go through as

8 it's written today, what impact would it have

9 on your business and other organic

10 stakeholders such as yourself, long-term?

11 MS. SHERMAN: Not having the amino

12 acids? Is that what you're saying?

13 MEMBER AUSTIN: Yes.

14 MS. SHERMAN: Well, we're of the

15 mind do no harm. I don't know karmically

16 whether I could actually create a food that I

17 would know, that there could be issues,

18 because how can you do something like that? 

19 I mean knowingly, you know, with all the

20 information, all the scientific data, how can

21 we do that?

22 You know, if the people knew that
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1 the gluten was contaminated, would they have

2 put it in the food, you know? There's so many

3 examples. If they knew they needed taurine,

4 they would have put it in beforehand, without

5 so many cats dying and becoming blind, you

6 know, or other issues.

7 CHAIRMAN STONE: All right. Thank

8 you very much, Sharon. Mohamed is up and

9 Daniella Steiner is on deck.

10 MR. MOUSA: Good afternoon or good

11 morning, ladies and gentlemen of the NOSB, and 

12 Mr. McEvoy and NOSB, thank you very much for

13 letting me talk.

14 I have so many thousands of

15 chickens I couldn't be here today, so they

16 send me here to talk to you. I also need some

17 methionine, like everybody else before me.

18 Methionine is very essential amino

19 acid, like what you see. Its component is

20 hydrogen, nitrogen and carbon and sulfurs and

21 oxygen. There's two types of methionine

22 manufactured, the L-methionine and hydroxy
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1 analog. It's a limiting amino acid.

2 We used to be at four point, four

3 pounds per ton of feed. It's .2 pounds from -

4 - .2 from the ration. It's very, very

5 essential to the welfare of the birds. 

6 History. The NOSB recommendation

7 were at four bound, when to two bound from

8 October 1st, 2012. One thing happened here

9 that who made the recommendation or applied

10 the ruling missed a big, big factor in the

11 animal production, and animal health in

12 general.

13 Birds have different need in

14 different stage of life. That was neglected

15 here, and I ask the Board and I ask the

16 program to correct it. It's really not good. 

17 We see a lot of bad things, and animal welfare

18 is a major, major concern of mine and other

19 producers.

20 The start-up birds needs a higher

21 level of methionine. Hence during production,

22 sexual maturity, I can tell you right now I
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1 have birds that are four weeks behind in their

2 maturity. They eat their feather. Birds at

3 17 and 18 weeks don't have any feather in

4 their necks, don't have feather in their tail.

5 I don't want to give the pictures

6 there because it's really depressing. 

7 Methionine is very, very essential to the

8 birds, because the birds is omnivores. It's

9 just like cats and dogs. If you don't feed

10 them their amino acid, it's a sulfur amino

11 acid. It's restricted. It's a limiting

12 factor. All the other amino acids will work

13 to the level of methionine.

14 Just like you have a barrel and

15 you make a hole in the middle. You're not

16 going to fill that barrel with water. You're

17 going to fill only where that hole is. 

18 Methionine is very important for the

19 bioavailability of the other levels of amino

20 acids.

21 So the heart, pancreas, immune

22 system, feather follicle. Birds like, I look
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1 at them as a very beautiful young lady. If

2 they don't have their feather, you see, you

3 look at them, they feel very sad. I see that.

4 I completed today 50 years and five days

5 working with chickens. I'm 59 years old, so

6 I started from very, very young age.

7 Well what do we need to do. I ask

8 the Board and the program, I'm not asking for

9 more methionine, but I ask it only for putting

10 the word average, and let me handle that and

11 get the certifier to talk to me when he comes

12 to audit my farm. Keep it for five years. 

13 Encourage research. Let's get some science

14 and data to support future regulations.

15 I was approached by two

16 scientists, two universities to serve in a

17 board for overseeing their research. There's

18 two over here now is was working with USDA,

19 was getting some grants, and we will help

20 them. 

21 CHAIRMAN STONE: All right. Thank

22 you very much. If there are questions? 
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1 Calvin.

2 MEMBER WALKER: Thank you, Dr.

3 Mousa. Could you share again some of the

4 impact of the step-down on your operation, as

5 far as animal welfare?

6 MR. MOUSA: The birds have a very

7 minimum recommendation or requirement they

8 need, according to the other ingredients. 

9 It's a holistic approach for what we put in.

10 Organic ingredients, which it will

11 be soybean meal and corn. That's, you know,

12 there's not too much stuff available for

13 organic we use, contains a high level of

14 protein.

15 So when we use, let's say the

16 maximum from everything, and we still have

17 deficiency, what happens, the birds cannot

18 grow when there are babies by the same rate

19 which they are supposed to grow. The other

20 thing is during the sexual maturity, from 12

21 to 18 weeks, the birds need that amino acid.

22 Not only methionine, but the
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1 better of amino acid, and because methionine

2 is a very limiting amino acid, they can't do

3 it. So the oviduct and the ovary developed

4 was less. 

5 The oviduct and the ovary is the

6 machine which makes the eggs, which give the

7 production for the farmer. The farmer don't

8 get the eggs. The bird's behavior, I can tell

9 you, I've seen birds very aggressive. When

10 feather falls from a high place from the

11 perch, the birds, 100 or so, jump on there,

12 try to pick up that feather.

13 In our houses, there is not a

14 single feather in the floor. The birds eat

15 the feathers from each other and from the

16 floor also. I'm really asking for the animal

17 welfare issue and not the production issue. 

18 This recommendation over here are

19 calculated by Dr. Willy Williams, and this is

20 the bare, bare minimum for requirement of the

21 bird. I would like to give him his thanks for

22 his help to me on that.
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1 CHAIRMAN STONE: Wendy.

2 MEMBER FULWIDER: What about

3 ammonia in the buildings? 

4 MR. MOUSA: Wendy, I thank you for

5 that questions. We have Amish contractor

6 growers in Indiana, and when we visit their

7 farms, and forgive me, because I am going to

8 tell you that with sadness, I've seen a lot of

9 ammonia level exceeded the animal welfare

10 guidelines of what we use, and also I've seen

11 several blind birds.

12 You know, in winter time, I call

13 those guys and I ask them to what I call it

14 perch the house. They turn all the fans on. 

15 Temperature sometimes goes to 50 degrees and

16 less on the birds. There are other birds that

17 lost most of their feathers. I don't like

18 that at all, and sometimes they pile and

19 suffocate.

20 CHAIRMAN STONE: Nick.

21 MEMBER MARAVELL: Yes. Could you

22 just explain why it's not necessary to make a
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1 recommendation for the first 17 weeks?

2 MR. MOUSA: Can you repeat the

3 question, please?

4 MEMBER MARAVELL: I looked at your

5 -- if you want to go back to your

6 recommendation slide. Just explain why it's

7 not necessary to make any methionine

8 recommendation?

9 MR. MOUSA: No, it is very

10 necessary. When I start, when I start my

11 presentation, I said from baby chick up to 18

12 weeks, it's different stage of growth. But

13 over here, that's when the birds suffer the

14 most, because they start to develop their egg

15 machine, you know. That's when they need it

16 the most.

17 MEMBER MARAVELL: But did you have

18 any specific recommendation, because the feed

19 is different during the first 17 weeks as

20 well?

21 MR. MOUSA: Yes. The

22 recommendation will be as it's stated, it will
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1 be about 2.95. But during the 17 weeks, let's

2 just take from 12 weeks, because that's the

3 time we start to increase a little bit. 

4 Between 12 and 18 weeks, you come to about the

5 middle, and it goes up to approximately 2.8,

6 2.7 and that, and all that, the added

7 methionine will depend on what's in the

8 soybean meal and also in the other

9 ingredients.

10 CHAIRMAN STONE: Thank you,

11 Mohamed. 

12 MR. MOUSA: Thank you very, very

13 much. Appreciate it.

14 CHAIRMAN STONE: Daniella Steiner

15 is up, and George Kimbrell is on deck.

16 MS. STEINER: Hi. My name is

17 Daniella, and I'm just a regular person. I'm

18 not a scientist. I don't work in the food

19 industry. I don't usually talk to people in

20 suits sitting around the table like that, but

21 I eat every day, usually a couple of times.

22 I'm really interested in what my
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1 food is and where it comes from, and I feel

2 like I'm more curious about it than most of

3 the people I know. Even I don't have time to

4 read all the articles, and I don't understand

5 all the science behind it. 

6 I don't have a car. I'm not going

7 to go to all the farms that my food comes

8 from, so I have to trust somebody to give me

9 appropriate information.

10 I have an awesome co-op. I really

11 trust their guidelines there. They send

12 people to all the farms that, the farmers from

13 the farmers market there, and they actually

14 visit them several times a year.

15 So I totally trust that, and I

16 feel like for an advisory board and a

17 regulatory board, that I want to really trust

18 the guidelines that you're laying out, and

19 that it's not advertising, you know, that it's

20 actually just information.

21 Because advertising is to give you

22 permission to believe what you really want to
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1 believe, even though it's probably not true,

2 right. I just want the real information. So

3 if I'm at the store and I'm thinking about

4 buying some eggs, and there's two cartons of

5 eggs, and one is $2.50 and one is like $6.00,

6 I'd rather buy the cheaper one if it's just as

7 good. And look, they both say they're organic

8 and they have access to the outdoors, right?

9 But the one, the access to

10 outdoors is a little tiny door in the way back

11 of the henhouse that none of them are ever

12 going to find, and the outdoors, it's like a

13 little tiny patch of dirt, which like maybe if

14 they took turns, they could each go out there

15 for like two minutes ever, right.

16 But in my mind, there's a picture

17 on the front of the carton. It's a third,

18 it's outside, and that's what I'm picturing.

19 And so, and that's probably the reality of the 

20 expensive eggs. But why am I going to spend

21 three or four dollars more if I'm led to

22 believe it's just the same?
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1 So the organic chickens should

2 have reasonable access to outdoors, and a

3 reasonable amount of space once they get

4 there, so they can all go outdoors for as much

5 of the day as they want, and eat bugs like

6 they're supposed to, yes?

7 And something like carrageenan,

8 like no independent research has suggested

9 that it's safe for human consumption. I'm

10 going to assume that something like that isn't

11 in some food that I'm buying that says

12 organic. But it's in there. Only industry

13 has suggested that it's safe. The people that

14 are going to make money from me eating it.

15 For antibiotics, organic animals

16 aren't allowed to have antibiotics. Who's

17 going to think that organic plants are getting

18 antibiotics on them. So why are the

19 antibiotics allowed on organic apple and pear

20 trees?

21 And now we're talking about

22 farming shrimp, yeah? So it's just another
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1 feedlot. The animals are too close together. 

2 They're eating food that's not what they're

3 naturally supposed to eat. 

4 What happens to all their waste? 

5 It's totally polluting the water. But it says

6 "Oh, like this is organic shrimp. Now I can

7 feel good about eating it, and I'm not going

8 to look into all the information and find out

9 what's really going on, yeah?"

10 So me and all the other regular

11 people out there, we're all trusting you guys

12 to give us useful information, so we can make

13 the decisions that we want to make, and not

14 just let us believe something and then give us

15 whatever. Thank you.

16 CHAIRMAN STONE: Thank you very

17 much. Questions. Tracy.

18 MEMBER FAVRE: Were you here

19 during the presentation on the aquaculture

20 about an hour ago?

21 MS. STEINER: I was not, but I

22 heard a little bit about it.
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1 MEMBER FAVRE: Well, the reason I

2 ask is because there was some discussion about

3 where the waste products go in aquaculture,

4 that it's actually very similar to what the

5 natural biology would be anyway, or the

6 biosphere would be anyway. 

7 So you might want to read up on

8 that. It's actually fairly interesting. 

9 MS. STEINER: Well, just like what

10 I've read from feed lots for land animals,

11 it's just so many animals in such a small

12 amount of space, that there's a huge amount of

13 waste and it has to go someplace, and I think

14 that nobody really wants to live near the pig

15 feed lot. Yeah, there's just so much waste.

16 So it can't disperse naturally,

17 and I feel like it would probably be the same

18 for animals in the water.

19 CHAIRMAN STONE: Thank you very

20 much. Oh, I'm sorry. Ma'am, one more

21 question, real quick ones. What's your co-op

22 that you love so much?
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1 MS. STEINER: People's.

2 CHAIRMAN STONE: Okay.

3 MS. STEINER: And our farmers

4 market is this afternoon, if y'all want to

5 come.

6 CHAIRMAN STONE: Okay, thank you,

7 and how did you hear about the meeting?

8 MS. STEINER: From the Cornucopia

9 Institute.

10 CHAIRMAN STONE: Okay. Thank you

11 very much. George Kimbrell is up and Richard

12 Fulton is on deck.

13 MR. KIMBRELL: Good morning. 

14 Thanks for the opportunity to testify. My

15 name is George Kimbrell, and I'm the senior

16 attorney with the Center for Food Safety. You

17 know us. We're a non-profit. We work on a

18 lot of different organic issues, and today I

19 am here to talk about aquaculture.

20 So you heard quite a bit about it

21 this morning. As Paul Harvey used to say,

22 this is the rest of the story. In four
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1 minutes, I'm not going to be able to counter

2 some of the things that were said in the 25

3 minute presentation that you got, but I have

4 a five-page testimony that I'm submitting with

5 about 20 footnotes.

6 We've also, I've testified on this

7 since 2005 going forward. All of that is

8 integrated here and in the record. So I'll

9 try to summarize a few main points in the

10 limited time I have, and I want to be clear

11 that what I'm talking about here is finfish,

12 predatory, carnivorous aquaculture that's

13 going to be in net pens.

14 I think our position is with

15 regards to production of herbivorous fish that

16 would be in closed systems, we think that

17 could be organic and in line, in accordance

18 with the law and the principles of organic,

19 but not with regards to open water net pens,

20 and not with regard to wild feed used for the

21 main -- wild forged feed used as the main

22 source of fish meal for these animals.
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1 The first one I want to make is

2 that this was a very acrimonious process back

3 in 2006-2007, when it began. If you're not

4 aware of that, you should be made aware of the

5 history of it. I believe the only protest

6 demonstration in NOSB history took place at a

7 meeting in 2007.

8 There were numerous sign-on

9 letters from broad coalitions of fishing

10 groups, as well as environmental groups and

11 consumer groups like mine, opposed to the

12 recommendation.

13 Of course, the recommendation

14 originally prohibited net pen aquaculture as

15 well as wild feed from foraged fish to be

16 used, and then did 180 degree reversal on

17 those two issues.

18 So I think the bottom line for us

19 is that this is contrary to sound science, to

20 good policy, to good governance and to OFPA. 

21 It's unlawful. I'm going to talk about why. 

22 First, with regards to net pens, just like in
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1 agriculture, not all types of aquaculture can

2 be organic.

3 Some are inherently unsustainable

4 and inherently unorganic. Net pen aquaculture

5 is one of those systems. The escape of fish

6 into the wild is an unavoidable consequence,

7 and part of the business model for net pen

8 aquaculture.

9 I'm passing out a chart here that

10 I've introduced into the record, that shows,

11 lists just the reported escapes from the last

12 several years you can see there.

13 So this has a dramatic, negative

14 impact on biodiversity. Ms. Richardson raised

15 the point of the mandate to conserve

16 biodiversity as one of the OFPA fundamental

17 standards here, and net pen open ocean

18 aquaculture is the antithesis of that.

19 Escapes cause, threaten native

20 wild populations. They spread diseases and

21 parasites, among other things. We talked

22 about the waste issue and the pollution issue
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1 here as well. I think one of the best stats

2 I've seen on that is such that, for example,

3 the farms off the coast of Scotland in one

4 year produced more waste than all the cities

5 in Scotland.

6 So they produce a tremendous

7 amount of waste that goes into the

8 environment. So when you talk about the

9 standards of promoting ecological balance and

10 conserving biodiversity, I think that's a big

11 problem here.

12 The other is the natural behavior

13 standard. Again, we're talking about salmon

14 here, which is an anadromous, migratory fish. 

15 If you're ever seen a salmon run, it is one of

16 the most breathtaking things you'll ever see. 

17 The idea that you could pen them up and that

18 would be natural behavior, I think, is a

19 ludicrous one.

20 Finally, I see I've got the yellow

21 light now. The other major issue I wanted to

22 talk about here is the feed issue. Now it's
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1 clear that feed for organic animals, livestock

2 has to be 100 percent organic. There are no

3 exceptions to that. We've got case law on

4 that. That is well-settled.

5 What the recommendation does

6 instead, and by the way we talked about how

7 the foraged fish are the irreducible. That is

8 the main course for them. That is what these

9 fish need, the predatory ones, to live. They

10 have reclassified them in the recommendation

11 as, quote, "a feed supplement."

12 Now that reclassification is not

13 going to withstand judicial scrutiny, I'm

14 going to tell you now. So that is, I think,

15 underscores, that this activity, when it comes

16 to these fish is inherently unorganic and

17 should not be certified. 

18 CHAIRMAN STONE: Thank you. 

19 Questions? Harold.

20 MEMBER AUSTIN: You made a comment

21 and then just kind of blasted past it. I'd

22 like you to clarify it just very briefly, that
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1 this process would be based off of acts that

2 are unlawful. In a nutshell, could you

3 describe what you made that comment based on?

4 MR. KIMBRELL: Thank you. That

5 last point I think I made about the feed is

6 very clear. Feed for organic livestock, 100

7 percent organic. We can't certify the Pacific

8 Ocean's forage fisheries.

9 So instead, we've made an

10 allowance here, similar to the Harvey case,

11 where they've said okay, 25 percent, doesn't

12 have to be organic. We're going to call it a

13 feed supplement. That's unlawful. 

14 Natural behaviors of the fish,

15 unlawful. You must conserve biodiversity. 

16 This is an inherently unsustainable activity,

17 unlawful. 

18 CHAIRMAN STONE: Zea.

19 MEMBER SONNABEND: Thank you. 

20 Could you explain a little more detail what

21 the problem is with the escaped fish into the

22 environment?
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1 MR. KIMBRELL: Absolutely. Well

2 first of al, as you might imagine, you've got

3 the competition with the native populations

4 that are already on the precipice of

5 extirpation, right? So you've got the

6 takeover of their habitat. You've got

7 competition for food from them, among other

8 things.

9 When they interbreed, you have the

10 reduction of their genetic diversity, and they

11 are less likely to survive in the wild,

12 because of course farm fish are not bred to be

13 able to survive in the native ecosystems the

14 way wild fish are.

15 It also spreads diseases and

16 parasites to these fish such as sea lice. 

17 We've seen this time and time again in every

18 country that has had salmon aquaculture. It's

19 destroyed the fisheries in Canada, for

20 example, the native fisheries as well as

21 Scotland.

22 CHAIRMAN STONE: Francis.
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1 MEMBER THICKE: Is your

2 organization against all forms of organic farm

3 fish, or do you have others that you approve

4 of?

5 MR. KIMBRELL: Thank you. I tried

6 to make that clear at the outset. But I'll

7 absolutely reiterate it, which is that my

8 comments are intended only for finfish or

9 carnivorous, predatory aquaculture. 

10 So closed systems, tilapia,

11 catfish, that the waste is contained, they are

12 fed vegetarian feed rather than wild, foraged

13 fish. Those things, I think, we would be in

14 favor of an organic standard for, absolutely.

15 I think when you talk about net

16 pen, open ocean aquaculture, and you talk

17 about predatory fish that require smaller

18 forged fish, by the way a dramatic negative

19 protein ratio. To grow one pound of salmon

20 takes between three to six pounds of ground

21 up, tiny forage fish.

22 So we're not solving any fisheries
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1 crisis here. We're robbing Peter to pay Paul

2 from the oceans. Those are the types of

3 things that we do not think are organic, and

4 cannot be made to be so.

5 CHAIRMAN STONE: John.

6 MEMBER FOSTER: You made a

7 reference that the one salmon operation in

8 Scotland produces more waste than all of

9 Scotland, and I really find that tough to buy. 

10 So I'm wondering what the citation is. I can

11 look that up.

12 MR. KIMBRELL: Yes. It's in my --

13 I'll give it to you right now. It's not just

14 one. It was all 350 marine salmon farms in

15 2000 produced more sewage waste, in terms of

16 nitrogen and phosphorus, than the country's

17 human population. It's footnote 9 in my

18 remarks, and the study is -- yes, footnote 9. 

19 So you have a copy of this.

20 MEMBER FOSTER: And so if I look

21 at that, I'm going to find a reference that --

22 MR. KIMBRELL: You'll find a
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1 scientific paper that confirms that, correct.

2 MEMBER FOSTER: Thanks.

3 CHAIRMAN STONE: Jay.

4 MEMBER FELDMAN: Thanks, George. 

5 I'm wondering what you think this Board should

6 do in terms of revisiting all or a portion of

7 the underlying policy that is, that we're

8 relying on here.

9 MR. KIMBRELL: Well, Mr. Feldman,

10 I think the Board should do whatever it can

11 here, you know, in terms of rethinking it.

12 I think it needs to go back to the

13 drawing board and offer to the people an

14 organic standard that actually can be organic,

15 and to the extent we're talking about

16 herbivorous, closed systems operations, rather

17 than trying to put an organic label on

18 essentially conventional, you know, operations

19 when it comes to net pens.

20 So I leave it to the Board's

21 expertise about how you might rethink that. 

22 But I think it's imperative that you do so.
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1 CHAIRMAN STONE: Calvin. All

2 right. Thank you very much, George. Richard

3 Fulton is up and Brennen Herbruck is on deck.

4 DR. FULTON: Good morning. My

5 name is Richard M. Fulton. That's what my

6 mother calls me when she's mad at me. My

7 friends call me Mick Fulton, Mick kind of like

8 Mickey Mouse.

9 The reason, first of all, I am the

10 -- have been a veterinarian for 32 years and

11 have been active in the poultry industry as a

12 veterinarian for 28 years. I am currently a

13 faculty member and associate professor of

14 avian diseases at Michigan State University. 

15 I actually work at an animal

16 disease diagnostic laboratory there, and I see

17 anything from somebody that has one or two

18 chickens in her backyard to commercial poultry

19 producers that have millions of chickens.

20 So my reason for being here

21 initially was my concern that there's a

22 possibility of eliminating all vaccines from
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1 poultry, and after I've been here to observe

2 what's going on, it appears to me that you

3 guys are just struggling with definitions.

4 I applause you for trying to

5 figure this out. It's very complex. Even me

6 as a scientist, sometimes I don't understand

7 some of those things, and the other thing I've

8 seen is I've dealt with some of those backyard

9 people.

10 They want to also raise what they

11 call organic. They chose not to use vaccines. 

12 Their birds die from diseases that are easily

13 preventable, especially with vaccines. So the

14 thing that I would recommend that you do is

15 please don't forget about the resources that

16 you have.

17 We have a great number of

18 universities of higher learning with

19 veterinary faculty and scientists on staff,

20 who have nothing to try to sell. They're

21 there for information, and I'm sure that

22 they'd be glad to work with you and be able to
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1 help that process.

2 The other proviso is that I do

3 know of one vaccine that is actually

4 genetically altered. It's a vector vaccine. 

5 That vaccine is excellent, and I recommend it

6 to people because it does not spread the

7 disease. 

8 There are some vaccines, and most

9 vaccines are derived from finding something in

10 the wild, changing it by either growing it at

11 different temperatures, something like that, 

12 and putting it in chickens to protect the

13 chickens.

14 But if there is one disease called

15 infectious laryngotracheitis that is caused by

16 herpes virus, if you use that vaccine in

17 chickens, it will spread and it will cause

18 disease. So there is a good use of that

19 vaccine, which is there's a vector vaccine

20 that has just a small protective portion of

21 that.

22 So anyway, that's my, the end of
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1 my presentation. If you have any questions,

2 I'll be happy to answer them.

3 CHAIRMAN STONE: Very good. 

4 Questions from the Board? Jean.

5 MEMBER RICHARDSON: Not as much a

6 question as a comment. You could be

7 absolutely certain that we're all on the Board

8 very much aware of the fact that the poultry

9 industry is one of our areas of complexity,

10 and there's no way that we're going to prevent

11 the use of vaccines in poultry, because

12 obviously it is important to have healthy

13 stock at all times.

14 So it's working it so that it --

15 coming up with something that works overall is

16 what we're trying to do over the long run. 

17 DR. FULTON: Very good, thank you.

18 MEMBER RICHARDSON: Thanks very

19 much for your comments.

20 CHAIRMAN STONE: Nick.

21 MEMBER MARAVELL: Yes, just

22 another comment. Jean and I served on the
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1 Working Group. This Board does not try to

2 take action, which would be overly disruptive

3 to producers, so that anything we did would

4 have to be taken and take industry practice

5 into account.

6 Our intention is to have a safe

7 food supply here and a healthy livestock. So

8 we're going to take those things into account.

9 DR. FULTON: Very good. Sounds

10 like you're working with me.

11 CHAIRMAN STONE: All right. Thank

12 you very much. So Brennan Herbruck is up, and

13 David Will is on deck.

14 MR. HERBRUCK: Hello. My name is

15 Brennan Herbruck. I'm a fourth generation egg

16 farmer from Michigan. I'm responsible for

17 approximately 100,000 organic-laying hens

18 located across several small farms.

19 Over the last few months, I have

20 seen young hens being affected by the two

21 pound per ton limit on methionine. Some of

22 the symptoms I have encountered are hens
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1 pecking the feathers off each other. I've

2 seen resulting injuries where they've actually

3 died from that.

4 The hens are also eating all the

5 lose feathers that they can find on the

6 ground. This indicates to me that they are

7 not receiving enough methionine in their feed,

8 and are trying to get it from any other source

9 that they can.

10 They've also been eating their own

11 eggs that they can find. They kind of peck at

12 it, and then they try to get something out of

13 that. The welfare of the hens is being

14 jeopardized by the lack of methionine in their

15 early life. They will find methionine from

16 other sources like the bodies of other hens if

17 they cannot get it in their diet.

18 This really concerns me about the

19 welfare of my hens, as it seems like abuse to

20 arbitrarily restrict the important nutrient

21 from them at a critical stage of their life,

22 and the resulting pecking is definitely a
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1 welfare concern, because it will lead to

2 higher death loss in my houses. That's it.

3 CHAIRMAN STONE: Very good, thank

4 you. Questions? Calvin.

5 MEMBER WALKER: Could you give us

6 a rough, maybe a percentage of your birds that

7 shows that feather-picking tendency and

8 percent death?

9 MR. HERBRUCK: Probably about ten

10 percent of the ones that died.

11 CHAIRMAN STONE: Harold.

12 MEMBER AUSTIN: If we don't make a

13 modification to the methionine ratios that are

14 on the books now, what long-term impact would

15 that have on your operation? 

16 MR. HERBRUCK: I think this will

17 just continue, and just, if there is no step18 down especially, it will make it much worse. 

19 Yes, it will just keep continuing like this

20 and make it worse.

21 MEMBER AUSTIN: Make it worse. 

22 Would you be able to continue to do business? 
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1 Would you choose to continue to do business

2 with the effects that it would be having on

3 your stock?

4 MR. HERBRUCK: I'm not really

5 sure. I can't speak to that.

6 MEMBER AUSTIN: Okay, thank you.

7 CHAIRMAN STONE: Nick.

8 MEMBER MARAVELL: What did you

9 think about the recommendations that were put

10 up, in terms of stepping up and stepping down

11 the use of methionine through different stages

12 of production?

13 MR. HERBRUCK: I think that's a

14 good recommendation. They do have different

15 requirements throughout different stages of

16 their life. So I would support something like

17 that.

18 CHAIRMAN STONE: Could you briefly

19 describe the general management practices that

20 you use for your birds, your housing, their

21 access to the outdoors, the type of feed they

22 have available to them?
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1 MR. HERBRUCK: Well, they are

2 certified organic. They have access to the

3 outdoors, to sunlight, to the ground, to

4 grass and dirt, and they have areas that go

5 inside. We are in the north, so they do have

6 to be inside in the winter, so they don't get

7 any access in the winter.

8 CHAIRMAN STONE: All right. Thank

9 you very much. David Will will be the last

10 presenters in the livestock session.

11 MR. WILL: Hi. My name is David

12 Will. I'm the general manager of Chino Valley

13 Ranchers, a Southern California-based organic

14 egg producer. I'm also the chairman of the

15 United Egg Producers Organic Egg Committee,

16 and I am one of the founding members of the

17 Methionine Task Force, at which my comments

18 are directed towards.

19 I want to thank you first for the

20 time and for hearing our public comment, and

21 I also wanted to let you know that the

22 Methionine Task Force is a group based of
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1 about 15 like-minded producers in the broiler,

2 layer and turkey industry, and of those 15

3 producers, we represent about 200 organic

4 family farms, anywhere from 1,500 to 18,000

5 layers, single family farm businesses in

6 addition.

7 That includes everything from a

8 pasture-based system all the way to an

9 organic-based system. In the past, the

10 Methionine Task Force, we've been here since

11 about 2007 presenting to you.

12 Things that we've done and looked

13 at in the past is we funded a high methionine

14 corn study. We did our own trial within our

15 company of 15,000 sister birds that we fed

16 zero additional methionine to. Those were in

17 a cage-free operation. They were not

18 organically fed.

19 We've done a literature review of

20 all literature out there on methionine in the

21 world, and I have just passed out to you a

22 current study that we funded through the
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1 University of Pennsylvania and University of

2 North Carolina.

3 While the Task Force funded the

4 study, we have retained absolutely zero

5 editorial rights on the study, and they intend

6 on publishing it in Poultry World magazine. 

7 We wanted to thank you from the

8 Task Force for delaying our petition from this

9 meeting 'til the October one, mainly because

10 we'd agree with you. There is no time to

11 really look at the total impact of the step12 down.

13 We've only had 27 weeks since the

14 step-down went into effect on October 1st of

15 2012, and if you look at that, it takes 24

16 weeks to get an organic layer from day of age

17 to realistic egg production.

18 So we anticipate that only about

19 five percent of the eight million plus organic

20 layers have been raised and are actually in

21 full lay, based on just the timing of

22 replacement of flocks with the 70-week
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1 replacement cycle.

2 We think that we will have a lot

3 more information to give you at the summer. 

4 We will have the conclusion of our study. 

5 We're also now feeding a much higher level of

6 feed, because in cold weather, birds eat more

7 and so they are in direct getting more

8 methionine.

9 Throughout the summer, we

10 anticipate some of the effects being a little

11 bit more severe, from the fact that they're

12 being fed less methionine, because they'll be

13 down about 25 percent in total feed

14 consumption.

15 Right now, we're having producers

16 tell us they've had no issues to, or having

17 minor or moderate issues which have ranged

18 from bird health issues and the ammonia levels

19 in the farms due to overfeeding of protein, a

20 wetter dropping, feather issues.

21 Also at the Anaheim Expo, I had

22 two different organic certifiers come up and
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1 talk to me, and both of them said that their

2 certifiers going into the farms have noticed

3 issues with the birds, just from the last time

4 they were there, on either environmental or

5 physical appearance. 

6 In fall of this year, we will

7 present the study for you, and we will also

8 bring a large group of individual family farms

9 to take a look at everything, and so that you

10 can hear firsthand from them what the change

11 has been.

12 What we're mainly asking for is

13 the change, that we go to a two-pound average,

14 because we don't feel you should feed an

15 infant the same rate you should feed a

16 teenager, that you should feed a senior

17 citizen.

18 We want to work with our

19 certifiers in order to get a method that they

20 feel they can certify on the farm level, that

21 guarantee that we still have that two pound

22 average over the life of the bird, instead of
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1 the hard cap. 

2 That's our goal. Thank you very

3 much for your time, and I didn't make it. Oh

4 well. Thank you. 

5 CHAIRMAN STONE: Sorry. I think -

6 - oh Tracy, questions?

7 MR. WILL: Yes.

8 MEMBER FAVRE: Not so much a

9 question as a request. Since we will be

10 addressing this issue at the fall meeting, I'd

11 really appreciate if you guys do communicate

12 with us as much as you're able to prior to the

13 report coming out, so that we can use that as

14 part of our deliberations.

15 MR. WILL: Yeah. The contact

16 information for the professors is on here. I

17 can get you information. Like I said, we just

18 funded the study. After that, we're

19 completely hands-off.

20 So we have invited them to come

21 and have offered to pay for them to come to

22 this group, to make a presentation. Any time
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1 that would be allowed for their presentation,

2 we'd be appreciative of as a group.

3 CHAIRMAN STONE: Thanks, Dave. 

4 MR. WILL: Thank you, sir. 

5 CHAIRMAN STONE: So Terry Shistar,

6 just so you know. You're still at top of the

7 list of the timing, and we're just figuring

8 out what the prize is at this time. 

9 Madam Chair, that concludes the

10 public comment for the Livestock session.

11 MEMBER FAVRE: Okay. Thank you,

12 Mac. I think that next on the agenda is

13 actually a break for the Subcommittee, to

14 modify proposals as needed. Mac, do you have

15 any -- since you're, really have the only

16 proposal, do you have any feedback on that?

17 CHAIRMAN STONE: Yes ma'am. I'd

18 like to get the committee together and

19 evaluate a recommendation based on public

20 testimony, and maybe we'll bring something

21 back tomorrow for a vote.

22 MEMBER FAVRE: Okay. So basically
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1 everybody, it looks like we're going to

2 postpone the vote on the pet food amino acids

3 until tomorrow, if everybody's okay with that.

4 CHAIRMAN STONE: So maybe we can

5 either meet at lunch or tonight or something

6 and discuss what we've heard. Jay.

7 MEMBER FELDMAN: So we'll -- can I

8 ask a question about it, so that maybe the

9 Subcommittee could consider it? I'm still a

10 little unclear as to whether a high animal

11 protein diet that is available on the market

12 currently, maybe not as organic, does not

13 require the addition of the amino acids and

14 specifically the taurine.

15 If that is the case, I'd really

16 like to get clarification on that. I've been

17 on their website, Nature's Logic. I don't

18 know if that's one of the ones you looked at

19 when you did your survey.

20 But I really think we need an

21 answer to that question, because if it is

22 available, it's really, I think it's difficult
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1 to make an essentiality argument. Thanks.

2 CHAIRMAN STONE: Okay. Okay. So

3 that concludes the morning session. It's

4 11:30. We will break for lunch. I think

5 because this afternoon is so tight, we want to

6 have as much time as we can. We'll take an

7 hour and 15 minutes. 

8 Before you leave, a couple of

9 notes. They are going to lock the room,

10 because there's another conference across the

11 hallway, and access to outdoors. So your

12 computers and all your things will be fine. 

13 They'll open it up obviously a little while

14 before we come back.

15 But let's come back at 12:45

16 promptly to start the Crops Committee. Thank

17 you.

18 (Whereupon, the above-entitled

19 matter went off the record at 11:29 a.m. and

20 resumed at 12:50 p.m.)

21

22
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 (12:50 p.m.)

3 CHAIRMAN STONE: If I could have

4 everyone's attention, we'll get started for

5 the afternoon session. We broke a little

6 earlier for lunch.

7 The panelists are here. They're

8 prepared for the presentation. We just want

9 to give ourselves as much time as we can for

10 this spirited debate that we're engaged in at

11 this time.

12 I want to remind the audience as

13 well as Board members that we've had the

14 luxury of time to ask numerous questions of

15 various presenters. We've had the luxury of

16 time for the presenters to give lengthy

17 answers.

18 But in the effort, we'll have to

19 just watch the clock and if presenters, don't

20 be offended if I have to cut you off or Board

21 members not be offended if I encourage you or

22 I don't call you in the effort of time. So
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1 just a reminder that we have this luxury the

2 last couple of days and don't get spoiled at

3 all. 

4 So, so. I'm excited. We're

5 scheduled to quit at 5:30 or something, but

6 certainly 5:40. Certainly, if we're doing

7 good and having the right kind of

8 conversation, we'll certainly let it -- I'm

9 not opposed to letting it run a little bit

10 long.

11 But at some point, there's

12 diminishing returns or not new information and

13 that kind of thing. So Jay, I'll turn the

14 program over to you.

15 Crops Subcommittee

16 MEMBER FELDMAN: Thank you Mac,

17 and welcome back from lunch everybody. We

18 have an exciting panel to help introduce a

19 discussion on the petition for tetracycline

20 use in apple and pear production.

21 We have four speakers on the panel

22 this afternoon, and we've asked each speaker
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1 to present about a ten minute introduction of

2 the issue from their perspective, and then we

3 as a Board will follow up with about a half

4 hour of questioning, and then we'll go into

5 our presentations.

6 The first speaker will be Dr. Ken

7 Johnson. Dr. Johnson is a professor of Botany

8 and Plant Pathology and has been since 1999 at

9 Oregon State in Corvallis. He has a Ph.D. in

10 Plant Pathology from the University of

11 Minnesota, an M.S. in Plant Pathology and a

12 B.S. in Plant Health Technology.

13 Dr. Johnson's major research

14 interests include plant disease, epidemiology,

15 with emphasis on disease and innocular

16 dynamics, management, strategies, disease

17 impact assessment.

18 We know Dr. Johnson from his work

19 with the e-Organic webinar, which we really

20 appreciate you holding over the last year or

21 so, and we also know that he drives a mean van

22 and took us around the Mount Hood
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1 neighborhood. So thank you, Dr. Johnson, for

2 being here.

3 DR. JOHNSON: I guess speaking to

4 the Board is pretty easy, because I think most

5 of you have probably seen my webinar, and I

6 drove you around for a day in Hood River. So

7 we went out and looked at different orchards.

8 For everybody else, my part in

9 this has been to look at the development of

10 alternative approaches to fire blight control

11 in organic orchards, and we have had a several

12 year project now, a research project through

13 the OREI, to investigate just that.

14 I actually go back in fire blight

15 in looking at alternatives to antibiotics for

16 about 25 years. So I've got a long experience

17 in this area.

18 Our project the last three, four

19 years has sort of been to take a systems, we

20 call it a systems approach, and we're looking

21 at a lot of different issues in fire blight. 

22 When does the pathogen become active. Can we
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1 use sanitation to suppress the pathogen early

2 before bloom.

3 Things like interactions with

4 bloom thinning, and then products that would

5 be effective during the mid to late bloom

6 periods, that are when you need to protect

7 flowers from fire blight and to prevent

8 infections in your orchards.

9 In that regard, we've become

10 interested in two products. There's lots of

11 products that give some activity in fire

12 blight control, and many of them are organic. 

13 But two of them that we've been especially

14 interested in has been this yeast material

15 called Blossom Protect. It was registered by

16 the EPA last year.

17 It comes from Europe, some German

18 scientists. It was very limited in supply

19 last year and this year, it's much more

20 available, and there's quite a few people that

21 are going to use it in Washington State this

22 next season or right now, in fact. So we're
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1 learning a lot, and about that material this

2 year.

3 The second material that we've

4 been interested in has been a copper material

5 made by the Gowan Company, and it's a new

6 formulation of copper sulfate that Gowan has

7 sort of been staking their formulation --

8 Gowan's very interested in formulation, and

9 they've got this mix of copper sulfate with

10 seaweed and things that they think is safer to

11 the finish of fruit.

12 Just to back up a little bit,

13 copper bactericides are pretty good materials

14 for fire blight control. The problem that

15 they have is that they're a little bit

16 phytotoxic.

17 So that if you spray copper

18 bactericides to control fire blight, you risk

19 damaging the finish or the skin of your fruit,

20 and it's a cosmetic thing.

21 It doesn't affect the nutritive

22 value of the fruit. But if you are trying to
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1 sell fruit in a grocery store or in some place

2 where you're competing with a lot of other

3 products, if your fruit doesn't look just

4 right, just so, then you've got a problem.

5 So part of the reason that

6 antibiotics are useful is that they are so

7 safe for fruit, and they don't do these

8 things.

9 We look at the alternatives, and

10 the alternatives then give us this risk that

11 our fruit won't finish as well, and when it

12 doesn't finish as well, it's not worth near as

13 much, at least downgrading and it becomes hard

14 to make money selling organic fruits.

15 So those are the big issues, and

16 that's also an issue with the Blossom Protect

17 too, although in the drier climates like

18 central Washington, we don't think fruit

19 russet from Blossom Protect will be an issue,

20 and the testing that's gone on with this new

21 copper material that we think is safer, this

22 new formulation of copper that we think is
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1 safer, also shows that in the drier climates

2 on apple, it appears to be a fairly safe

3 material.

4 The copper material does not have

5 an EPA registration yet, and it's just being

6 submitted this year. So the first year that

7 it could potentially be available would be the

8 year 2014. I guess I've still kind of got my

9 fingers crossed about that. I've seen things

10 take longer than that to go through

11 registration processes.

12 I think that the 2015 season would

13 be the first season that this copper material

14 would be widely available. The company has

15 said that their ingredients for the

16 formulation have been accepted as organic. 

17 You know, they've run it through the

18 preliminary screening that it needed to have

19 to get that.

20 So they are reasonably confident

21 that they can get an organic OMRI

22 certification for their material, but they
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1 still are, you know, a year to two years from

2 widespread use of the material in organic

3 orchards.

4 So I think that's sort of my

5 summary. I guess the other thing about it is

6 that biocontrol agents like yeast are useful

7 during the flowering period, and they're

8 pretty much restricted to being useful during

9 the flowering period.

10 If we look at our fire blight

11 problems that we have in industry, that yes,

12 we have problems in the flowering period, but

13 we also have problems in the post-flowering

14 period. We have problems when fire blight

15 breaks out in the summer, due to a hailstorm

16 or some event like that.

17 And so the yeast is not going to

18 have any value to the type of fire blight that

19 you get, say after the primary bloom period. 

20 This copper material does have value for that,

21 and it is another reason that we're interested

22 in it. We would look at it as the best and
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1 the direct substitute for oxytetracycline, and

2 I'll stop right there.

3 MEMBER FELDMAN: Thank you, and we

4 will have a chance to ask questions again

5 after this. Our second speaker is Dr.

6 Virginia Stockwell, who is a research

7 Assistant Professor in the Department of

8 Botany and Plant Pathology also at Oregon

9 State University.

10 She has a Ph.D. from the

11 Department of Botany and Plant Pathology at

12 Colorado State University, an M.S. as well,

13 and a B.A. in the Department of Biological

14 Sciences from Rutgers.

15 Her major research interests

16 include biological control of plant diseases,

17 antibiotic resistance mitigation, microbial

18 ecology, epidemiology, bacterial pathogen

19 diversity, and her research focuses on sources

20 and variation in biological control efficacy

21 at the population molecular level. Thank you

22 so much for joining us.
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1 DR. STOCKWELL: Thank you, Jay,

2 and thank you for the opportunity to talk with

3 y'all today. It's a rare opportunity, and I

4 appreciate it.

5 As Jay indicated in my

6 introduction, I have been interested in

7 antibiotic resistance and the use of

8 antibiotics in orchard environments, and

9 trying to do some risk assessment as far as

10 what are the dangers or potential risks,

11 putative risks associated with the use of

12 antibiotics in orchards.

13 I want to say that one thing we

14 have looked at streptomycin more so than

15 tetracyclines, because streptomycin's used in

16 more countries around the world than

17 tetracyclines. But some of that work is

18 applicable to our work on tetracyclines.

19 For example, there was concern

20 that maybe plant grade antibiotics would be

21 contaminated with their fermentation products. 

22 So they grow the bacterium that produces them,
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1 and then they, in the case of plant-created

2 antibiotics, they do purify the antibiotic

3 from the culture fluid, and then they add that

4 to a clay material like kaolin, to make the

5 final product.

6 In animal agriculture, there are

7 some cases where they're just spinning down

8 the entire broth culture, resulting in both

9 the producing strain being present in the

10 antibiotic formulation, and also the

11 resistance genes, which could be a problem

12 when they're using it for growth promotion.

13 In plant-created antibiotics, we

14 did look at, look for DNA in those products,

15 and we did not find any from products

16 collected from around the world. So at least

17 we know we don't have bad products. We don't

18 have contaminated products. The products are

19 human grade and fairly clean. So that's one

20 thing.

21 I was given three questions to

22 address, and I'll do those briefly. I'll take
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1 the second one first. Please explain the

2 breakdown in tetracycline in an orchard, after

3 it's used for fire blight management, and how

4 likely is it to persist in soil or contribute

5 to resistance in soil microbes over time.

6 So with the tetracyclines, the

7 form that's used in plant agriculture is

8 actually the oxy form, oxytetracycline. It's

9 still a natural product, but it's -- the oxy

10 form is more heat-tolerant.

11 If you buy tetracycline from a

12 chemical company like Sigma Chemicals, and

13 store it in the lab, it will degrade just due

14 to air temperature. So you have to freeze it. 

15 The oxy form is room temperature-stable. So

16 that's one reason it's used in plant

17 agriculture.

18 There is some instabilities,

19 though, with oxytetracycline. For example,

20 these tetracyclines absorb light strongly, and

21 they're degraded by exposure to light or

22 sunlight. They're also labeling basic
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1 conditions. 

2 So there was some work done by

3 Christiano and all on oxytetracycline

4 persistence in the orchard canopy after sprays

5 on peach, because it's also used for

6 bacterial-spotted peach, and they found that

7 first of all, sunlight and UV radiation does

8 degrade the compound very rapidly.

9 They also found that some rainfall 

10 would wash the compound quickly off of the

11 leaf surfaces, and they also demonstrated that

12 there was no absorption into the leaves by the

13 oxytetracycline applied on the surfaces.

14 So they found that if you had a

15 rainstorm within say a day of application of

16 the tetracycline, it pretty much would be

17 washed off and not present on the plant

18 surface anymore for inhibition.

19 Which is why we recommend that you

20 time your sprays, so you don't hit bad

21 weather. I have applied tetracyclines onto

22 flowers in a screen house so it's protected
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1 from rain, and found that the activity, the

2 bioactivity of the compound lasts for about

3 four days.

4 So that's the duration of the

5 inhibition of bacterial on plant surfaces. 

6 It's about four days. You could be generous

7 and say less than a week. So it's not

8 persistent as far as its selective

9 capabilities.

10 Also antibiotics are not

11 mutagenic. They're just selecting for

12 resistant strains amongst the population. So

13 I just wanted to make that point.

14 As far as what happens when it

15 falls on soils, it's rapidly absorbed by soils

16 and loses its activity. Actually, if you just

17 add iron to tetracycline, it loses activity. 

18 It's a kelator, so it kelates iron and loses

19 its antibiotic activity.

20 So they found that even just most

21 of the work on soils and tetracycline

22 stability's actually been done with animal
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1 manures, because they estimate between 40 to

2 90 percent of the tetracyclines administered

3 to animals is excreted into manures. So that

4 was the interest there.

5 They found that even with

6 overloading soils with heavily contaminated

7 manure, the tetracyclines were absorbed, and

8 only in rare cases did they even see an effect

9 on the -- only in cases where it was really

10 heavily loaded with antibiotic resistance

11 genes and also tetracyclines did they see a

12 change in the soil community.

13 So generally with the spray, 200

14 parts per million per acre, you'd get many two

15 micrograms landing per square centimeter of

16 soil. That would probably be bound very

17 quickly and activated by both -- if it's on

18 the surface by sunlight, and also by natural

19 hydrolysis, and also by the binding to soil

20 particles.

21 The other two questions I have is

22 what's my analysis of horizontal gene transfer
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1 in bacteria from orchards to human pathogenic

2 organisms, and has this actually occurred. We

3 have no evidence that it has actually -- that

4 is has occurred to human pathogens, first of

5 all.

6 Now I've done a lot of work on --

7 we've looked in orchard fruit and flowers and

8 leaves. Work's been done by Temple in

9 Johnson's group, Larry Pusey up in Washington.

10 I've worked on pear flowers and

11 Patty McManus did work in Wisconsin, using

12 culturable and non-culturable techniques, and

13 we have not found any human pathogens on these

14 plant surfaces. So at the time when we're

15 applying antibiotics, human pathogens aren't

16 there. 

17 Now I had done a lot of work on

18 acquisition of plasmids by the fire blight

19 pathogen, erwinia amylovora, and we have found

20 some years that up to 60 percent of the

21 isolates during epidemics have acquired

22 plasmids, which is amazing.
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1 So we know that plasmid exchange

2 can happen on flower surfaces. The

3 interesting thing is we are sequencing those

4 plasmids and we're assembling them now, and we

5 have not detected any antibiotic resistance

6 genes on these plasmids.

7 So although we have plasmid

8 exchange with the fire blight pathogen, which

9 is a distant cousin from e coli, erwinia

10 amylovora is an enterobacteriaceae, which is

11 similar to e. coli. We have not seen any

12 acquisition of antibiotic resistance, just

13 acquisition of plasmids. 

14 So yes, if human pathogens were

15 present on flowers, yes, they could probably

16 acquire plasmids. But that's the problem. We

17 lack the recipient. We don't have the human

18 pathogens on flowers. So there's no evidence

19 that we have horizontal gene transfer directly

20 from bacteria to human pathogens in orchards.

21 Finally, what's the possible risk

22 to human health or the environment with the
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1 current use, cycles, and rates of tetracycline

2 used in the Pacific Northwest? 

3 There's a couple of things I want

4 to say. First of all, when we think about

5 antibiotics as selection agents, most of the

6 cases that are brought from the literature

7 deal with subtherapeutic uses and chronic

8 exposure to antibiotics.

9 Here, we're dealing with an acute

10 exposure. The spray is present for a couple

11 of days, and then it loses its selective

12 capability. The amount found on residues on

13 fruit, when present, are extremely low. So

14 they'll be sublethal doses, and we could talk

15 about that later.

16 Honestly, we've looked at fruit

17 from sprayed orchards and non-sprayed. Patty

18 McManus at Wisconsin just finished up a huge

19 metagenomic study, where they looked at

20 orchards that have been sprayed for ten years

21 with streptomycin, which is more selective

22 than tetracyclines, and orchards that have
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1 never been sprayed with antibiotics.

2 The bacterial communities on the

3 fruit, the leaves and the flowers, or the

4 fruit and the leaves and also the flowers in

5 late bloom, were indistinguishable. They had

6 the same level of naturally-occurring

7 streptomycin resistance, but the population

8 structure was not changed over time.

9 Fiona Walsh in Switzerland has

10 also done similar work, looking at leaves,

11 flowers and soils, and again right after a

12 spray, she does see a shift in antibiotic

13 resistance genes. But within a week, it's

14 indistinguishable between soils that were

15 treated with streptomycin or -- streptomycin

16 primarily, and non-treated.

17 Then we've also done work using

18 culture-based studies, where we also sprayed

19 flowers with streptomycin, tetracycline or a

20 combination of the two, and we do see a change

21 in populations on antibiotic treated trees. 

22 The populations are lower for about a week.
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1 But within 14 days, 45 days and

2 also in fruit, you cannot tell the difference

3 between fruit that were sprayed with

4 antibiotics during bloom, and those that were

5 not.

6 So if a human did obtain an

7 antibiotic resistance gene from eating a

8 fruit, I wouldn't be able to tell you if that

9 fruit was from a sprayed or non-sprayed

10 orchard, because if I just looked at the

11 bacteria present on fruit from sprayed or non12 sprayed orchards, or the number of antibiotic

13 resistance genes on those fruit, there's no

14 difference.

15 So there's not a clear linkage

16 between antibiotic application and what ends

17 up on the fruit at the end, and it's really --

18 there's no direct linkage with human pathogens

19 at this point. So I'll stop there and turn it

20 over to Jay.

21 MEMBER FELDMAN: Thank you, Dr.

22 Stockwell. Our next speaker is Brenda Book. 
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1 She is the program manager for the Washington

2 State Department of Agriculture's Organic Food

3 Program. Brenda holds a B.A. in Sustainable

4 Agriculture from the Evergreen State College

5 and studied botany at the University of Iowa.

6 I guess you've been with the

7 Washington Department of Agriculture's organic

8 program since 2002. Ms. Book oversees all

9 aspects of the agency's organic certification

10 services and staff.

11 She's a native of Central Iowa and

12 grew up on a family farm, third generation,

13 grain and livestock farm that has been

14 involved in the organic industry since 1996 as

15 a farmer, researcher, retail, produce manager,

16 farmers market regulator and regulator. 

17 In addition to managing the WSDA's

18 Organic Program, Brenda currently serves on

19 the Board of Directors for Tilth Producers,

20 and is the past president of the National

21 Association of State Organic Programs. Thank

22 you Brenda for being here.
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1 MS. BOOK: Thank you. I really

2 appreciate having the opportunity to provide

3 technical information on the certification

4 process, and I truly hope I can be some

5 assistance to your work and the organic

6 community. 

7 I would also like to add, as far

8 as my introduction, that I -- so you know

9 where I'm coming from, I'm also a mother and

10 a dedicated organic consumer. My family eats

11 organic apples and pears every day, literally.

12 A little bit about Washington

13 State Department of Agriculture Organic

14 Program. We have a long history of organic

15 inspection and certification services. 2013

16 marks the 25th year of certification for our

17 agency. We are the oldest and largest state18 run certification agency in the country, in

19 terms of acreage and number of clients.

20 The mission of the WSDA Organic

21 Program is to protect consumers and support

22 the development of the organic food industry
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1 by ensuring the integrity of organic food

2 products. All of our 24 staff, the agency and

3 our organic stakeholder advisory group take

4 this mission very seriously.

5 So a little bit about tree fruit

6 in Washington. Washington state produces, is

7 the number one producer of organic apples. We

8 produce about 65 percent, and we're also the

9 number one producer of organic pears, about 61

10 percent.

11 You know, if you're interested in

12 more statistics about Washington State

13 agriculture, the Center for Sustaining

14 Agriculture and Natural Resources utilizes all

15 the WSDA certified organic producer data to

16 produce reports, specifically on organic tree

17 fruit in the state.

18 As we reported in our public

19 comments in Seattle, in 2010, WSDA certified

20 719 producers. Of these producers, 361 are

21 certified for organic apples and/or pears. Of

22 these, 136 farmers included the use of
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1 tetracycline in their organic system plan.

2 I do want to make a clarification,

3 though, that that data was taken from the plan

4 and not from the actual inspection findings of

5 confirmed use. In 2012, a year that was

6 particularly high in fire blight incident, 76

7 of our 333 certified apple and pear producers

8 used oxytetracycline.

9 Of these 76 growers, 34 of them or

10 45 percent also produced apple and pear

11 varieties that are in compliance with the EU

12 export restrictions, which means they produce

13 them without oxytetracycline.

14 I do want to note that that total,

15 as far as number of apple and pear producers,

16 also includes those producers that may just

17 have one apple or pear tree in their backyard. 

18 So we have a wide variety included in those

19 numbers.

20 I should mention too, about 736

21 producers total; we certify over 1,100

22 certified operations, handlers and processors
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1 that are all part of that chain of custody for

2 those certified organic apples and pears.

3 So I want to, in my introduction

4 here, go through the certification process,

5 and explain what we do to evaluate the use of

6 material on an organic farm, and specifically

7 the use of an antibiotic.

8 So Section 205.206 of the National

9 Organic Standards is the crop, pest, weed and

10 disease management practice standard. Within

11 the standard, the requirements are outlined. 

12 The requirements that have to be met prior to

13 the use of any material are outlined.

14 The practice standards require

15 producers to use management practices to

16 prevent crop, pest, weed and disease

17 including, but not limited to, crop rotation

18 for annuals, biodiversity for perennials, soil

19 and crop nutrient management practices, good

20 sanitation to limit the spread of infection,

21 and cultural practices such as pruning for air

22 flow and selection of varieties that are
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1 resistant to prevalent pest, weeds and

2 disease.

3 Resistance to one disease may mean

4 high susceptibility to another. We find that

5 our growers are continually put in the

6 position of making the choice of what disease

7 they can best manage, when they are selecting

8 varieties.

9 205.206 also goes on to state that

10 disease problems can be controlled through

11 management practices which suppress the spread

12 of the disease, and the application of non13 synthetic biological, botanical or mineral

14 inputs.

15 So it's only after all those

16 different preventative practices have been in

17 place, and that first level of preventative

18 practices, if they've been implemented and

19 they're not effective, then 205.206(e) goes on

20 to state that a material listed on the

21 National List, specifically 205.601, may be

22 applied to prevent, suppress or control pests,
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1 weeds or disease, provided the conditions are

2 documented in the organic system plan.

3 So 205.601 materials such as

4 oxytetracycline may be applied and are

5 explicitly allowed as a component of multi6 level preventative plan.

7 The National Organic Standards do

8 require confirmed -- do not require confirmed

9 detection of fire blight in an orchard prior

10 to an oxytetracycline application. Use of

11 models to determine risk and prevention needs

12 are consistent with the regulation. 

13 So that's the standard that we are

14 focused on when we are evaluating materials. 

15 So I want to put that into practice a little

16 bit and go through our application review and

17 inspection process, so you see how we apply

18 that.

19 So in the application process,

20 USDA National Organic Standards Section

21 205.200 require an operation to develop an

22 organic system plan. Requirements of this
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1 plan include description of practices and

2 procedures, a list of all the substances to be

3 used, a description of monitoring practices,

4 and a description of record keeping system.

5 In the WSDA organic system plans

6 specifically, we require a narrative disease

7 prevention description. We also provide

8 checkboxes to indicate practices that are

9 utilized to prevent disease, such as crop

10 rotation, resistant varieties, vector

11 management, plant spacing, companion planting,

12 soil balancing, composting, field sanitation,

13 timing and planning of cultivation.

14 Our system plan is not just a tree

15 fruit operation system plan. So it's the wide

16 variety of those different practices that may

17 be used.

18 We also require a self-assessment

19 of the effectiveness of a producer's plan, and

20 a question about whether disease control

21 materials will be used if preventative

22 practices are ineffective.
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1 Then on an annual basis, the

2 certified operation is submitting an update of

3 their plan to us, and within our update form,

4 we require again a description of the

5 monitoring, an evaluation of the effectiveness

6 of that plan, and we ask for plans to improve

7 disease management for the upcoming year, that

8 continuous improvement that we're all looking

9 for within certification.

10 So then once we get either that

11 initial application or that renewal

12 application, then our staff are doing a review

13 of that. Section 205.402 and 205.406 are the

14 parts of the regulation that pertain to this.

15 After receipt of a new or renewal

16 application and an organic system plan, then

17 our trained certification specialists review

18 the paper work for compliance with the entire

19 regulation. The review includes evaluation of

20 both the practice standards and the National

21 List compliance for those material inputs.

22 All of our producers must
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1 implement an integrated preventative system

2 with regards to pest, weeds and disease. 

3 These preventative systems are dependent on

4 current cultural practices such as trellis

5 systems versus standard planning, site6 specific conditions and risks. 

7 Practice must foster biodiversity

8 of the production sites. We see permanent

9 grass, row cover; we see insectory hedgerow

10 plantings, crop species, diversification, all

11 those ways that a producer may be meeting

12 these requirements.

13 So reviewers are also looking in

14 the system plan for references to models, or

15 confirmation of work with crop consultants. 

16 These are established and well-tested industry

17 norms that are used widely in both organic and

18 conventional tree fruit production.

19 We will return a system plan to a

20 grower if the required preventative practices

21 and monitoring techniques are not outlined or

22 implemented prior to the use of a synthetic
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1 substance.

2 In the situation of

3 oxytetracycline, this is a rare occurrence,

4 given the fact that management practices

5 required by organic standards are simply good

6 farming practices, with monitoring built into

7 the widely-used models. 

8 So I'm going to move onto

9 inspection. So the inspection takes place,

10 and it's 205.403 that we're focused on now,

11 and during the on-site inspection, the

12 inspector's job is to verify compliance or

13 capability to comply.

14 They're also there to verify that

15 the information submitted in the system plan

16 accurately reflects the practices, and that

17 prohibited substances have not been applied. 

18 So our inspections are a combination of

19 interviews, field observations and records

20 reviews. 

21 WSDA, we specifically hire

22 inspectors that are experienced in the
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1 agriculture systems in which they will be

2 inspecting. Experience in tree fruit is a

3 requirement for tree fruit producing

4 territories.

5 We have a robust training program

6 and provide ongoing continuing education

7 opportunities such as webinars, attendance to

8 industry conferences, so that our inspectors

9 are up to date on current preventative

10 strategies and control methods.

11 The report that our inspectors

12 fill out require observations as well as the

13 verification of records to support the use of

14 any input material.

15 We rely on our expert inspectors

16 to observe and verify that preventative

17 disease management strategies have been

18 implemented. And when fire blight is active

19 in those different inspection territories, our

20 inspectors are well-informed of the conditions

21 and situations.

22 For the most part, our inspection
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1 staff is located right in the territory that

2 they work, so they are very familiar with the

3 industry that they are inspecting.

4 The tree fruit industry is very

5 diverse in site selection and acres and

6 varieties grown, climate, elevation, soils and

7 management practices, and that's just in

8 Washington state. The occurrence and risk of

9 fire blight infection varies widely from year

10 to year and is dependent on many of those

11 environmental factors.

12 Regardless of this diversity and

13 variation, the current disease management

14 practices and standards are effectively

15 implemented. I'll stop there for now.

16 MEMBER FELDMAN: Thank you very

17 much. Our next speaker will be Dr. Glenn

18 Morris, who is the director of the newly19 established Emerging Pathogens Institute at

20 the University of Florida, where he is also

21 Professor of Medicine, specializing in

22 infectious diseases.
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1 He received his B.A. degree from

2 Rice University in Houston, and his M.D. and

3 Master's degree in Public Health and Tropical

4 Medicine from Tulane. His residency training

5 was at the University of Texas-Southwestern

6 and Emory University, with service as an

7 epidemic intelligence service officer at the

8 Centers for Disease Control and Prevention in

9 Atlanta.

10 He is board-certified in internal

11 medicine and infectious diseases. From 2000

12 to 2007, he served as chairman of the

13 Department of Epidemiology and Preventive

14 Medicine at the University of Maryland15 Baltimore School of Medicine, and from 2005-

16 2007, was interim dean of the UMB School of

17 Public Health.

18 From '94 to '96, Dr. Morris worked

19 with the Food Safety Inspection Service, USDA,

20 on development of the new hazard analysis and

21 critical control project regulations, created

22 and directed by FSIS Epidemiology and
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1 Emergency Response Program, the forerunner of

2 the FSIS Office of Public Health and Science,

3 and was responsible for the establishment of

4 FoodNet, the national surveillance system for

5 food-borne illnesses.

6 In 2005, he was awarded the James

7 D. Bruce Memorial Award by the American

8 College of Physicians for distinguished

9 contributions in preventive medicine, in

10 recognition of this and subsequent work in

11 food safety.

12 He has served on seven National

13 Academy of Sciences expert committees dealing

14 with food safety, and served for four years as

15 a member of the Institute of Medicine's Food

16 and Nutrition Board. He has published over

17 200 papers in peer-reviewed journals, and has

18 had continuous federal grant funding since

19 '84.

20 He currently serves as the

21 University's PI for the Florida Integrated

22 Food Safety Center of Excellence, one of five
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1 such centers established nationally under the

2 Food Safety Modernization Act. Thank you for

3 joining us, Dr. Morris.

4 DR. MORRIS: Thanks. It's a

5 pleasure being here. After that introduction,

6 I'm not sure I can say anything else. But,

7 again, it's a pleasure to be able to meet with

8 the Board today.

9 What I'd like to do is perhaps

10 bring in a perspective from that of an

11 infectious disease physician, and I will say

12 that I continue to see patients in infectious

13 disease, and that one of the major problems

14 facing medicine today is the rapid emergence

15 of resistant strains.

16 As you may be aware, we have

17 significant problems in terms of development

18 of new antibiotics, and we are seeing rapidly

19 rising levels of resistance across multiple

20 pathogens.

21 Speaking as a clinician, there is

22 a strong motivation to do everything that we
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1 can to try to minimize the risk that further

2 resistance genes, resistant strains may move

3 into human populations, because right at the

4 moment, we've got a problem on our hands which

5 we are having a lot of trouble handling.

6 What I'd like to do just very

7 briefly is to run through some basic concepts

8 which I think are applicable to this

9 particular discussion. And again, to kind of

10 come back to the basics, to get antibiotic

11 resistance, you really need two things.

12 You need the gene. You need a

13 resistence gene. Resistence genes may arise

14 spontaneously within strains due to mutations. 

15 But generally, resistance genes move among

16 bacteria, and they move very easily and very

17 readily on a variety of different transposable

18 elements.

19 Bacteria are highly promiscuous. 

20 They spread their genes all over the place,

21 and as I will talk in a minute, many of our

22 studies have clearly shown that when you have
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1 a situation where there is selective pressure,

2 that movement of genes is something that

3 happens with great ease.

4 And again, the second point here

5 is the presence of evolutionary selective

6 pressure, specifically the presence of

7 antibiotics, which provide an evolutionary

8 survival advantage to strains that can resist

9 killing by antibiotics.

10 And again, in these instances,

11 probably the most critical thing is the

12 presence of antibiotics at sub-therapeutic

13 levels. In other words, just enough to give

14 a little bit of a survival advantage to

15 strains that do carry resistance genes, as

16 opposed to strains that are either killed by

17 it or, you know, strains that have, you know,

18 are not able to really compete as well as

19 those that do carry the resistance markers.

20 If somebody could advance these

21 slides. Sorry about that. 

22 Let me just give you an example,
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1 and again I recognize that here we're talking

2 animals and not plants, orchards as we are

3 here. But nonetheless, just to give you a

4 flavor of what we tend to observe, this is a

5 study we did a couple of years ago in a Hog

6 CAFO, where there were sub-therapeutic levels

7 of tetracycline being used as part of the

8 feed.

9 What we did was go in and

10 essentially culture everything in sight. 

11 Soil, water, you name it, we cultured it, up

12 to a half a mile radius away from the CAFO. 

13 What we found was tetracycline-resistant

14 bacteria from all sites at all time points

15 sampled, including samples collected half a

16 mile away from the CAFO.

17 We found that among E. coli, 77

18 percent were tetracycline-resistant, and among

19 enterococci, 68 percent were tetracycline20 resistant. We then said, okay, where are

21 these genes moving? What strains, species?

22 What we found was the tetracycline
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1 resistance was present in strains from 26

2 bacterial genera and 60 species. Basically,

3 the tetracycline resistance had moved into

4 virtually everything. We were able to

5 identify ten known tetracycline resistance

6 genes, which accounted for approximately 60

7 percent of the resistant strains identified.

8 We found that strains carry up to

9 five different tetracycline resistance genes

10 at one time. I would point out that this

11 means that there were 40 percent of the

12 resistant strains where we did not identify a

13 known resistance gene, where we actually -- we

14 did not go through and attempt to sequence the

15 strains, so we're not sure what the basis was

16 for resistance in those particular strains.

17 I guess the picture I want to

18 paint here is that when you have a setting

19 where there is sub-therapeutic use of

20 tetracycline, what you get is within the

21 entire, you know, sort of within an island

22 around the area where the tetracycline is
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1 being used, you get high levels of

2 tetracycline resistance, because for the

3 bacteria in those areas, even very, very small

4 levels of sub-therapeutic tetracycline, are

5 sufficient to select out for resistant strains

6 and to facilitate the movement of resistance

7 genes.

8 The fact is there are lots of

9 tetracycline resistance genes, and a lot of

10 unknown tetracycline resistance genes. In

11 fact, one of our major concerns is the

12 development of new resistance genes, that then

13 have the potential for moving into populations

14 of bacteria in that environment.

15 So how do you get resistance from

16 the environment into something on four feet,

17 or in particular on two feet? And I think

18 that there have been, at this point, multiple

19 studies that it occurs readily among persons

20 with exposure to animals or animal

21 environments, where sub-therapeutic

22 antibiotics were used in feed.
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1 Stuart Levy's original studies 30

2 years ago were still some of the best around,

3 and basically what he did was show that when

4 they started use of tetracycline in feed in

5 chickens, that basically for the majority of

6 families on farms where tetracycline was used,

7 greater than 80 percent of the fecal coliforms

8 in the intestinal tract were tet-resistant.

9 This was obviously significantly

10 much higher in the farms where no tetracycline

11 was used. There are clearly now have been

12 multiple studies documenting transfer of

13 specific resistance genes from animals and

14 humans.

15 I think the point to emphasize

16 here is that I'm really not concerned about

17 movement of a resistance gene, you know, on

18 the blossom into a human pathogen. What I'm

19 really concerned about is the overall

20 generation and spread of tetracycline

21 resistance genes, and ultimately the entry of

22 these genes into the bacterial communities
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1 that are on animals and humans.

2 Again, I think what we have

3 discovered with the studies that have been

4 done, particularly with the increasing

5 capabilities in terms of genetic studies,

6 you've got more bacterial cells on you than

7 you have cells in your body.

8 Bacteria are all over you, inside

9 you, and what the real concern is the overall

10 level of resistance that one sees in these

11 commensal bacterial populations. What then

12 happens is that when you are given

13 antibiotics, if the genes are present even in

14 numbers that cannot be readily detected, then

15 they will rapidly expand and move into

16 pathogens, which in turn can cause serious

17 disease.

18 So again, my concern is not the

19 pathogen. My concern is the overall impact of

20 the resistance genes on the commensal

21 population. And again, there was a very

22 interesting study, again part of the same, I
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1 believe the same cluster of studies that Dr.

2 Stockwell mentioned, where studies were done

3 where pastures were sprayed with streptomycin

4 at concentrations used in orchards.

5 What they found was that 39

6 percent of the intestinal E. coli were

7 resistant in animals that were, that were on

8 sprayed fields, versus 22 percent on animals

9 on control fields. And resistant E. coli were

10 in many instances multi-drug resistant.

11 So again, what this does is simply

12 reinforce this concept that the concern is the

13 overall level of resistance within commensal

14 organisms, and even at the low levels seen in

15 spraying in orchards, it has been possible to

16 demonstrate in animal populations that one

17 sees a dramatic increase in overall levels of

18 resistance within commensal bacteria.

19 So to kind of pull it all

20 together, anti-microbial resistance is a

21 critical and increasing problem in clinical

22 medicine. And again, speaking as a clinician,
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1 this is going to become, is becoming one of

2 the biggest problems we've got in medicine.

3 Tetracycline remains an important

4 clinical drug. It is listed as "highly

5 important" by the World Health Organization. 

6 There are a variety of pathogens where I use

7 tetracycline on a regular basis.

8 One that comes immediately to mind

9 is that there are a lot of strains of MRSA,

10 where tetracycline is my drug of choice, in

11 terms of treatment, because again these are

12 strains that have built up resistance to just

13 about everything else.

14 The major risk for human infection

15 is the presence of resistance genes strains in

16 the body's normal microbial flora, on the

17 intestine and skin. So again, the concern is

18 not the acquisition of resistance genes by

19 human pathogens in the field; the concern is

20 the amplification of resistance genes and

21 potentially selection of new, previously

22 unrecognized resistance genes, and then the
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1 potential for movement of those strains into

2 human populations.

3 I would point out that we have

4 done mathematical models, looking at, you

5 know, kind of how much does it take. Again,

6 what the models show is that even if it's a

7 very rare event, when one actually gets

8 movement of a gene or a new gene into a human

9 commensal population, once it gets into human

10 commensal populations and, you know, with

11 antibiotic use in humans, one can then get

12 rapid amplification and movement and spread.

13 So again, even very rare events

14 are important in terms of the overall ecology

15 of resistance in commensal bacteria in humans

16 and in animals. 

17 Finally, the transfer of resistant

18 gene strains from the environmental sources to

19 humans and human microbial flora is well20 documented. It definitely happens.

21 I think, again, a lot of these

22 data are in an animal CAFO situation. As
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1 pointed out by Dr. Stockwell, we have a

2 situation here where applications are less in

3 an orchard setting.

4 But I think, again, my concern is

5 that, you know, every time you're using

6 tetracycline you are presenting an opportunity

7 for the development of new resistance genes,

8 and/or the amplification of resistance genes

9 and potential to transfer those into humans,

10 either via animals or directly into humans,

11 workers in the area, you know, potentially on

12 product, and again, it's not like you have to

13 have a lot.

14 What the models say is a very,

15 very rare event is enough to have significant

16 impact in terms of long-term risk within human

17 populations. Thank you.

18 MEMBER FELDMAN: Thank you, Dr.

19 Morris. So our plan now is to open -- and

20 thank you to the whole panel. We really

21 appreciate you coming out for this. It really

22 helps us as we work through these critical and
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1 serious issues. I guess the point -- we're at

2 the point now in the program where we will

3 entertain questions of the Board members to

4 the panelists.

5 So the floor is open to anybody

6 who has questions. Do you want me to manage

7 this? Is that -- okay. Okay. Any questions

8 from the Board members?

9 CHAIRMAN STONE: Harold.

10 MEMBER AUSTIN: First off, I thank

11 all of you for taking the time out of your

12 busy schedules to come in and be a part of our

13 day today. It's an important decision that we

14 all are going to be participating in later on.

15 Dr. Morris, this question's going

16 to be directed to you. Looking at your

17 presentation and some of your slides that you

18 had out there, part of the information that

19 you showed showed, you know, hog farm

20 applications made over a covered crop, also

21 using streptomycin.

22 I mean, really our topic is
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1 antibiotics, but it's really focused on

2 oxytetracycline.

3 Do you have any working knowledge,

4 firsthand information dealing with our

5 environments in the tree fruit area,

6 physically dealing with, specifically dealing

7 with the oxytetracycline and the effects that

8 it would have, similar as what you've just

9 been talking about?

10 DR. MORRIS: As Dr. Stockwell

11 pointed out, there are some studies that are

12 beginning to come out. We have not worked

13 directly in the orchard environment. I would

14 say that the concern is that, given what we

15 know about the animal environment, there are

16 concerns that the basic concepts are also

17 going to be applicable to an orchard

18 environment.

19 You know, the obvious answer

20 always is, well, we need more studies. The

21 problem is these studies are very difficult. 

22 As I pointed out, particularly in the CAFO
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1 study, they really have to be done at a

2 genetic level. They take time. One really

3 needs to be sampling both human populations

4 and the basically everything in the orchard

5 environment. And they are very expensive.

6 So consequently, you know, the

7 question is are there sufficient data

8 extrapolating from other settings to be able

9 to move forward? What I would say is I think

10 that there are sufficient data extrapolating

11 from other settings.

12 But I will also say it is

13 extrapolating from other settings. And again,

14 as Dr. Stockwell has pointed out, we are

15 beginning to see some data coming out. There

16 is, you know, there is a need for additional

17 data. The question is do we go ahead and move

18 forward at this point and stop the usage,

19 given the data that we do have?

20 I think if you say we wait for

21 more studies, we are potentially talking years

22 and a lot of money. And again, while I'm not
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1 speaking officially for IDS, for the

2 Infectious Disease Society of America, I

3 believe there is a letter from IDSA in your

4 docket, and again the feeling very strongly

5 from the Infectious Disease Society for

6 America is, you know, it's time to do it now.

7 MEMBER RICHARDSON: Dr. Johnson,

8 you talked a little bit about the Blossom

9 Protect and the copper-based material that --

10 one of which is presently available, the first

11 one, Blossom, and we're waiting on the second

12 one. 

13 Are these two materials the same

14 as or similar to the materials that are being

15 used in Europe for fire blight control? And

16 second part of the same question, have these

17 two materials, as part of an integrated

18 approach, been found to be effective in fire

19 blight control?

20 DR. JOHNSON: Yeah, I think the

21 answer to that is yes. I can't say I'm an

22 expert on fire blight control in Europe. I
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1 have had some conversations with some Swiss

2 researchers about sort of the boots on the

3 ground control of fire blight in apples.

4 My feeling is that some of the

5 areas that apples are grown in Switzerland

6 aren't at especially high risk for fire

7 blight, but they do have it, and they've

8 learned to fight it.

9 They have some products that we

10 don't have, and I think I was asked this on

11 the webinar. But they do have Blossom

12 Protect, and they're using it. Coppers, I

13 believe, are not allowed in the EU. I guess

14 I'm just sort of saying that. I'm not

15 positive about that, but my feeling is that

16 I'm not sure that -- maybe Virginia has some

17 closer colleagues who could answer that. But

18 I'm not sure why they use coppers, are in the

19 EU. 

20 They have another product that's

21 actually a ground up stone material, kind of

22 like a mineral material, and they'll put that
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1 on flowers pretty heavily. I think it's

2 fairly expensive and I think it works sort of

3 in, I think, some of the smaller scale organic

4 situations in Europe.

5 I don't think that in our larger

6 scale farms that we really wanted to go that

7 direction. We do have a -- there is some

8 stone materials used. Kaolin clay is used in

9 apple production in Washington, and it's used

10 primarily as a preseason treatment for insect

11 control, and it works fairly well.

12 I don't know if you were ever in,

13 say, Wenatchee in the first two weeks of

14 March. You'll see all the trees look kind of

15 ghost-white. It's kind of an interesting and

16 pretty experience, and they put clay on. 

17 And we've done some work with that

18 for fire blight control. It sort of works,

19 sort of doesn't, and it's sort of a lot of

20 material. You have to put on say 100 pounds

21 per acre to get it to work. So that's kind of

22 the extent of my knowledge of fire blight
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1 control in Europe.

2 When I was up there was a meeting, 

3 International Organic Tree Fruit group in

4 Leavenworth, Washington last June, and that's

5 where I really talked some of this with some

6 Swiss tree fruit people. That's kind of how

7 they presented it to me, and they were pretty

8 interested in what we were doing with Blossom

9 Protect.

10 They did frown a little bit. They

11 said our ability to use copper probably isn't

12 as easy as it is for you. So our ability in

13 the U.S. to use copper is probably a little

14 bit easier than it is to use in the EU.

15 MEMBER FELDMAN: Other questions? 

16 John.

17 MEMBER FOSTER: So I think, Dr.

18 Johnson, this will be for you. I'm

19 interested, could you talk more about kind of

20 the timing of the EPA registration process --

21 and that's one thing. But I guess more

22 concern to me is the time it takes from there
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1 to get it into kind of actual use in the

2 field, and what you anticipate relative to

3 these alternatives, which look really

4 promising and I think they will be. But it's

5 the timing issue that I'm more concerned

6 about.

7 DR. JOHNSON: Yeah. Well, I've

8 been around this long enough to say that the

9 EPA is pretty unpredictable about these kinds

10 of things. Some things take a long time and

11 some things don't. 

12 I would have to say that something

13 like copper sulfate mixed with, you know,

14 seaweed extract, or whatever the exact

15 formulation is, probably will have a fairly

16 fast track because there are many copper

17 sulfates that are already registered through

18 the EPA.

19 It's not really, I don't think,

20 new chemistry or new molecules, and I think

21 that the toxicology and that kind of thing is

22 going to be pretty well known when the
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1 application is made. So my guess would be

2 that it would go through fairly quickly.

3 And the company has told me that

4 it would be this summer but, you know, I don't

5 -- I mean, I don't have a more definitive

6 answer than that, and I guess we're just sort

7 of waiting on that.

8 MEMBER FOSTER: So part is that

9 process, but then also how is that -- it's one

10 thing to have it registered; it's another to

11 get it into use.

12 DR. JOHNSON: Right, yeah.

13 MEMBER FOSTER: And in a diverse

14 growing community --

15 DR. JOHNSON: Yeah. Well, with

16 the Blossom Protect material, we've sort of

17 had the experience with that, though I do

18 think with biological materials, where you

19 have to have a living product in the bag when

20 you sell it to the grower, and they have to

21 spray a living organism, that it's harder to

22 scale up and be ready.
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1 I mean, you're anticipating this

2 day when you're going to get this

3 registration. But you can't have so much

4 inventory on hand, because the shelf life is

5 fairly short with a biological product.

6 I think the scale-up could be a

7 little faster with a chemical material like a

8 copper sulfate material. I still think you're

9 looking at the first year that they get it,

10 it's going to be new, and they may have

11 limited inventory, and also they're not going

12 to have that much demand, because the

13 information goes out to the people that have

14 their ear closest to all of this. But there's

15 a lot of people that don't have their ear

16 quite so close.

17 And then -- so I think it really

18 is the second year after the registration,

19 where you see the material start to take off.

20 MEMBER RICHARDSON: Just to follow

21 up, on the webinar I got the distinct

22 impression listening to you that we can
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1 control the fire blight without the use of

2 antibiotics. 

3 DR. JOHNSON: Well, I think with

4 the materials that we talked about, I think we

5 can get there. Remember, one of my finishing

6 slides was about risks. I do think we change

7 the risks somewhat. I do think that there is

8 some risk that fruit won't finish as well.

9 I think that's a risk. I do think

10 that there's a risk that some people in some

11 places are going to have a tougher time

12 controlling fire blight than others. So

13 that's a risk, so that I think that who is

14 growing organic fruit, say, ten years from

15 now, if oxytet isn't available, will cause

16 some kind of a shift in the people who do it.

17 So but do I think it can be done? 

18 Yeah, I think it can be done. But I would

19 really like to see those materials that we

20 talked about be available.

21 MEMBER SONNABEND: My question is

22 for Dr. Stockwell. There's been a bit of
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1 controversy within organic community over

2 whether there is residue of tetracycline

3 actually on the fruit from its use in

4 orchards, and when we surveyed the literature

5 in writing our paper, we just found EPA data

6 from I think 2005 that was used as part of the

7 tolerance-setting process.

8 It was unclear to us whether the

9 residues actually had occurred in harvested

10 fruit, and I'm wondering if you could just

11 talk about what you know about residue

12 occurring on fruit, from tetracycline not

13 streptomycin necessarily.

14 DR. STOCKWELL: Right. I also

15 read that EPA report on the registration. 

16 That's the information that I have. I don't

17 know of any situations where they had a .35

18 parts per million detection on fruit. 

19 But if you think about -- I think

20 the highest amount of residue that they found

21 on one apple or something in that study was

22 .25 parts per million, which if you
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1 extrapolate that to like an apple, that would

2 be 35 micrograms, which is -- and if you take

3 an oral dose of like tetracycline, you take

4 250 milligrams, which is -- I can't remember,

5 it's like 5,000 times more, that you're taking

6 a pill, versus what might be on a fruit. So

7 it's very small. But yeah, possibly.

8 DR. MORRIS: I also read the EPA

9 report, and I have your similar hesitation

10 about exactly what they're saying. But, you

11 know, and Dr. Stockwell's completely correct,

12 that in terms of the therapeutic dosage, it is

13 a minuscule amount.

14 But the other side of it is, you

15 know, my concern is really more at an ecologic

16 level, which is that even very, very low doses

17 of an antibiotic are able to cause gradual

18 shifts in population levels of resistance

19 across time, because it means that strains

20 that have some degree of tetracycline

21 resistance have a minuscule, you know, better

22 chance of growing in the presence of very low
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1 levels of tetracycline.

2 But that's enough to potentially

3 cause long-term shifts in the overall

4 intestinal ecology. So I will say that even

5 though the levels are extremely low, I think

6 one cannot say, in terms of the intestinal

7 ecology, which is really where I'm coming

8 from, that they have absolutely no effect.

9 MEMBER SONNABEND: Yeah. My

10 question was -- and I do understand what both

11 of you said. But my question was more where

12 did that .25 that they found come from, and is

13 that going to be likely on every apple that

14 was sprayed at bloom time, or could that have

15 been from a spray after bloom, or do we even

16 know those type of things? Has that type of

17 research been conducted?

18 DR. STOCKWELL: It was not clear

19 in that study exactly when that particular

20 fruit, I think, which orchard it came from. 

21 I can't remember. But I remember that there

22 was like no clear correlation between number
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1 of sprays and the residues, and most of the

2 apples were at below detection levels, which

3 was .013, I think, parts per million.

4 So, yeah, I would like to see

5 actually some really good work done on that. 

6 But as far as, you know, the EPA sets their

7 tolerances based on information from the FDA

8 and also clinical studies. And they felt that

9 a tolerance of .35 would cause no harm to the

10 environment or to humans, and that's if every

11 apple was contaminated at that level, which

12 hasn't happened. 

13 MEMBER FAVRE: My question is for

14 Dr. Morris. I'm having trouble reconciling,

15 understanding the process. If we're being

16 told by Dr. Stockwell and Dr. Johnson that

17 oxytet basically degrades within four days of

18 exposure to sunlight in the environment, how

19 is that going to migrate into potential

20 bacterial populations?

21 DR. MORRIS: Again, even within

22 the window of time that it's sprayed, one can
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1 have fairly substantial impacts on bacterial

2 populations that are in the immediate

3 environment.

4 The question is how long those

5 effects last, and again as Dr. Stockwell has

6 pointed out, there are starting to be studies

7 that suggest that, you know, populations

8 return back into normal levels within a period

9 of time. A month?

10 MEMBER FAVRE: Like two weeks.

11 DR. MORRIS: Two weeks. So there

12 is, with the use of the tetracycline, there is

13 a clear perturbation of the environmental

14 bacterial populations. And again, as I said,

15 what our data suggests and I think what most

16 people would agree is that, one, it's fairly

17 widespread.

18 But then it sort of trails off. 

19 I guess my concern is that what our

20 mathematical models suggest is that, you know,

21 even if one is seeing only temporary

22 perturbations, there still -- what it does is
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1 increase the opportunity for resistant

2 organisms to get into the environment,

3 potentially to come in contact with humans or

4 through various environmental routes.

5 Again, what I'm in many ways most

6 concerned about is the genetic material, which

7 is the actually the tetracycline resistance

8 genes, and the possibility actually of

9 developing or selecting for new genes, which

10 might not have been previously present.

11 So most of the time, it will have

12 no effect. But again what the models say is

13 that even in a very, very rare instance they

14 do have an effect, it can long-term have a

15 significant impact on human populations,

16 because once they enter into human

17 populations, then they are much more readily

18 transmitted among humans.

19 Then once you get somebody with

20 one of those genes and their intestinal tract

21 into a hospital, potentially undergoing cancer

22 chemotherapy, then suddenly what will happen
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1 is that those genes will move into serious

2 pathogens, and one really then starts to get

3 into problems.

4 MEMBER FAVRE: Okay. I guess sort

5 of a follow-up question to that then is, as

6 we're looking at this specifically for organic

7 production by all accounts is, what, less than

8 ten percent of the overall fruit tree

9 production, the impact that we can make on

10 this board by either allowing this material to

11 sunset in 2014 or extending it, whatever we

12 end up deciding here today, is that going to

13 make a significant impact in the overall use

14 of oxytet in fruit production, not

15 specifically organic?

16 DR. MORRIS: I can't speak about

17 the overall fruit production. I can say that

18 the approach that we have started to take

19 increasingly, given the significant problems

20 we're encountering in human medicine, is we

21 need to try to limit or eliminate use in all

22 instances, because all of this -- and again,
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1 even though, you know, what difference does it

2 make? Well, there is a remote possibility

3 that one could get selection of new

4 tetracycline resistance gene tomorrow, when

5 you spray, and that that could then move into

6 human populations with devastating impact.

7 Again, it's a very, very rare

8 event. But what's fascinating is that when

9 you work with the mathematical models, even

10 very, very rare events can clearly have

11 significant downstream populations because of

12 the potential for amplification once they get

13 into the human intestinal flora.

14 And again, that's our concern. 

15 It's not movement into a human pathogen, but

16 movement into the overall ecology of your

17 intestinal flora, where it may not even be

18 detectable until you are in a setting where

19 suddenly antibiotics are administered, and

20 where suddenly you become very susceptible to

21 farther infection.

22 MEMBER THICKE: I think this is a
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1 very interesting discussion about the levels,

2 low levels, sub-therapeutic. I think,

3 however, if you look at it from -- if you use

4 Avogadro's number and calculate 250 parts per

5 billion, it's interesting.

6 One part per billion will end up

7 to be that apple will have about 10 to the

8 15th molecules of antibiotics in it, or about 

9 ten quadrillion molecules of antibiotics will

10 be in that. Now, whether that's significant

11 or not, it's astounding, though, to realize

12 that. That's why I wanted to bring that out.

13 MEMBER MARAVELL: Yes. At the

14 risk of showing my lack of knowledge, I'm

15 going to disclose that I do not produce any

16 tree fruit, but I'm going to ask some

17 questions of the panel. 

18 Dr. Johnson, is there any way, if

19 I were a tree fruit producer, and we were

20 having a quote-unquote perfect storm of

21 circumstances for the development of the fire

22 blight pathogen, is there any way for me to
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1 make a positive ID of the presence of that

2 pathogen in my orchard in time for me to

3 provide sort of a curative or preventative or

4 a static type of treatment?

5 DR. JOHNSON: Well, yeah. That's

6 another research question that we like to work

7 on. We have developed some techniques for

8 scouting orchards for the development of the

9 fire blight pathogen in flowers, before they

10 reach the really major stages of activity

11 where you would get a major perfect storm or

12 epidemic.

13 We've developed the molecular

14 technologies to do that. The problem right

15 now is waiting for the detection technology

16 that can implement that molecular technology

17 to catch up, and the simple analogy would be

18 to say can we make this as easy as a home

19 pregnancy test or something like that, and the

20 answer is not yet.

21 But at some point down the road, I

22 think that that's going to be possible. But
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1 I think we're talking more like a decade or

2 something like that.

3 There's some instrumentation

4 that's coming down the road that is allowing

5 for portable molecular tests to be done, and

6 it's called Point of Care use of molecular

7 testing.

8 I think that at some point in the

9 future, that will be done routinely in

10 orchards for the fire blight pathogen, and

11 we've kind of been at the forefront of that in

12 developing technology to do that.

13 And we do it now in our research

14 objectives, and for example, that work with

15 pre-bloom sanitation with copper in

16 California, we are employing a molecular

17 detection technology to tell when the fire

18 blight pathogen is in flowers.

19 But right now, the flowers all

20 come to my lab and my technician works night

21 and day to get the samples processed, and

22 we're only working in, you know, a half a
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1 dozen orchards and things like that.

2 So we don't feel like having some

3 facility where everybody mails their flowers

4 in would be sufficient, because it would

5 overwhelm, and it's very much a needle and a 

6 haystack problem to find it.

7 So the only way we feel that

8 people could do that would be actually to do

9 it themselves, or have a service, a local

10 service do it, and they would need these

11 onsite instruments that could do that.

12 So I think your question's a good

13 one and I do think it's coming, but I think

14 we're looking probably at maybe ten years down

15 the road.

16 MEMBER MARAVELL: If that

17 technology were available, and now we're in

18 the hypothetical, would it be ever useful to

19 determine whether or not the treatments that

20 you had undertaken, having gone through all

21 the processes that Brenda outlined for us,

22 were being successful, and you would not have
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1 to treat? I know it's a difficult question.

2 DR. JOHNSON: Yeah. I've worked

3 with a couple of growers up in Central

4 Washington, where we're doing this for them,

5 and one grower in particular wanted me to say

6 treat or not to treat. Our experience with,

7 it's not so much a technology problem, but

8 it's more of a sampling problem.

9 So if you're looking for needles

10 in haystacks, and fire blights, if the

11 temperatures -- the bacterium itself, if the

12 temperatures are such, it can double two,

13 three, four times a day, and the number can

14 jump, and your flower pickers are out there in

15 the cool of the morning and by mid-afternoon.

16 So it's a little bit nervous to

17 say that yeah, we could just, you know, give

18 you a prescription for an orchard and say

19 "treat," and I guess I don't feel like we're

20 confident enough in the science at that point. 

21 I think the technology would be useful for

22 looking at say sentinel orchards, or knowing
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1 when it's active --

2 You know, we've learned a lot in

3 the last say three, four years, just kind of

4 this understanding of when it's active and

5 what's the pattern of build-up in the flowers. 

6 I think because of that, we've actually

7 changed not just organic but conventional

8 practices in fire blight control somewhat, and

9 gotten people to kind of, you know, hang on a

10 second.

11 It's not going to be exploding on

12 you today or tomorrow. But as we get near the

13 end of bloom, that's when you're really going

14 to have a serious issue.

15 So we've done a lot of that kind

16 of work, and so I think we'd have to do a lot

17 more sampling and get a lot more confidence in

18 our sampling protocols before we would be

19 saying okay, today you could spray, you know,

20 copper, or today you could spray

21 oxytetracycline or even the harder question to

22 us, no, you don't need to spray, you know.
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1 What we've really found by doing

2 these surveys and doing this, running these

3 molecular acids is that the models work. The

4 models are pretty good, and in terms of

5 telling people when they have a risk problem. 

6 In the areas we've been working in

7 in California, this is now in California

8 primarily, you know, the pathogen builds up in

9 those orchards most every year, but it doesn't

10 get to really high numbers until you get to

11 fairly late bloom.

12 So you know, at some point I think

13 that people would say, you know, I don't know

14 if I want to do that test, because I know

15 what's going to happen, and I probably would

16 agree with them. So but it's been very useful

17 to do it as a research problem.

18 MEMBER FELDMAN: John.

19 MEMBER FOSTER: Brenda, I think

20 this might be your deal here. I'm fuzzy on

21 how copper is handled in the EU, relative to

22 certification materials approval. Can you
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1 clarify that for me? How is that done

2 differently, and what lessons can we learn

3 that might be applicable here?

4 MS. BOOK: I don't know how much I

5 can expand on it, because we don't evaluate to

6 the EU specifically. But when we did, the EU

7 standard for copper is an absolute. It's a

8 certain amount per hectare that you can apply,

9 which differs from our standard.

10 What Ken mentioned earlier,

11 talking to the folks that are in the EU, it is

12 more difficult for them to use a copper

13 product over there, because they have an

14 absolute, versus ours is as long as there's

15 no, you know, accumulation in the soil.

16 MEMBER FELDMAN: Dr. Morris, I

17 wanted to ask you a question about the World

18 Health Organization rating of tetracycline in

19 specific, because it sounds like we're talking

20 about this chemical as if it were a normal

21 pesticide that didn't intersect with

22 protection against human diseases.
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1 Could you put that into context

2 for us, in terms of how this specific material

3 is viewed in the world context of protecting

4 human health?

5 DR. MORRIS: Tetracycline is a --

6 it's an important drug. It's an older drug. 

7 We have a great deal of experience with it. 

8 It is a drug that we use here in the United

9 States for fairly selective instances,

10 particularly as I say, I probably use it most

11 commonly in something like MRSA, because for

12 outpatient treatment, sometimes our options

13 are limited, and most of the other drugs that

14 are currently -- are still available tend to

15 be relatively toxic.

16 At a global level, tetracycline is

17 an extremely important drug. There are a

18 variety of diseases where it is either the

19 only agent which is effective, or it's an

20 agent which is by far the preferred agent.

21 A fair amount of my research deals

22 with cholera. For cholera, tetracycline is
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1 clearly the number one drug. It's not

2 something that we're necessarily going to get

3 here in the United States.

4 But nonetheless, what I would say

5 is here, on a global level, tetracycline is

6 an important drug, and consequently, at least

7 within the professional community, within

8 those of us who practice infectious diseases,

9 it's one of those drugs, and again based on

10 the WHO ranking, is a highly important drug.

11 It's one of these drugs that we

12 want to try to do everything in our power to

13 try to minimize further enhancement of

14 resistance.

15 MEMBER AUSTIN: Ken, Dr. Johnson,

16 most of the research is -- that you've been

17 working with is really it's been looking at

18 the Blossom Protect and then looking ahead at

19 that later stage of development with the

20 copper that Gowan's coming with, the Previsto.

21 I was just informed at lunch time

22 by Glenn Foster with Gowan that EPA has pushed
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1 the registration process for that back into

2 August 2014. What impact will that have with

3 our proposal, you know, more of an organic

4 approach to replacing tetracycline in your

5 trials and actually then with the growers

6 themselves?

7 DR. JOHNSON: So that's August

8 2014 now is the -- or 2013.

9 MEMBER AUSTIN: August 2014.

10 DR. JOHNSON: Oh, okay. Well, so

11 now we're talking about, if the sunset is at

12 the end of 2014, then if the product is

13 registered, we would have a very short period

14 of time to have people ready for the 2015

15 season.

16 My own feeling about all of the

17 things that we've worked on is that that

18 copper material is fairly essential to being

19 able to control fire blight, and as I said in

20 my opening remarks, not so much -- well, both

21 during the primary bloom period. 

22 But I said a lot of our problems
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1 in fire blight extend beyond the primary bloom

2 period, and the biological material like

3 Blossom Protect or the other materials that

4 are out there like Serenade and things like

5 that, they have value during the bloom period,

6 but they don't have that much value in this

7 post-bloom period and the period during the

8 summer when, if you get fire blight in your

9 orchard and you're trying to get it back in

10 check, you need a material that you can spray

11 out there, that will kill bacteria.

12 This Previsto product has that

13 potential. It's a good bactericide in the

14 testing that's done and has been primarily

15 done by Tim Smith up in Wenatchee, is that the

16 Previsto has done a better job than this new

17 formulation of copper sulfate. It's doing a

18 better job than the older formulations of

19 coppers.

20 So we think it's a good material

21 and would have the best fit in that period of

22 bloom, when or after bloom when fire blight
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1 gets kind of messy and can do a lot of damage. 

2 So we'd have a real short period of time to

3 get people up to speed, and I think that --

4 I mean here again, we're talking

5 about a chemical and not a biological. I

6 think that the company would have a better

7 chance of being ready itself, and I think that

8 the word would have to go out very quickly in

9 the sheds and all that, that supply growers

10 with material would have to get ready.

11 You know, I think, you know, we've

12 been on the trail on this, out there speaking

13 quite a bit, and I don't think it's going to

14 be a problem of not, of people not really

15 knowing about it. You've just got this kind

16 of logistical issue, getting people up to

17 speed and knowing and being ready.

18 MEMBER FELDMAN: Final questions. 

19 Yes.

20 MEMBER SONNABEND: Dr. Johnson, we

21 heard from some people's testimonies that Dr.

22 Sundin in Michigan did research for several
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1 years, showing that Blossom Protect did not

2 work very well at all in Michigan, and we were

3 wondering, I was wondering if you knew what

4 they're going to do, what they're going to try

5 next or, you know, what options they have.

6 DR. JOHNSON: That was the

7 question I forgot to answer during the first

8 part. So there's a couple of ways to answer

9 that question.

10 Just if you have an apple flower

11 in Michigan or if you had an apple flower in

12 Washington, I don't think there's a reason

13 that Blossom Protect wouldn't work in

14 Michigan, as opposed to Washington.

15 I mean there's not a difference in

16 the flowers per se. I know George pretty

17 well. I know that he worked with it in 2011,

18 and he did publish a report, and he had fairly

19 good results with it in 2011. In 2012, they

20 pretty much got froze out in Michigan, so they

21 didn't get any, really any data last year.

22 Biologicals have never been a real
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1 strong emphasis of George's program, so that

2 their testing with Blossom Protect has been

3 fairly limited.

4 I think the bigger issues for

5 Michigan growers are climatic ones, and the

6 two things that affect fire blight control in

7 Michigan are the speed at which spring

8 happens, and it's faster than it is out west

9 here. They have warmer nights and bloom

10 happens very quickly, and so they have to be

11 ready to go and they have to move fast.

12 That's number one, and the second

13 one is that they have apple scab, and apple

14 scab is probably a bigger problem for them

15 than fire blight. So all through the bloom

16 period, they are putting on materials for

17 apple scab. So they're putting on materials

18 that are suppressing the growth of fungi, and

19 as yeast is a fungus.

20 So they're very concerned that if 

21 they're in the middle of an apple scab program

22 that if they put this yeast on, that they're
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1 going to have difficulty establishing

2 effective populations of the yeast on flowers.

3 I can't say that I've seen any

4 research to say one way or the other what the

5 result of that is, and I do think it is a

6 concern. I got some trials out that I'm going

7 to put out here in a couple of weeks, looking

8 at sulfur before and after Blossom Protect, to

9 see if we can get a little better

10 understanding of that.

11 But again, we're still really just

12 learning about the material. The advantage

13 that we have in the west with Blossom Protect

14 is that it's dry, and we don't worry about

15 scab very much in most of the production

16 areas.

17 MEMBER SONNABEND: In the

18 Northwest, not in California though.

19 DR. JOHNSON: It's true, yes, and

20 in California and in pears in particular, we

21 do worry about scab more, as we saw from the

22 Mount Adams guys telling us about pear scab
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1 the other day.

2 In pears in California, Dan Goff

3 was a grower down near Lake Port. He's an

4 organic grower of pears, and I had an email

5 exchange with him just the other day about

6 this, him and Brock Soller about this, about

7 how to put on sulfur and try to integrate it

8 with Blossom Protect.

9 It's still, we're just kind of

10 feeling our way through it, and we're actually

11 going to get the samples after I'm a little

12 less busy, and look and see what his success

13 was in establishing this yeast on his pear

14 fruit, on his pear flowers.

15 MEMBER FELDMAN: One last

16 question, and it goes to this question of

17 persistence. We, in our technical review, and

18 I guess this is for anyone on the Panel that

19 can touch it, but tetracycline, it says

20 "Tetracycline can persist in soil for long

21 periods of time, without showing antimicrobial

22 activity, and high concentrations can be
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1 achieved. Upon later release from soil

2 components, it can exhibit antimicrobial

3 activity."

4 So it gets bound up in the soil,

5 and it says "factors that may result in

6 release of tetracycline from soil includes

7 changes in organic material composition,

8 shifts in microorganism populations, or

9 changes in soil pH." Is that, does that make

10 sense? Anybody?

11 DR. STOCKWELL: No. You'd expect

12 some degradation through hydrolysis of the

13 compound. I mean it could be bound to soil

14 particles, but through exposure to

15 microorganisms and other things, it should

16 degrade. 

17 MEMBER FELDMAN: Well, I'm just

18 citing. There are a couple of citations here

19 on that point.

20 DR. STOCKWELL: Yeah. That was a

21 -- I think you're talking about the Chandler

22 study or something.
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1 MEMBER FELDMAN: Agar Poposka.

2 DR. STOCKWELL: Oh, Poposki? 

3 Okay.

4 MEMBER FELDMAN: Well, Poposka it

5 says here, et al.

6 DR. STOCKWELL: Yeah. They didn't

7 actually study that. So they're just

8 speculating. So that's a comment on the

9 discussion, but they actually didn't -- I

10 don't think they actually looked at the --

11 they didn't do any chemistry in that study. 

12 So --

13 MEMBER FELDMAN: Okay. Thank you

14 all very much for participating in this. 

15 Appreciate it.

16 CHAIRMAN STONE: Thank y'all very

17 much. We appreciate your coming and attention

18 to help us with the, wrestle with this

19 decision here. So Jay, just a little bit of

20 a time check. The way we have it outlined,

21 we've scheduled 30 minutes for the Board to

22 discuss three proposals, and then the balance
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1 of the afternoon is basically three hours

2 that's scheduled for public testimony, at five

3 minutes each.

4 So just depending on how that

5 goes, if we have some -- if it went like

6 yesterday, we may have a little time for some

7 questions, but not very much. So if you want

8 to go work through this 30 minute Board

9 discussion and go part-way into public

10 comments before we break at 3:15.

11 MEMBER FELDMAN: Okay. So as

12 y'all know, we have a majority/minority

13 position, and Harold is going to present his

14 slides, right? So Harold's going to present

15 the majority opinion with the --

16 MEMBER AUSTIN: Yeah, Jay. I'll

17 present the proposal, a brief history and then

18 I'll start the majority, and then Zea will

19 finish that part of it. We're going to do it

20 together.

21 MEMBER FELDMAN: Do you want to

22 read the petition?
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1 DR. BRINES: I can do the brief

2 introduction, sure. So the tetracycline

3 petition was received on June 11th, 2012. It

4 was a joint submission by three parties, the

5 Washington State Horticultural Association,

6 the California Pear Advisory Board and the

7 U.S. Apple Association.

8 The petition requests an amendment

9 to the annotation for tetracycline at 205.601

10 on the National List. So the current listing

11 is under paragraph (I) as plant disease

12 control. Number 12 reads tetracycline for

13 fire blight control in apples and pears only,

14 until October 21st, 2014.

15 In support of the review, the

16 Crops Subcommittee reviewed the previous

17 technical report that was available for

18 tetracycline. So there was no new report, but

19 the previous report was completed in 2011. 

20 There was also a previous report done in 2006.

21 Both the petition, the previous

22 technical reports and the Subcommittee
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1 proposals were all posted on the NOP website

2 in advance of the opening of the public

3 comment period for this meeting. Thanks.

4 MEMBER FELDMAN: Thank you. 

5 Before we jump into the conversation and

6 presentation, I guess there are maybe some

7 members that want to talk about their

8 potential conflicts of interest, or address

9 disclosure of interests. So who wants to

10 start with that? Go ahead, thank you.

11 MEMBER SONNABEND: Okay. I do, I

12 know there's a lot of debate about conflict of

13 interest, but I do feel it's important for the

14 public to, at least for me to be transparent

15 to the public about my interest that I may or

16 may not have on the subjects before the Crop

17 Subcommittee.

18 So with that in mind, I do want to

19 state that I work for a certifier who may or

20 may not certify products that have any of the

21 materials that we are considering before us

22 today used on them, and I do grow apples. But
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1 I do not use tetracycline in my orchard, nor

2 do I plan to.

3 To accuse me of a conflict of

4 interest when I do not use the material I feel

5 is inappropriate. Thank you.

6 MEMBER FELDMAN: Thank you. 

7 Harold.

8 MEMBER AUSTIN: Yeah. I have two

9 points to make the public aware of, as my

10 declaration, and I do not feel that I do have

11 a conflict of interest, because I'm here to

12 represent stakeholders. That's what we're all

13 here for.

14 First, as part of the petition,

15 prior to being appointed to the Board, there

16 is a letter of support on behalf of my

17 company, written by myself, that is there, and

18 that's posted and that's full public

19 disclosure.

20 Also, my company that I work for,

21 we are organic and conventional apple, pear,

22 cherry, blueberry, wine grape growers, and we
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1 use tetracycline on part of our acreage. We

2 use it not on a lot of our acreage.

3 We brought this up in discussion

4 with the full Subcommittee, Crops

5 Subcommittee. It was decided that we did not

6 have a conflict, I did not have a conflict at

7 that time. But we moved that forward. Jay

8 moved that forward to the program to make a

9 decision, and the decision came back that they

10 saw no conflict, as far as they were

11 concerned.

12 MEMBER FELDMAN: Thank you. We've

13 gotten all those administrative matters --

14 okay, go ahead.

15 CHAIRMAN STONE: Let me just

16 confirm that the Executive Committee also

17 vetted the decision of the Subcommittee, the

18 lack of those conflicts.

19 MR. McEVOY: To just reiterate,

20 from the Program's perspective, the members of

21 the Board are here to represent their

22 stakeholders. There's no disproportionate
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1 benefit that the members receive. So

2 therefore, all the members of the Board do not

3 have an interest that constitutes a conflict

4 that they need to recuse themselves. 

5 So we looked at specifically

6 Harold's and Zea's situation, and they do not

7 need to recuse themselves on this particular

8 topic.

9 MEMBER FELDMAN: Thank you. The

10 floor is yours, Harold.

11 MEMBER AUSTIN: All right. We're

12 a little tight on time, so we'll try to move

13 this along as rapidly as possible. We do have

14 a proposal on oxytetracycline. We did receive

15 a petition to remove it from the, with the

16 October 21st expiration date.

17 The original petition was to

18 actually relist it back into the sunset

19 process.

20 The Crops Subcommittee decided

21 that since it had already been removed, that

22 we would -- we did not like that option or
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1 that we did not like that as an option, and we

2 chose to, based off of the knowledge that we

3 had, that there was research being done,

4 knowing that this Committee, this Board

5 actually in 2011 in Seattle, challenged the

6 industry to go forward, start to make changes,

7 come back to this Board with a petition, if

8 they felt that they needed an extension, which

9 is essentially what had taken place.

10 So we moved forward with a new

11 proposed expiration date of October 21st,

12 2016, and this would be used for both apples

13 and pears for control of fire blight. We've

14 got a resolution, which I'll read in a minute,

15 as we get down further into the motion.

16 The petition to the National

17 Organic Standards Board was received for the

18 removal of the expiration date, and we just

19 described that. Because this is such a --

20 this subject is so complex, we presented a

21 proposal that was essentially 40 pages, I

22 believe. That thing changed and morphed about
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1 16 times with the Subcommittee.

2 But I think we ended up with a

3 document that got posted, that read at about

4 40 pages, trying to lay out for the community

5 and the stakeholders. It's a little bit

6 complex. It's a little bit big. But we tried

7 to take and lay out a history of what has

8 happened with oxytetracycline, and

9 streptomycin was a part of that decision

10 previously.

11 Also, after the history then we

12 went into a strong presentation with both the

13 majority opinion and then also a very indepth

14 description of the minority opinion. We felt

15 that that was the proper way to approach this,

16 because this is such a complex issue. There's

17 a lot of dynamics in play, and we needed to

18 make sure that all of the stakeholders felt

19 that the information being presented to the

20 public represented each and every side of this

21 discussion.

22 So we hope that that was achieved,
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1 and I probably, I don't know. The Program

2 hasn't told us, but it was probably the

3 longest proposal that they've ever received. 

4 If not, it gives us something to shoot for. 

5 I just don't want to be a part of the next

6 one.

7 Okay. All right. Moving down

8 into the actual motion itself, Crops

9 Subcommittee moved the motion forward to amend

10 the listing of tetracycline to remove the

11 expiration date of October 21st, 2014, add the

12 following annotation: That 205.601, synthetic

13 substances allowed for use in organic crop

14 production, as a plant disease control, 12

15 tetracycline for fire blight control in apples

16 and pears only until October 21st, 2016.

17 That moved out of the Subcommittee

18 to where we are today by a motion of five

19 yes's, three no's and no absences and no

20 abstains.

21 We did further accompany that with

22 a resolution, and the resolution reads that
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1 "The National Organic Standards Board is

2 committed to the phase out of this material. 

3 The Board urges growers and certifiers between

4 now and the 2016 proposed expiration date, to

5 encourage an annual increase in the extent

6 and/or number of alternative practices that

7 are trialed for controlling fire blight.

8 "In addition, the Board strongly

9 supports increased support for the research in

10 these alternative practices and materials." 

11 That carried out of Subcommittee to the full

12 Board, 7 yeses, 0 no, 1 absent. 

13 Here we go. Okay. Written public

14 comments that we received back, 320. 

15 Supporting the majority position for an

16 extension of the expiration date, 35, and that

17 included Bluebird Coop, which had 27 growers

18 on their petition.

19 Supporting the minority position

20 against an extension of expiration date, 281. 

21 We had several large petitions that were

22 submitted electronically. OCA, 24,016
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1 signatures; FWW, 6,544 signatures; CFS, their

2 petition had 24,545 signatures.

3 Supporting the centralist proposal

4 that was proposed by NOC, Co-Op Partners

5 Warehouse, Organic Produce Wholesalers

6 Coalition, Organically Grown Company,

7 Veritable Vegetable, Northwest Organic Dairy

8 Producers Alliance.

9 Organizations for and/or agencies

10 supporting the majority opinion for some sort

11 of an extension include MOSA, OFTA. Just for

12 the sake of saving a little bit of time, I'm

13 not going to read through all of the groups,

14 but I will read a little bit of the comments.

15 "OTA is committed to the use of

16 antibiotics in organic apple and pear

17 production. 2017 expiration date will support

18 current research and testing, allow for grower

19 education and success. Expiration dates need

20 to be based on research-based time lines, not

21 political compromise.

22 "OTA supports the Subcommittee
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1 resolution. OTA also recognizes the role

2 organic agriculture can play in developing an

3 approach that will ultimately be adopted in

4 conventional orchards as well."

5 Organizations, agencies supporting

6 the majority opinion or type of extension. 

7 "MOSA believes that the proposal to extend the

8 expiration date to 2016 doesn't go far enough,

9 in allowing time for development of equivalent

10 alternatives for fire blight control."

11 Recommends that "the NOSB consider grower

12 input." 

13 NWHC. Acid oxytetracycline be

14 retained on the National List or relisted

15 until viable and proven alternatives are

16 identified. Arbitrarily established

17 expiration dates do not provide a solution to

18 the organic industry and its various

19 stakeholder groups.

20 Oregon Tilth urges the NOSB to

21 consider a sunset date that is based on

22 realistic expectations for current research to
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1 draw statistically significant conclusions. 

2 They do not support the inclusion of

3 annotations that reiterate existing standards.

4 UNFI, representing 7,000

5 associates, 27,000 customers and I will say

6 that this is a statement that they gave us. 

7 This is not a signed petition that they

8 submitted, supports a 2017 expiration date,

9 based on research-based time lines, not

10 political compromise.

11 Albert's Organics 2012 sales for

12 Northwest organic apples alone were almost $16

13 million. This is a critical organic sales

14 category for them. 

15 CF Fresh. This is not a debate

16 about substances used to grow prettier or

17 larger fruit, to increase storage life, or for

18 the convenience of organic growers. This is

19 about actual life of the trees, and by

20 extension, the livelihood of growers and

21 workers, their families and the communities.

22 OTFA. Long term solutions
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1 discussions should include currently no viable

2 alternative to antibiotics for post-blossom

3 infection fire blight control. Blossom

4 Protect does not work in Michigan's climate. 

5 Blight resistance, root stocks and tolerant

6 cultivars are not a solution to this problem

7 at all.

8 Objections to the use of

9 antibiotics for fire blight control tend to be

10 philosophical, rather than scientifically

11 based.

12 Organizations, agencies supporting

13 the majority continued. California Natural

14 Products, a very promising research program,

15 OREI, will not be ready for use by the organic

16 farmers and conventional farmers until 2017,

17 giving these pioneering farmers and

18 researchers the time they need to bring this

19 to a successful organic conclusion.

20 General comments. "We apple

21 growers cannot grow organic apples on a

22 commercial scale without antibiotics at this
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1 time. After testifying at the Seattle

2 meeting, Spring 2011, I walked away losing

3 faith in the democratic process being a good,

4 fair and compromising system, which makes

5 regulatory decisions based on good science and

6 common sense instead of politics.

7 "I returned to my farm. I started

8 preparing to transition my food production and

9 processing back into conventional food stream. 

10 We are now a split operation."

11 "Fire blight is one of the

12 principal limiting factors of pear production

13 in California. I'm a producer of organic

14 pears in the Lake County district in the North

15 coastal mountain areas of California. 

16 Supporting the centralist

17 position, NOC had proposed a three point

18 centrist proposal. Co-Op Partners, Warehouse, 

19 I've already mentioned those a little bit. 

20 Specific use annotations to document grower's

21 movement upward in the disease management and

22 add a resolution detailing how oversight from
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1 certifiers in the NOP would be carried out.

2 Alternative proposal. 

3 Cornucopia's position. While opposed to the

4 majority opinion and in full support of the

5 minority opinion, Cornucopia is willing to

6 consider another proposal.

7 They recognize that due to the

8 high susceptibility of fire blight that pears

9 have, that the fact that there has been

10 relatively little research done on

11 alternatives to antibiotics on pears, that the

12 regulations may need to be different for pears

13 compared to apples.

14 They would support removal of

15 antibiotics from apples production 2014

16 expiration date, without impacting pear

17 growers, while more continued research could

18 be conducted. There wasn't a time frame

19 submitted to that. I don't know if you guys

20 will make further comment on that or not. 

21 Okay. Support of the minority opinion. 

22 Opposed to an extension of the expiration
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1 date.

2 Consumers Union. The goal of OFPA

3 was to apply consistency to the organic label. 

4 Food and Water Watch. The prophylactic use of

5 antibiotics contributes to the growing

6 reservoir of antibiotic resistant bacteria in

7 the environment, which has been identified by

8 medical authorities as critical threat to

9 public health.

10 Advocacy groups supporting

11 Minority Opinion 20, Consumers Union, BP, CFS,

12 PIER, several more, Cornucopia and several

13 more. Support of the minority opinion,

14 continued. Beyond Pesticides stresses the

15 importance of antibiotic resistance. They

16 state that the majority opinion is contrary to

17 prevailing medical and scientific opinion.

18 Tetracycline use poses significant

19 health and environmental threats. It is

20 incompatible with a system of organic and

21 sustainable agriculture. There are numerous

22 individual comments submitted in support of
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1 Beyond Pesticides, and we have several

2 supporting that position.

3 Johns Hopkins University. To

4 protect public health, the NOSB should allow

5 the authorized use of oxytetracycline to

6 expire next year as scheduled. General

7 comment. Please keep antibiotics out of

8 apples and pears, and any other organic fruits

9 and vegetables.

10 Antibiotics should not be in or

11 used on any food, especially that which is

12 marked as organic. No synthetics should be

13 allowed of any kind.

14 Continued support of the minority. 

15 There were many individual comments stating

16 that antibiotics do not belong in organic

17 production. Keep all synthetics out. Please

18 keep our food safe, and numerous generic and

19 form letter types of these comments were

20 presented to us.

21 Key points of discussion. Zea,

22 when I get to your slides, yell at me so I
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1 don't -- I may just keep going.

2 OREI. Research will not be

3 completed by the current 2014 expiration date. 

4 What impact will the 2014 expiration date have

5 versus allowing for specific extension, in

6 allowing completion of the trial work and

7 transition of these programs physically out to

8 the grower spray programs for actual use?

9 So taking them out of the trial

10 status and moving them out physically into the

11 real world, out into actually growers putting

12 these materials on. There are several

13 suggestions to extend the date that we have

14 received, ranging anywhere from 2017 all the

15 way out to 2023.

16 Does the current system provide

17 adequate oversight? Annual inspections,

18 organic systems plans in place. Certifiers

19 ensuring that all the necessary steps leading

20 up to the use of the tetracycline have been

21 met prior to an application being made.

22 If an extension is agreed upon, is
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1 any further restrictions truly needed, and

2 would they even be able to be implemented in

3 a timely enough manner to be of any help? 

4 What are the actual facts of antibiotic use in

5 tree fruit on human health and the

6 environmental impacts, and I think our panel

7 was able to take and give us a little

8 disclosure on some of that.

9 Do they exist, don't they? At

10 what levels? What could be done to help

11 mitigate these concerns, if an extension is

12 granted to help with consumer confidence in

13 organic?

14 All sectors of the organic

15 community agree that antibiotics need to be

16 moved from organic use, and are committed to

17 doing so? It's just a matter of when the

18 phaseout should be.

19 Can a compromise be made that

20 allows all organic stakeholders to share in

21 the decision, and ultimately the victory that

22 OFPA worked as it was intended to? Allow a
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1 substance of use added to the National List,

2 reviewed as required by law, and ultimately

3 that material then was removed when the

4 appropriate organic replacements became

5 available.

6 Are we truly there yet? Arriving

7 at that point in time is something that all

8 organic stakeholders will be able to take

9 pride in. OFPA worked, as designed. 

10 MEMBER SONNABEND: Okay. I'm

11 offering some talking points in support of the

12 majority position for an extension.

13 OFPA clearly stipulates that the

14 NOSB review each material by specific use and

15 application. Provisions in OFPA against

16 antibiotics are only stated for animals. 

17 Nowhere in OFPA is there a prohibition against

18 use in crops.

19 It's never been a secret that

20 tetracycline has been approved for fire

21 blight, that has been public record since

22 1995. We posed the question whose
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1 responsibility is it to notify consumers of

2 what the organic rules actually are? Perhaps

3 it's the groups that represent them.

4 Satisfying consumer expectations

5 is not on one of the criteria in OFPA, nor in

6 the federal rule, although it is one of 12

7 criteria for assessing compatibility in the

8 NOSB policy and procedures manual. But there

9 are 11 others. How does this work? Thank

10 you. 

11 The claim that every time someone

12 bites an organic apple, you take in

13 tetracycline is not true. Many organic apples

14 each year are grown without tetracycline. 

15 Other statements in both the majority and the

16 minority position can be challenged and

17 debated at length, without anyone changing

18 their mind.

19 So in the spirit of moving

20 forward, we've laid out all of our positions

21 in both minority and majority in the written

22 document, and we all agree that finding the
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1 best way to remove tetracycline from use,

2 while trying to create a viable way for fruit

3 growers to continue to produce organic crops

4 is our goal.

5 Right now, there are not suitable

6 alternative practices that work in all

7 locations for both apples and pears. 

8 Blossom Protect has shown to be

9 works well in Washington and Oregon, has not

10 been tested enough in California, and does not

11 seem to work in Michigan, and we don't know

12 about New York, North Carolina, Wisconsin and

13 any number of other states where apples and

14 pears are grown.

15 There was 2,000 acres available

16 for 2013 and we're not sure of the

17 availability in the future. The new copper

18 product, Previsto, Harold has just talked

19 about. It's not registered, seems to be

20 pushed back.

21 Limited years and locations of

22 trials means limited information on the timing
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1 of applications between these products and

2 other materials used for scab or other pests. 

3 Limited experience and differing weather

4 patterns and microclimates and limited

5 experience to small test products and not

6 major acreage.

7 The industry does not plan to

8 submit any further petitions. The NOSB

9 majority investigated how to indicate this by

10 resolution, but the NOP was not able to

11 support such a resolution because in the

12 rules, anyone has the right to petition at any

13 time.

14 Therefore, we are simply stating

15 this clearly on the record. The industry does

16 not plan to submit future petitions. 

17 The NOSB Crops Committee discussed

18 possible annotations to put further

19 restrictions on growers and ACAs for

20 alternative practices and oversight, but could

21 not agree that being redundant to what is

22 already part of the ACA and grower procedures
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1 would be worthwhile in an annotation.

2 Therefore, a second resolution has

3 been proposed to address oversight as well as

4 research needs. What we are looking for is a

5 level playing field for growers in all states. 

6 We want to provide U.S. consumers with USA7 grown organic fruit.

8 The majority of the NOSB Crop

9 Subcommittee believes that an extension to

10 2016 is a good compromise between the needs of

11 growers for alternative materials and

12 practices, and the expectation of consumers

13 that organic fruit be grown without

14 antibiotics and produced in the USA. Thank

15 you.

16 MEMBER FELDMAN: Thank you. So a

17 time check here. We have a minority position

18 as well that you should have access to in

19 written form. I'm not going to go through

20 these slides at this point, given the limited

21 time. I hope everyone has a chance to look at

22 these.
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1 But I do want to say, I think Dr.

2 Morris really did capture the urgency of the

3 need to evaluate the impact of continued

4 tetracycline use.

5 Yes, we have to balance the need

6 for this material, but we also have to really

7 seriously evaluate the impact of the material

8 on human health and the environment,

9 compatibility with organic practices and

10 essentiality.

11 This is a complex issue, as you've

12 said Harold and, you know, there are multiple

13 complex factors that come together. The

14 confluence of these issues is almost

15 extraordinary, and you know, starting with the

16 impacts on the environment and contribution to

17 horizontal gene transfer, how that makes its

18 way up the chain, across the chain and

19 ultimately affects our ability as human beings

20 to deal with human pathogens and respond to

21 them in a clinical setting.

22 The subtherapeutic uses are
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1 actually the worst uses in this context. We

2 can't rely on the typical scenario that we

3 think about when we're introducing a synthetic

4 material into the environment, that dose makes

5 the poison or it's very little, or we're an

6 insignificant percentage of overall

7 agricultural production.

8 We really have to look at the

9 mechanism at work here, as was described to

10 us. When we're talking about actual exposure

11 direct through the finished fruit, we have

12 nothing else to go on but what the EPA

13 utilizes as part of its protocol for

14 evaluating residues.

15 The document that's referenced in

16 our technical review is not a study; it's an

17 EPA protocol for setting tolerances. That's

18 what we do when we determine that we need an

19 enforceable level in the fields and after

20 production, to determine whether something is

21 violative of the level that the agency, for

22 better or worse, determines is acceptable.
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1 And by the way, when EPA registers

2 a pesticide and allows an acceptable level,

3 they don't call it safe. It's not allowed to

4 be called safe. It's allowed to be called, as

5 having an acceptable risk. This is where the

6 Organic Foods Production Act differs

7 significantly from the Federal Insecticide,

8 Fungicide and Rodenticide Act.

9 We have a very different standard. 

10 We're trying to advance systems that don't

11 integrate hazards, and the conventional side

12 is trying to integrate hazards by mitigating 

13 risks. It's a totally -- it flips everything

14 on its side.

15 So when the minority looked at

16 antibiotic resistance in human pathogens,

17 ultimately as a result of commensal bacterial

18 resistance at very low levels for short

19 periods of time, for long periods of time in

20 other cases.

21 Even if there's disagreement on

22 some interpretation of some of the studies, we
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1 still have use in the fields, exposure to

2 bacteria, identification of bacterial

3 resistance as a result of its use in the

4 field, and then the cycle of impact on human

5 health down the road.

6 I close by saying that we're not

7 just dealing with another input in

8 agriculture. We're dealing with an input that

9 is unfortunately related to a world crisis in

10 bacterial resistance, and organic needs -- the

11 minority believes that organic is the sector

12 of agriculture that must lead on questions

13 like this, always must lead.

14 It can't hide in the shadow of

15 being a small percentage of overall

16 agricultural production. It must serve as a

17 leader for where agricultural production needs

18 to go. So that's the underlying premise and

19 Mac, I apologize. We are now behind schedule.

20 We have two other materials to get

21 to. As you know, we have polyoxin D zinc. 

22 What I'd like to do, if we could just take
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1 five minutes at this point, is have the

2 leaders on that, if it's acceptable to you

3 guys, to just break down what the vote was,

4 and a couple of sentences on where the

5 majority and minority is on the particular

6 issue.

7 So for IBA, if you could just tell

8 us what the vote in Subcommittee was, and then 

9 give us a sentence or two, and then Harold,

10 John will go first, if that's okay? Give

11 Harold a break or - okay, Harold. You're

12 ready now? I didn't want to impose on you

13 further. Lisa, I apologize.

14 DR. BRINES: That's all right,

15 Jay.

16 MEMBER FELDMAN: Okay, go ahead.

17 DR. BRINES: Thank you. The

18 petition for polyoxin D zinc salt was received

19 by the Program on March 4th, 2012. There were

20 a couple of updates in the interim. It was

21 submitted by Conn and Smith, Inc., on behalf

22 of Kaken Pharmaceutical Company Limited.
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1 The petition requests the addition

2 of polyoxin D zinc salt to Section 205.601 of

3 the National List, to control and suppress

4 fungal diseases in organic crops. The

5 substance does not appear elsewhere in the

6 National List.

7 In support of its review, the

8 Crops Subcommittee requested the development

9 of a third party technical evaluation report. 

10 That report was developed and provided to the

11 Subcommittee in 2012.

12 Both the technical report, the

13 original petition and two subsequent petition

14 addenda were posted on the NOP website in

15 advance of the opening of the public comment

16 period. Thank you.

17 MEMBER AUSTIN: Okay. We

18 received, the Crop Subcommittee received the

19 petition to list polyoxin D zinc salt as a

20 synthetic substance to be allowed for use in

21 organic crop production under 205.601. 

22 It's a material that's derived
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1 from streptomyces, classified as a fungicide

2 rather than an antibiotic. It's a funginistic

3 form of action. The Crops Committee, voting

4 to classify it as a synthetic, 8 yes, 0 no, no

5 abstentions, no abstains.

6 The listing motion to add polyoxin

7 D zinc salt to the National List 205.601 as a

8 synthetic substance allowed for use in organic

9 crop production. 3 yes, 4 no, 1 abstention. 

10 The rationale behind the majority

11 vote to not list it was that it was not

12 essential, that it was a broad spectrum

13 fungicide, and that there were concerns with

14 its impact on soil, biological and fungal

15 activity and also predacious predators.

16 The minority position was that it

17 was a FRAC-19 fungicide. It was funginistic,

18 fungistatic activity, so it did not physically

19 kill the fungi. It inhibited cytokine

20 development.

21 We did have some concerns, though,

22 on its impact on beneficials, that I still
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1 think that even the minority did not quite get

2 all of their questions answered as well. So

3 I think that's all I've got for the moment. 

4 We'll hand it over to Lisa.

5 MEMBER FELDMAN: Thank you, Jean,

6 and thank you Harold. John, you're up next,

7 but I'm going to go to Lisa first. Thank you.

8 DR. BRINES: Thank you, Jay. The

9 next petition on the agenda is indole-3-

10 butyric acid, also known as IBA.

11 This petition was received on

12 August 8, 2012, and was submitted by Hortis,

13 and as some of you in the audience may recall,

14 this substance was previously petitioned

15 before the Board in 2009, and the Board made

16 its recommendation on the previous petition in

17 November 2011. 

18 The petition requests the addition

19 of IBA to Section 205.601 of the National

20 List, for use in plant propagation from

21 cuttings. It is not currently listed

22 elsewhere on the National List.
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1 In support of its review this

2 time, the Subcommittee did not request the

3 development of a new technical report, and

4 instead referred to the technical report that

5 was developed in response to the previous

6 petition. So the current technical report

7 that's available is dated 2011.

8 Both that technical report, the

9 previous petition and the petition that's

10 before the Board today were all posted on the

11 NOP website in advance of the opening of the

12 public comment period for this meeting. Thank

13 you.

14 MEMBER FELDMAN: Thank you. John.

15 MEMBER FOSTER: Thank you. 

16 Melissa, I think you said about half of what

17 I was going to, so I'll just summarize. The

18 change here over the previous petition was to

19 the method, to limit it to the purpose of

20 plant propagation via dipping this time

21 around.

22 That was the difference. We voted
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1 to classify it as petitioned as a synthetic

2 material, 8 to 0, and then to list. The

3 listing motion was to list indole butyric acid

4 or IBA, with its CAS number 133324 as

5 petitioned on 601 for the purpose of plant

6 propagation via dipping. That vote when 3 yes

7 and 5 no, and 0 absent, abstained or recusing.

8 In general, it met the criteria

9 for lack or negligible impact on humans and

10 environment, and then had, on the whole, no's

11 for essentiality and compatibility of

12 consistency. Then the commercial supply was

13 not applicable.

14 MEMBER FELDMAN: Thank you, and I

15 turn the gavel back to you, Mr. Chair. Thank

16 you.

17 CHAIRMAN STONE: Okay. So I think

18 the plan is we'll have a little further

19 discussion about each of these materials as we

20 go through the voting process tomorrow. We'll

21 engage public comment here this afternoon. So

22 we'll further discuss this tomorrow. With
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1 that in mind, we remind you that we're here to

2 listen to the public.

3 So I want to work through these

4 questions. Again, it's scheduled at one

5 minute per person for questions, including the

6 time it takes to ask the question. 

7 So public commenters, if you see

8 me going like this or like this, that means

9 you're going like this, and you need to be

10 going like this, if you get a question. So

11 it's just in fairness to those that follow you

12 is where this is going.

13 So again, the process is if you're

14 just getting here, there's a little stoplight

15 system on the podium. It's green for three

16 minutes, then yellow for one minute, and then

17 a red light with a beep that indicates time. 

18 Everyone's been very respectful of that, and

19 hope you'll continue to do so.

20 I'll call one person to be at the

21 podium, and then the second one is on deck,

22 which means if you'll go ahead and come up
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1 towards the front and stand behind Michelle,

2 so that we can rotate in and out of the podium

3 as quickly as possible. I appreciate your

4 assistance on that.

5 So first we have Gerald Davis at

6 the podium, and James Adaskaveg. Excuse me,

7 you can help me with that when you get up

8 here. Gerald.

9 Public Comment/Crops Subcommittee

10 MR. DAVIS: Good afternoon. 

11 Gerald Davis, Grimmway Farms out in

12 California. I am ex-NOSB Board member from

13 2005 to 2010, and Crops Subcommittee chair for

14 three years.

15 I reviewed a lot of materials

16 during that time, and voted sometimes to list,

17 sometimes not. I felt I was fair-minded and

18 willing to consider each material, and not

19 just automatically vote one way or the other.

20 I've encouraged that out of this

21 Board. I see the vote on the polyoxin D in

22 the Crop Subcommittee was relatively split. 
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1 If everyone had voted, I'm sure it would have

2 been exactly split. So I see that the vote

3 for this material will probably be the same

4 for the full Board.

5 Been a long-time crop advisor for 

6 Cal Organic, Grimmway, 20 years or more, and

7 a lot of experience with 30 or more crops. 

8 What I like about this material is that it's,

9 you know, it is a naturally derived

10 fermentation type product with a twist, which

11 is why the Board is reviewing it. Otherwise,

12 it would just be allowed, because it is a

13 natural. The addition of the zinc salt makes

14 it become synthetic. 

15 I like that it works differently. 

16 As a grower, it works differently than the

17 other organically approved materials that are

18 already on the market. A lot of the materials

19 on the market are preventive fungicides such

20 as copper or other things, that you pretty

21 much have to predict what diseases you will

22 have and when they will be a problem, and put
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1 the material on, if you really want to get

2 control in an area where you have disease

3 pressure.

4 Copper is a problem. In some

5 areas, not in our area in California, but we

6 do use copper. In some areas, they use a lot

7 of it, and it's an environmental problem for

8 organic growers, to be putting on a lot of

9 metallic copper every single year. I see this

10 material as a potential aid in cutting down on

11 that usage of copper.

12 Another thing I like about it, it

13 controls certain diseases that none of the

14 other materials already certified will touch,

15 like Southern blight or sclerotium rolfsii,

16 which is a pest in potatoes, in carrots and

17 potentially in onions. I hear it's a pest in

18 peanuts.

19 This material, from research I've

20 been made aware of, works really well for a

21 disease called alternaria, which would be

22 alternaria leaf blight in carrots is a serious
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1 disease, and we deal with it all the time. 

2 Alternaria leaf spots in almonds and stone

3 fruit is also a problem for organic growers in

4 certain areas. So this material would be very

5 helpful. 

6 Another disease it controls is

7 botrytis in stone fruit and tomatoes. Our

8 farm grows greenhouse tomatoes. Botrytis is

9 not a usual problem. We manage it, you know,

10 environmentally mostly, but it would be nice

11 to have a material to fall back on if we

12 needed it.

13 But I just come as a grower to ask

14 you to seriously consider the material, and

15 not just rule it out based on your biases one

16 way or the other or vote it in, if you're

17 biased towards voting in more materials. Just

18 consider it carefully please. Any questions?

19 CHAIRMAN STONE: Thank you very

20 much. So James and Richard Conn is on deck.

21 MR. ADASKAVEG: I'll thank you for

22 the opportunity to come here today and speak
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1 to you about polyoxin D. My name is

2 pronounced Jim Adaskaveg, and I appreciate

3 your concern with pronouncing it. Anyway, I'm

4 a professor at the University of California5 Riverside.

6 I study epidemiology and

7 management of fruit and nut tree diseases, and

8 I basically developed the disease management

9 programs for a lot of the tree and fruit nut

10 commodities in California.

11 I work with the statewide UC-IPM

12 pest management program and develop

13 guidelines, and that includes for organic tree

14 fruit and nut production. Thus, I work with

15 the Boards, and Boards still think that I

16 should be developing new products and those

17 products include organic products for that

18 segment of our industry.

19 We do a lot of screening of

20 materials, and identifying organic products is

21 part of our mission goal. Although there's

22 numerous products labeled for tree fruit
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1 production that are under organic product

2 listing, things like many different copper

3 formulations and many different natural

4 products.

5 Many of these products have, do

6 not, they represent limited modes of action

7 and are not necessarily, a lot of them might

8 be redundant to each other under the concept

9 of FRAC, of listing materials by mode of

10 action.

11 Many of the products have

12 limitations. Low to moderate efficacy is one

13 of the major concerns. There's potential

14 phytotoxicity with certain products like

15 copper on tree fruit crops, and there's also

16 labeling limitations.

17 So although there's a lot of

18 different products listed, and if you go

19 through the labels, many of them have

20 constraints that prevent their use in a high

21 performance level.

22 Many of these products are
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1 overused in my opinion, and so therefore

2 having alternatives will prevent environmental

3 contamination and/or allow for better worker

4 safety. We're concerned with workers and

5 overuse of sulfur products on tree fruit crops

6 and again, this is a concern of why we will

7 need to develop these types of products.

8 So part of our, to get to the

9 point, I've screened a lot of products,

10 hundreds of products over the years. Polyoxin

11 D represents one of the first new biofungicide

12 registrations I helped develop with other

13 companies here in the U.S. or under the EPA

14 registration.

15 As mentioned by Gerald Davis, it's

16 a fermentation product, which is a natural

17 product, and fortunately it was actually

18 evaluated critically for toxicological

19 characteristics and has been recently listed

20 last year as exempt from tolerance by the EPA.

21 It has broad spectrum activity, as

22 most people have recognized, with activity
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1 against alternaria, which even conventional

2 materials have a hard time controlling, and

3 for almond production this is essential in

4 California, even for the organic production.

5 One of the revolutionary ideas of

6 using polyoxin D is that we're developing it

7 also for potential use for post-harvest

8 disease control, which there are no materials

9 available in the organic segment for managing

10 post-harvest decays once a crop is harvested.

11 This material, again, has that

12 potential with outstanding efficacy against

13 brown rot and gray mold, which is botrytis. 

14 So in summary, I fully endorse the

15 registration of polyoxin D, even under the

16 segment of the synthetic materials approved

17 for organic use. Thank you.

18 CHAIRMAN STONE: Thank you. 

19 Questions, Jean.

20 MEMBER RICHARDSON: Yes, I have a

21 question. The technical report, I'm here.

22 MR. ADASKAVEG: Oh, okay. There
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1 you are.

2 MEMBER RICHARDSON: The technical

3 report says that this material has the

4 potential to have a negative impact on the

5 beneficial materials in the soil, as it says,

6 beneficial.

7 MR. ADASKAVEG: Fungi.

8 MEMBER RICHARDSON: Fungi in the

9 soils. Do you have any research experience

10 that would help us to better understand that?

11 MR. ADASKAVEG: We deal mainly

12 with foliar diseases, but from our experience,

13 I mean most of these pesticides, including

14 polyoxin D, at the rates we're using them,

15 they are organic compounds in the strict sense

16 of carbon-based. They are degradable, and we

17 don't see long-term persistence or detrimental

18 effects on the vast majority.

19 There is, all these materials,

20 including polyoxin D, has a range of materials 

21 or a range of efficacy on different diseases,

22 and it's not going to be a broad spectrum
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1 fungicide killing all fungi in the soil. 

2 There are microbes that degrade it, and it

3 does not last in a persistent environment.

4 MEMBER FELDMAN: The technical

5 review also says it's long been regarded as an

6 antibiotic because of structure and function.

7 MR. ADASKAVEG: I failed to

8 mention that we actually screened this

9 product. We're also involved with screening,

10 looking for new bactericides such as

11 kasugamycin for fire blight control. We've

12 identified that material, and it's going

13 through the EPA registration. 

14 We looked at polyoxin D, and it

15 had no bactericidal effect on the bacterial

16 diseases that occur on tree fruit crops in

17 California. I obviously don't screen against

18 all bacteria.

19 CHAIRMAN STONE: Harold.

20 MEMBER AUSTIN: With the rotation

21 of a new mode of action, fungicide into the

22 organic program if this one was approved, what
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1 impact would that have on soil health in

2 quality, because this would then, as you

3 stated, would replace the overuse or the heavy

4 use of coppers, sulfurs, those types of

5 materials.

6 So what would this -- inclusion of

7 this for use, what would this do to soil

8 health and quality?

9 MR. ADASKAVEG: The concerns here

10 are that we don't want to use this

11 exclusively. Resistance, as we know with any

12 product, whether it's antibiotics or

13 fungicides or potential organic materials,

14 resistance can develop, even to copper

15 materials with over-usage.

16 So we're not promoting the

17 exclusive use of polyoxin D, but rather using

18 it in an integrated approach, and we

19 definitely can see that as we screen new

20 materials for organic usage, we want to start

21 with, you know, a foothold with polyoxin D for

22 organic use, and then potentially develop
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1 other materials that can be coincidal, other

2 organic materials, fermentation products,

3 other plant extract materials that can be used

4 in concert.

5 As I said earlier, I don't think

6 it's going to have a long term effect. It is

7 degradable material, and with toxicology looks

8 favorable as something that will not persist

9 in the environment and not be totally

10 effective against eliminating soil fungal

11 flora. 

12 It's not that broad spectrum. 

13 It's broad spectrum in the sense of foliar

14 fungal diseases of and certain diseases of

15 roots on tree crops that I've tested. So I

16 don't think it has that type of long-term

17 persistence and broad spectrum activity to

18 ruin the microflora of, the fungal component

19 of soil microflora.

20 CHAIRMAN STONE: Francis, if

21 you'll finish up.

22 MEMBER THICKE: Yeah. It said in
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1 the technical review that the mode of action

2 is that it inhibits the formation of chitin in

3 the maul of fungi, and that makes basically

4 broad spectrum. Would that also affect the

5 beneficial fungi in the soil as well?

6 MR. ADASKAVEG: Yes. The question

7 is exactly correct. That's been the studied

8 mode of action. But there's different types

9 of these chitinases that are being developed

10 by different fungi.

11 They're not all -- chitinase is a

12 general term. They're not all exactly the

13 same. So we do see degrees of activity of

14 polyoxin D against different types of fungi.

15 So for example, we see that it

16 works very well on alternaria and ground root

17 botrytis, but it has no activity on rhizopus,

18 mucor, zero activity, and they're all chitin19 producing fungi.

20 So the chitinase, synthase

21 molecules are different between different

22 fungi, and that's the extent of our research
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1 on that. 

2 MEMBER THICKE: And then relative

3 to persistence, the TR said the half life is

4 32.5 days at pH 7 at 25 degrees Centigrade. 

5 Would that be a fairly long persistence?

6 MR. ADASKAVEG: That's considered

7 fairly short, I mean in the sense that

8 depending on how you want to look at it, it's

9 not persisting very long, and your mode of

10 action would be basically if it's a half life,

11 you'd be expecting that to work for disease

12 control, maybe seven to ten days.

13 MEMBER THICKE: I was referring to

14 in terms of soil food web, 32 days of effect

15 on fungi in the soil, food web adapting.

16 MR. ADASKAVEG: Well that's

17 considered very good in microbial beneficials

18 and support, that these things do degrade. 

19 That's the time line that was I was

20 suggesting.

21 There are products out there, not

22 to mention anything in specific, but that
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1 lasts months in the soil, and this is

2 obviously in that much shorter 32-day time

3 frame. So that's the mind set that I'm coming

4 from, that it is a very short persistence with

5 that type of half life.

6 CHAIRMAN STONE: Thank you. 

7 Richard Conn and Cynthia Smith is on deck.

8 MR. CONN: Good afternoon. My

9 name is Richard Conn. I'm the president of

10 Conn and Smith, Incorporated, and Cynthia

11 Smith and I will be speaking today in support

12 of polyoxin D zinc salt.

13 First, I'd like to call to your

14 attention the five submissions that Conn and

15 Smith, Incorporated has made on behalf of

16 polyoxin D zinc salt. First was the revised

17 petition that was submitted March 4th of last

18 year, 2012. 

19 Second, was the reply to the

20 technical report that was submitted January

21 18th of this year. The third item was the

22 reply to the Crop Subcommittee's
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1 recommendations, submitted on March 6th this

2 year, and then there were four reports

3 regarding the safety to beneficials that was

4 submitted March 22nd of this year.

5 Finally, the fifth item was new

6 data on the safety to earthworms that was

7 submitted on April 4th of this month. So

8 polyoxin D zinc salt is not an antibiotic. 

9 The decision to include or exclude polyoxin D

10 zinc salt from organic crop production is a

11 regulatory decision.

12 Only a regulatory definition of

13 antibiotic or antibiotic drug should be used

14 as part of the regulatory decision-making. 

15 Otherwise, the regulatory decision would be

16 arbitrary and capricious. Neither antibiotic

17 or antibiotic drug are defined by USDA, NOP,

18 EPA or FIFRA. 

19 The Federal Food, Drug and

20 Cosmetic Act defines antibiotic drug and

21 requires intended use in humans or animals. 

22 Polyoxin D zinc salt has always been marketed
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1 exclusively as a plant protectant. Polyoxin

2 D zinc salt is not and has never been intended

3 for use in humans or animals.

4 Therefore, polyoxin D zinc salt is

5 not an antibiotic, as defined by the Federal

6 Food, Drug and Cosmetic Act. Regarding safety

7 to humans, polyoxin D zinc salt has large

8 margins of safety for humans. The formulation

9 developed for organic market has such low

10 toxicity that EPA does not require a first aid

11 statement.

12 Also, polyoxin D zinc salt has an

13 extensive toxicology database, and EPA has

14 determined that polyoxin D zinc salt does not

15 cause mutations, birth defects, cancer or

16 other long-term health effects.

17 Polyoxin D zinc salt provides

18 broad spectrum control of crop fungal

19 pathogens only. Most of the 73 EPA registered

20 uses are also California registered uses. We

21 request your support for the inclusion of

22 polyoxin D zinc salt in organic crop
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1 production. Thank you.

2 CHAIRMAN STONE: Thank you. 

3 Harold.

4 MEMBER AUSTIN: We've -- I'm here. 

5 We received all of the information that you

6 submitted, the various beneficial data and

7 studies, the earthworm study.

8 The one thing that was missing and

9 the one thing that we were really trying to

10 get further information and declaration on is

11 in the TR report, there is one study that

12 showed there was an incidence where because

13 polyoxin D is a chitin inhibitor, there was a

14 negative impact on I believe it was some type

15 of a roach.

16 Our question is on beneficial

17 insects such as ladybird beetles, those types,

18 we've seen your lacewing studies and some of

19 the others. But very specifically, when we're

20 looking at beneficial insects such as

21 ladybugs, the beetle family that are

22 definitely valuable in our crops, is there a
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1 negative impact or not?

2 Does it inhibit during the molting

3 process? Does it inhibit the chitin formation

4 on those types of beneficial insects?

5 MR. CONN: I'm going to defer the

6 answer to Cynthia Smith. She's a lot more

7 familiar with this than I am. Hopefully, she

8 has the answer.

9 MEMBER AUSTIN: Okay, thank you.

10 CHAIRMAN STONE: All right. 

11 That's your cue, Cynthia. You're up.

12 MS. SMITH: Thank you and good

13 afternoon. My name is Cynthia Smith. I'm

14 here on behalf of Kaken. I'm the Vice

15 President of Conn and Smith, and I'm also the

16 primary author of the petition.

17 It's probably best to start with

18 the answer to the question that was asked

19 about ladybird beetles. Fundamentally,

20 polyoxin D zinc salt has the mode of action

21 that is specific to cell walls. There are

22 plant cell walls and animals do not have cell
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1 walls. They have cell membranes.

2 So the study that you mentioned

3 having to do with cockroaches looked at organs

4 of cockroaches that had been put through a

5 blender and it was done entirely in vitro. 

6 There's no evidence whatsoever that there is 

7 any efficacy for control of insects using

8 polyoxin D zinc salt, zero evidence

9 whatsoever.

10 Going back to some of the things

11 that were mentioned earlier, the mode of

12 action of polyoxin D zinc salt is it

13 suppresses the formation of chitin synthesis,

14 such that it doesn't kill the fungus; it only

15 stops the growth of the fungus.

16 This is important when you're

17 looking at the environmental impacts, because

18 if you're looking at the impacts on soil

19 health, that effect is a temporary effect. It

20 degrades in the order of 50 percent in the

21 order of a month in the soil.

22 So it will have a temporary effect
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1 on the soil microbes, and so you could in fact

2 apply it with something that would be

3 suppressed, but you will get a later

4 beneficial effect. So yes, it might cause

5 lack of growth, but it will not kill the fungi

6 that are naturally occurring in the soil.

7 Now in the way of other non8 targets, I'd first like to point out that it

9 is not toxic to be as defined by the

10 Environmental Protection Agency, and then

11 there were some additional studies that were

12 recently submitted, recently translated, and

13 those were on silk worms, hover flies,

14 lacewings and wolf spiders.

15 The thing that's noteworthy there

16 is that one, there was no mortality; two,

17 there was no adverse effects on behavior and

18 for the three beneficial insects. There was

19 no negative impact on the development. So

20 they developed normally from larvae to pupae. 

21 Also recently submitted, there's

22 no adverse effects on earthworms. There has
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1 been a lot of discussion within the technical

2 report about what happens within the soil and

3 the soil organisms, but again, no adverse

4 effects on earthworms.

5 Another issue that was raised has

6 to do with fish and aquatic invertebrates. 

7 Because polyoxin D zinc salt degrades so

8 rapidly in the environment, and because it's

9 applied only to terrestrial crops and only at

10 low use rates, EPA concluded that there would

11 be negligible concentrations of polyoxin D

12 zinc salt in, in this case, drinking water,

13 pond water, reservoirs, rivers.

14 So this is a material that can be

15 very adequately used, safely used with regard

16 to aquatic organisms. Thank you.

17 CHAIRMAN STONE: Thank you. Any

18 questions for -- Francis?

19 MEMBER THICKE: A quick question

20 about the essentiality. Do you see this as an

21 essential need for organic? I'm looking at

22 the TR and there are two pages of alternative
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1 products that are approved for organic use,

2 for a whole range of crops and diseases, fungi

3 diseases.

4 MS. SMITH: Well, I would say that

5 yes, it is essential, and the reason for that

6 is that no matter what fungal disease you're

7 looking at, maintaining an environment where

8 you do not establish resistance or do not

9 encourage resistance is important.

10 One of the things that polyoxin

11 does it provides a unique new mode of action,

12 and that uniqueness gives it a special

13 position. Now when we were looking at the

14 spectrum of diseases, there are diseases that

15 are problematic to growers, and polyoxin D

16 zinc salt does provide control of diseases

17 that are otherwise hard to control.

18 Yes, there are a number of

19 products that are registered, but those

20 registered products have only a small number

21 of modes of action, and for those that are

22 registered, there are many instances in which
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1 the control will be described as lackluster.

2 So this would give growers an

3 opportunity to in fact gain control, not just

4 prospectively, but many of the products are

5 registered only for as a preventative. But

6 polyoxin D zinc salt is also registered as a 

7 curative material.

8 CHAIRMAN STONE: Harold.

9 MEMBER AUSTIN: Yeah. I think part of

10 your petition, and then also from some of the

11 public comment that we got, stated that there

12 were several diseases like I think gummy stem

13 Southern blight, that there were really no

14 true effective alternatives to it, and that

15 this would give those growers an opportunity

16 to come in and have a material that they could

17 use that would be effective, and also it could

18 be applied after the fact, as a curative

19 material.

20 So I have seen that in the

21 comments and in your information that you've

22 provided. One comment in written testimony
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1 that raised one concern, and I liked a little

2 bit of clarification, would be on the post3 harvest use. What would be the intent, the

4 crops, the timing of the application there,

5 and it looks like it's a fairly safe material.

6 But I think I'd like to see some

7 clarification of the post-harvest direction of

8 the material as well.

9 MS. SMITH: Okay. I prepared the

10 petition to EPA to extend the limited number

11 of tolerance exemptions to all crops, pre12 harvest and post-harvest. EPA approved that

13 petition. There are no currently registered

14 uses that are post-harvest. 

15 The petition, the tolerance

16 exemption is in place. That gives us the

17 green light to actively develop post-harvest

18 uses, but there are none that are currently

19 registered.

20 I learned over lunch today that 

21 there has been research done by another

22 company, that does demonstrate good control in
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1 cherries post-harvest.

2 CHAIRMAN STONE: Great. Thank you

3 very much. We appreciate that.

4 MS. STEINER: Thank you.

5 CHAIRMAN STONE: We're going to --

6 we're not too bad, a little bit off. But

7 we're going to take a 12 minute break, be back

8 here at 3:35, and Alexis Baden-Mayer will be

9 first up. If Alexis, you can be here.

10 (Whereupon, the above-entitled

11 matter went off the record at 3:23 p.m. and

12 resumed at 3:36 p.m.)

13 CHAIRMAN STONE: It's time to call

14 the meeting back into session. If I can have

15 the Board members -- I see that. I see who

16 get brownie points later today. May get to

17 ask an extra question, for instance. Tracy's

18 here, gets to ask all the questions she wants.

19 So appreciate everybody. Twelve

20 minutes is hard, and like I said yesterday,

21 the conversation and networking is a big part

22 of our week-long meeting. So if I could ask
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1 those in the audience to have a seat please. 

2 Okay. 

3 So we're back in. We're starting. 

4 We have a series. The way Michelle worked

5 these out, we have quite a few presenters on

6 tetracycline specifically. So first up is

7 Alexis Baden-Mayer, and Lynn Coody is on deck. 

8 Alexis.

9 MS. BADEN-MAYER: Hello. I'm

10 Alexis Baden-Mayer. I represent the Organic

11 Consumers Association. Most organic consumers

12 do not know that there has been an exception

13 for tetracycline on organic apples and pears

14 since 1995, and obviously no organic consumer

15 would want any organic orchards to be lost.

16 But it's worth pointing out that

17 since 1995, new orchards could have been

18 planted and could have even reached maturity

19 four or five times already. It's pretty easy

20 to understand why consumers would be

21 frustrated at this point by the industry

22 always being given two more years. This has
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1 gone on too long.

2 We need to stick to an expiration

3 date for once, and unfortunately honestly I

4 don't believe that that will ever happen if

5 the growers get two years this time, two more

6 years again.

7 Almost 30,000 people have signed

8 our petition now to get antibiotics out of

9 organic apples and pears. The official count

10 is 28,581, and that's after de-duplicating;

11 it's after taking out anyone from overseas. 

12 Those are just U.S. residents that gave us a

13 zip code and a state and a name and a comment.

14 5,897 people took the time to

15 write unique comments, and I'd like to read as

16 many of these for you today from the record. 

17 My favorite is the most succinct.

18 Blakely Dillar of Ohio says

19 "Antibiotics are for sick people, not for

20 healthy food. But when consumers learn that

21 every time they eat an organic apple or pear,

22 they risk exposing themselves and their gut
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1 flora to measurable levels of tetracycline,

2 this means something for certain consumers

3 especially."

4 We have three pages of comments

5 from consumers whose comments begin "I am

6 allergic," and they tell a story of being

7 allergic to antibiotics, and specifically, in

8 some circumstances, tetracycline. Lynn Gorski

9 from Indiana says "I am allergic to

10 tetracycline. Therefore certainly do not want

11 that on my apples."

12 Pat Faith from Michigan says "I am

13 allergic to tetracycline. Since we don't know

14 the producers of the non-antibiotic fruit, I'm

15 in a quandary.

16 How do I know if the organic fruit

17 I purchase had tetracycline used on it? I buy

18 organic because I don't want to worry about

19 the added stuff that is not necessary for food

20 to be produced. I was horrified to hear that

21 antibiotics are being used."

22 Michelle Swisher from Oregon says
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1 "I am allergic to tetracycline and all other

2 cyclines, to the point that I can't touch

3 people who are taking it. Now to find out the

4 drug that hurts me is in my food is scary. 

5 How often have I been sick from that?"

6 Crystal Stillman from Vermont says

7 "I am a low income single mother of three

8 children. I buy organic food to protect the

9 health of my children. I am horrified to

10 learn that pears and apples advertised as

11 being organic are not really organic, because

12 the government allows them to be sprayed with

13 antibiotics. Please stop this false

14 advertising."

15 Jamie Bennel from Tennessee says

16 "I am a nurse, and try to raise my kids as

17 natural and healthy as possible. Medications,

18 including antibiotics, are used on as

19 sparingly as needed basis, and the more

20 exposure we get to them, the less effective

21 they are. Please allow me the right to choose

22 what goes into my body."
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1 Michael Goodman says, from

2 Florida, says "I am a Ph.D. health care

3 professional. For my own benefit, as well as

4 for my clients, I strongly request that my

5 organic food not contain antibiotic residues. 

6 This is simply not necessary."

7 Julie Fox from Florida says "I am

8 a registered voter with a severe life9 threatening allergy. Please comply. Keep our

10 medications effective and my gut bacteria

11 intact."

12 Nora Gottlieb from North Carolina

13 says "I am allergic to antibiotics. I break

14 out in itching spots with a white center. It

15 takes four months to clear my body. No to

16 antibiotics," and there are almost 6,000

17 comments like that.

18 CHAIRMAN STONE: Thank you,

19 Alexis.

20 MS. BADEN-MAYER: And I delivered

21 them printed out. I've got two copies. I

22 tried to print them out as sparingly as
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1 possible, but it fills an entire box and I

2 hope you will rifle through these.

3 CHAIRMAN STONE: Good. Jean.

4 MEMBER RICHARDSON: Hi. No

5 disrespect meant at all, but if you have an

6 article, a scientific article that you found

7 that specifically says that there are -- that

8 tetracycline is in the fruit, the pears or

9 apples, I sure would appreciate that

10 reference.

11 MS. BADEN-MAYER: Well, I did

12 actually include an industry paper, and

13 initially, I didn't realize that residues

14 would be an issue with this, because I was

15 told the blossoms are sprayed and by the time

16 it gets to the fruit, there are no residues.

17 But in the course of looking at

18 this issue, I did find an industry paper

19 that's titled "Antibiotic residues on plant

20 tissues, and actually this same --

21 MEMBER RICHARDSON: Is it on plant

22 tissues or in plant tissues?
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1 MS. BADEN-MAYER: Yes, on plant

2 tissues.

3 MEMBER RICHARDSON: On.

4 MS. BADEN-MAYER: And the same

5 figure that's mentioned in this paper was

6 mentioned earlier today. It's a parts per

7 million figure for residues of tetracycline on

8 apples, I believe.

9 I included this along with our

10 comments, and even though this is an industry

11 paper, so it says that there are measurable

12 residues, but it's not a worry, that's not why

13 I'm submitting this paper.

14 I think consumers are worried

15 about residues, and I was completely shocked

16 having first been told that residues weren't

17 an issue, to learn that industry is well aware

18 that there are residues of antibiotics on our

19 food. Not always, but we do have a risk of

20 those residues, and sometimes they're up to a

21 certain amount, and that's in this paper.

22 CHAIRMAN STONE: Okay, thank you. 
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1 Lynn Coody is up and Jane, excuse me,

2 Bultedaob, Bultidab. You can correct me when

3 you get up. Jane's on deck.

4 MS. COODY: Hi. My name is Lynn

5 Coody, and I'm commenting on behalf of my own

6 business, Organic Agsystems Consulting, which

7 is located in Eugene, and today I would like

8 to speak about the centrist proposal for

9 tetracycline.

10 I've worked on the tetracycline

11 issue many times, beginning in the late 1980's

12 and in this round of work, I first looked at

13 the overarching themes, and came up with my

14 goal for a tetracycline policy, that is, to

15 develop practical and principled production

16 policies.

17 I think it's important for the

18 NOSB to balance practicality and organic

19 principles, because in my years of work on

20 organic standards, I have noted that decisions

21 based too much on either one of the

22 foundations of organic world rarely lead to an
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1 outcome that works in both field and the

2 marketplace.

3 At this stage of its evolution,

4 organic agriculture is still described as an

5 alternative to conventional farming. In my

6 mind, a polarized just say no approach is

7 focused too much on principles, and results in

8 some growers having no alternatives but to

9 move toward IPM or conventional production.

10 Decisions based too much on

11 practical considerations can result in

12 consumers searching for alternatives to buying

13 organic products. Worse case, when the policy

14 about a material or practice is crucially

15 important to the success of growers like

16 tetracycline, is based on highly polarized

17 discussions, both production and sales can be

18 put at risk.

19 Clearly, alternative agriculture

20 needs alternative solutions to policymaking. 

21 A balanced approach that takes into account

22 the needs and concerns of all stakeholders can
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1 provide a way forward, that will foster the

2 stability and continued evolution of organic

3 systems.

4 I'd like to propose three

5 elements, that when taken together, provide a

6 practical and principled approach for a policy

7 on tetracycline. Limited duration extension,

8 annotation and increasing confidence through

9 oversight. 

10 So first is extension. I support

11 an extension that ends in October 2016 as

12 proposed by the Crops Subcommittee. This time

13 frame allows four more fire blight cycles for

14 testing management systems and materials, both

15 on research plots and on farms.

16 Further, it ensures that

17 tetracycline will be removed from the National

18 List prior to the date at which it would

19 normally sunset, thus precluding another round

20 of discussion on this contentious topic.

21 I recognize that this time frame

22 is completely insufficient for long term
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1 solutions, such as developing and planting

2 varieties and root stocks that are resistant

3 to fire blight.

4 However, I think the intense focus

5 by researchers and growers on new materials

6 and practices will result in innovative

7 practical strategies that can be implemented

8 quickly.

9 Annotation. OFPA provides a

10 unique role for the NOSB in the review of

11 synthetic materials. This authority has

12 always included the ability of the NOSB to

13 recommend limitations to the approved use of

14 a material through annotations.

15 Once an annotation is added to the

16 National List, it creates a direct, legally

17 binding linkage between the NOSB's decision

18 and both the regulation and oversight of the

19 organic industry. Some commenters noted that

20 annotations increased the difficulty of

21 implementing the regulation, and I agree with

22 them.
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1 However, I don't think this is

2 necessarily a detriment. In my mind, the

3 increase of regulation, the experience on the

4 ground supports the idea that annotations are

5 a powerful tool for the NOSB to effect change.

6 Oversight. Those of us who work

7 with the NOP standards every day know about

8 the hierarchy of disease control in 205.206,

9 which requires a primary focus on preventative

10 practices.

11 Consumers and marketers have not

12 necessarily been aware of this important part

13 of the NOP regulations. For this reason, I

14 recommend including a few words about

15 oversight in the annotation, in order to

16 reassure consumers about the stringent steps

17 that growers and certifiers must take, to

18 ensure that antibiotics are used only as a

19 last resort.

20 And in my paper, which I passed

21 out, I've proposed an annotation for your

22 consideration. But I don't have time to say
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1 it right now.

2 CHAIRMAN STONE: Thank you, Lynn. 

3 Zea.

4 MEMBER SONNABEND: Lynn, what

5 annotation do you think would be a good --

6 (Laughter.)

7 MS. COODY: Well Zea, I would --

8 I'll be happy to answer that question. Here's

9 my annotation. Originally, the centrist

10 proposal, the first draft of the centrist

11 proposal had a much more involved and long

12 annotation with the intent of trying to

13 explain to both ends of the spectrum, both the

14 consumer side and the grower side, some of the

15 options that were allowed.

16 We recognized from the start this

17 was way too long for an annotation, so here it

18 is. This is the revised one. "Tetracycline

19 for fire blight control in apples and pears

20 only until October 21st, 2016. Tetracycline

21 may only be used if the grower has implemented

22 an integrated system of practices and
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1 materials to control fire blight.

2 "Orchard management systems must

3 demonstrate an annual increase in the extent

4 or number of alternative practices for

5 managing fire blight." So there's three

6 sentences. Each one meets one of the goals

7 that I talked about.

8 One is the, shows the deadline. 

9 One is providing oversight, and one is talking

10 about the implementation of Section 206 of the

11 standards.

12 So we have received so many

13 comments from consumer groups that we've

14 worked with, that an annotation is important

15 to them because it is the legally binding

16 option. Other options such as you proposed in

17 the Crop Committee are not legally binding,

18 and having oversight explained, they told --

19 We had feedback from them saying

20 that it would help them a lot, to explain the

21 situation to the consumers, and to show that

22 there is -- to reemphasize that in this
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1 particular case, there is strong oversight,

2 even though we all know that it is already in

3 place. So it's just a reiteration.

4 CHAIRMAN STONE: Harold.

5 MEMBER AUSTIN: Lynn, thanks for

6 all the effort that you put forward working on

7 this. The resolution that you came up with,

8 the language for that, you were just talking

9 about some of the consumers and the consumer

10 groups that you had.

11 I'm assuming that this resolution

12 came forward as part of the discussions and

13 the conversations that you had with others?

14 MS. COODY: Yes. I did this work

15 on behalf of the National Organic Coalition,

16 and starting about last August, we made

17 multiple efforts with many, many different

18 parties, both from the consumer, the grower

19 side, all kinds of people within the industry,

20 trying to put together small meetings for them

21 to talk together.

22 This is my interpretation of what
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1 I heard from the consumer groups, you know. 

2 You've heard a lot of testimony that they

3 didn't know what, that consumers didn't know

4 about this. So in writing this annotation, I

5 tried to give some emphasis that could allow

6 consumer groups to explain the situation a

7 little bit better to consumers.

8 So yeah, this is my interpretation

9 of -- it's my effort to try to have a

10 compromise position that recognizes the

11 concerns of both the consumers and the

12 growers, which are on both ends of the

13 spectrum.

14 CHAIRMAN STONE: Thank you, Lynn. 

15 Jane Bultedoab or Jane and your last name

16 starts with a B. If you're in the room,

17 you're up. I didn't see any movement, and

18 there's not signed in. So that means Brian

19 Caldwell. Brian is up, and Michelle Catalano

20 is on deck.

21 MR. CALDWELL: Thanks. I passed

22 around what I called talking points on this
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1 issue, and I hope you all have copies and you

2 can just kind of look at them as I'm going

3 through. I'm going to bang through them, so

4 hopefully I can finish in the four minutes.

5 My name is Brian Caldwell from

6 Hemlock Grove Farm in West Danby, New York. 

7 I've operated a certified organic apple

8 orchard in Central New York since 1988. It's

9 a part-time operation and my full-time job is

10 doing research on organic vegetable and grain

11 systems at Cornell University.

12 Antibiotics are naturally

13 occurring microbial products, similar in that

14 way to the toxins produced by BT, etcetera,

15 that are commonly used in organic production.

16 But the key issue is that they

17 have a vital role in human health care, and

18 though it appears that antibiotics on fruit at

19 harvest are minuscule, I believe there's a

20 risk that broad-scale spraying of antibiotics

21 over thousands of acres with selection

22 pressure for antibiotic resistance on exposed
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1 organisms, especially bacteria, as we heard

2 earlier today.

3 This could potentially increase

4 the chances of transference of antibiotic

5 resistance to human pathogens, and the results

6 of scientific studies on this so far seem to

7 be mixed.

8 When I've asked Northeast

9 consumers about antibiotics in apples, they

10 are unaware that they're allowed to be used,

11 and they are invariably opposed to it.

12 I believe that the continued use

13 of antibiotics in organic production is a real

14 threat to the integrity of the organic label. 

15 I want to point out that organic dairy

16 farmers, almost all of whom have transitioned

17 from conventional practices which relied

18 heavily on antibiotics, have given up that

19 practice. 

20 Okay. Fire blight is a

21 devastating disease, and I have seen some bad

22 outbreaks, and it does kill trees. It's
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1 really nasty. The Northeast pear industry has

2 virtually disappeared and moved to the West

3 Coast because of fire blight. The Northeast

4 has more potential for fire blight than dry

5 Western apple regions.

6 Nonetheless, fire blight has not

7 been a major concern among many organic apple

8 producers in the Northeast. In contrast to an

9 informal West Coast survey, in which large

10 numbers of growers said they would abandon

11 organic production with the loss of

12 antibiotics, and one that I did for Northeast

13 growers, 92 percent of the 12 respondents,

14 it's a small sample, said that it would have

15 little or no effect on their operations.

16 Most of these growers are small

17 scale, but over half of them are full-time

18 diversified farmers. Many, including myself,

19 have never sprayed antibiotics, and why is

20 this? Well, in general, we have far lower

21 reliance on highly susceptible or fire blight22 susceptible root stocks and varieties.
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1 We tend to use a lower fertility

2 regime. We don't push the young trees so

3 hard, and some growers use early season copper

4 sprays. Some use probiotic sprays during the

5 season, and some use Surround, mostly for

6 insect control, during bloom, and all these

7 may help.

8 I just a little aside here. I

9 think if I wanted to produce fire blight on my

10 farm, and I probably could, I would plant M-9

11 in high density plantings and fertilize them

12 heavily, and I think that would do the trick. 

13 But I don't do that.

14 Okay. So I think this is a tough

15 choice. Fire blight pressure is even higher

16 in the Southeast and the Midwest regions than

17 it is in the Pacific Northwest or the

18 Northeast. My orchard is a very small part19 time operation, and I don't pretend to speak

20 for larger operators. My investment is very

21 small.

22 Some larger growers have
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1 investments of hundreds of thousands of

2 dollars in their orchards, to millions that

3 are at risk from fire blight, and this is a

4 real fact.

5 So I support the centrist proposal

6 on this issue. I believe it gives growers

7 whose orchards are at risk time to adopt non8 antibiotic purchase to fire blight, and it

9 ensures consumers that there will be no

10 antibiotic use after a specific date. So

11 thanks very much.

12 CHAIRMAN STONE: Thank you, Brian. 

13 Francis.

14 MEMBER THICKE: Thank you, Brian. 

15 I have a question. If the deadline for

16 oxytocin -- oxytocin, I'm a dairy farmer --

17 oxytetracycline is extended to 2016, do you

18 think that in the Northeast they will actually

19 do the research and will be in a different

20 place than they are now, or will we be again

21 in the same place by 2016, do you think, in

22 the Northeast?
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1 MR. CALDWELL: Well, I don't think

2 there is the heavy research program in the

3 Northeast that Ken Johnson talked about here

4 in the Northwest. But I think, as he said, I

5 think the results will be transferable, at

6 least to some extent, and as I said, I just,

7 at least for a lot of the growers, it's not a

8 huge issue.

9 CHAIRMAN STONE: Jay.

10 MEMBER FELDMAN: Pass. I'm going

11 to pass.

12 MEMBER SONNABEND: Brian, the main

13 difference between the centrist proposal and

14 the proposal we put forward as the majority

15 position is an annotation concerning oversight

16 of certifiers, and a mandate to use more

17 alternative practices than what growers are

18 already trying. 

19 Could you explain why you think

20 that makes a difference, to have that as an

21 annotation versus our resolution, to encourage

22 what we think is being already done?
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1 MR. CALDWELL: Well, I guess I

2 would agree with Lynn, that it just puts it

3 out there for everybody to see in a very clear

4 way. If it's already being done, I don't see,

5 I guess, why anybody would object to it.

6 CHAIRMAN STONE: Thank you, Brian.

7 MR. CALDWELL: Thanks very much

8 for your great work.

9 CHAIRMAN STONE: Michelle Catalano

10 is at the podium, and we have Pam Coleman on

11 deck.

12 MS. CATALANO: Good afternoon. I

13 represent the Washington State Department of

14 Agriculture's Organic Advisory Board, advisors

15 to our State Organic Food Program. I have

16 served on the board for 13 years as the

17 consumer representative, and currently serve

18 as board chair.

19 The OAB represents stakeholders

20 from all aspects of the organic industry,

21 including producers, processors, handlers,

22 retailers and consumers. The OAB supports the
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1 Crops Subcommittee proposal to extend the

2 expiration date for oxytetracycline to October

3 21st, 2016.

4 Along with the rest of the organic

5 industry, the OAB supports a phase-out of

6 antibiotic usage in tree fruit production, and

7 agrees with the Subcommittee that as an

8 industry, we must commit to and prepare for

9 this phase-out, supporting current and new

10 research for alternatives.

11 The two years ending October 2014

12 has not been enough time for research trials

13 to find effective replacements. The OAB

14 disagrees with the arbitrary decision to

15 extend the use of this antibiotic in tree

16 fruit production until October 21st, 2014,

17 rather than to have followed the five year

18 sunset cycle, which would have allowed use of

19 these materials until October 2017.

20 In the case of fire blight,

21 conditions that promote the disease do not

22 exist every year, and so time is needed for
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1 researchers to test alternatives under natural

2 conditions.

3 We do, however, applaud the

4 researchers and growers that have been working

5 tirelessly to find alternatives, and strongly

6 believe the NOSB should honor their efforts

7 with this reasonable extension of the

8 expiration date.

9 Industry commitment to a phaseout

10 is evident in current research. It is well11 known that organic research is underfunded,

12 yet its importance cannot be understated. 

13 Given the potential for entire orchard blocks

14 to be lost to this disease, it is reasonable

15 to allow for the extension of current fire

16 blight management tools, while research for

17 commercially viable alternatives continue.

18 Consumers in our region, in

19 Washington State, enjoy an amazing variety of

20 local organic Washington-grown apples and

21 pears. Yet most do not understand the

22 challenges that growers face, nor do they
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1 fully comprehend the complexity of the

2 National Organic Program regulations.

3 The organic industry will continue

4 to grow only if there is growing consumer

5 demand. The OAB believes consumers need more

6 information about the realities that organic

7 farmers face, not bullet points that simplify

8 that reality.

9 While recent public discussion may

10 indicate that antibiotics are heavily used, in

11 truth use in tree fruit production consumes

12 less than one percent of antibiotics sold in

13 the U.S., as per recent Rodale Institute

14 information. 

15 WSDA's Organic Food Program and

16 other accredited certifying agencies ensure

17 growers are complying with current organic

18 standards, allowing oxytetracycline when other

19 controls are ineffective.

20 Growers often have to make the

21 choice of which disease to control, leaving

22 them without options during times of severe
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1 fire blight outbreak. That forces growers to

2 choose between devastating crop losses or

3 using non-approved materials and potentially

4 losing organic certification.

5 The OAB requests the NOSB allow

6 oxytetracycline to be allowed until October

7 21st, 2016. Given its use at bloom time only,

8 there is no evidence that oxytetracycline

9 leaves residue on post-harvested fruit in

10 amounts greater than EPA allowances.

11 The loss of oxytetracycline in

12 tree fruit production now, when research is

13 making positive strides, unnecessarily

14 jeopardizes the tree fruit industry and risks

15 potential reduction of domestic fruit supply.

16 The continued use of

17 oxytetracycline benefits stakeholders,

18 especially in Washington State, which produces

19 high volumes of organic tree fruit. We wish

20 to see organic acreage continue to increase in

21 our state, and for a diverse variety mix of

22 tree fruit to continue to be available to
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1 consumers here and across the country. Thank

2 you very much.

3 CHAIRMAN STONE: Thank you. Thank

4 you very much. Oh, I'm sorry. Harold. 

5 Ma'am, we have one more question.

6 MEMBER AUSTIN: No. You're okay,

7 Michelle. Just for the sake of full,

8 absolute, complete transparency, I do serve

9 with Michelle on the Washington State

10 Department of Ag Organic Advisory Board. 

11 CHAIRMAN STONE: All right, thanks

12 Harold. Thanks Pam or Michelle. Pam Coleman

13 is up, and Natalie Reitman-White is on deck.

14 MS. COLEMAN: Good afternoon. My

15 name is Pamela Coleman. I'm a policy analyst

16 for the Cornucopia Institute. I have a Ph.D.

17 in Plant Pathology, and post-doctoral research

18 experience on apple diseases. I'm happy to be

19 here to discuss a plant disease.

20 Currently, tetracycline and

21 streptomycin are allowed for fire blight

22 control, only until 2014. Please reject the
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1 petition for extension. These antibiotics are

2 not allowed for any other use in organic

3 agriculture, not for livestock, not for crops.

4 It's time for a uniform standard. 

5 No antibiotics. In the past few days, you

6 might have gotten the impression that research

7 on control of fire blight has just begun in

8 the past few years. Let me correct that

9 impression.

10 Research on fire blight was

11 published as early as the 1930's, and hundreds

12 of publications have been printed since then. 

13 In particular, a great deal of research was

14 done in the 70's, 80's and 90's. That

15 information is available in a farmer-friendly

16 format, as an extension publication that

17 explains how to predict disease outbreaks

18 based on temperature, and how to use cultural

19 controls.

20 My recent review of the current

21 research has convinced me that fire blight can

22 be managed on apples without the use of
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1 antibiotics. Many apple and pear growers

2 already succeed without antibiotics. 

3 According to a recent survey that we conducted

4 at Cornucopia, and you should have a copy of

5 this survey received in the mail, according to

6 that survey, 56 percent of organic apple

7 growers nationwide who responded said they do

8 not use antibiotics.

9 Only 24 percent of the growers,

10 apple growers, said they used tetracycline. 

11 Many growers have not used antibiotics for 10

12 or 15 years. So what are the alternatives? 

13 Growers can use cultural practices, resistant 

14 varieties, resistant root stocks, blossom

15 thinning, minimum nitrogen and orchard

16 sanitation.

17 If those don't work, growers can

18 use materials, copper sulfate, lime sulfur,

19 fish oils, biological controls. That's a

20 pretty good list. Of course, there is the

21 recent research done by Dr. Ken Johnson, using

22 blossom thinning followed by a biological
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1 control. 

2 In case you haven't watched the

3 webinar, he said "It provided an excellent

4 level of control. It was as effective as an

5 antibiotic, even on a susceptible apple

6 variety, Galas, and over three years of

7 testing."

8 Of course, that effectiveness of

9 that material depends on an integrated

10 approach. Orchardists must be proactive. 

11 They must monitor the orchard and take action

12 to prevent disease outbreaks. That's a basic

13 principle of organic disease management.

14 If orchardists wait until

15 bacterial populations are high, they'll be

16 reactive, and they'll need to spray

17 antibiotics. That's an input substitution

18 mentality, similar to conventional

19 agriculture.

20 Even before this research was

21 done, growers in Washington were growing

22 apples without antibiotics. I inspected many
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1 of them. They avoided antibiotics, because

2 they were exporting to Europe, where

3 antibiotics are prohibited on organics.

4 I assure you, they were exporting

5 Galas, Fujis and other popular varieties. I

6 want those apple varieties available to me

7 here in the U.S. without antibiotics. 

8 Consumers agree. More than -- consumers

9 agree. Thank you. Sorry.

10 (Laughter.)

11 CHAIRMAN STONE: Thank you, Pam. 

12 Question. Jay?

13 MEMBER FELDMAN: So it sounds like

14 you're saying that we may be getting a skewed

15 view of the necessity or essentiality of the

16 materials. What is the method, what was the

17 methodology for your survey?

18 MS. COLEMAN: Okay. We sent the

19 survey out to about 700 growers. We at

20 Cornucopia have a database, and we believe it

21 includes all the organic apple and pear

22 growers. We received replies from 72 apple
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1 growers and 32 pear growers. 

2 So I reported the apples, because

3 I felt like that was a pretty significant

4 number. I was a little surprised at how many

5 people responded that they don't use

6 antibiotics, because I was concerned that the

7 people who responded would primarily be people

8 who still wanted to use antibiotics.

9 We asked them whether they used

10 streptomycin, tetracycline or either, and we

11 asked them how a prohibition of antibiotics

12 would affect them, and we had different

13 categories. No effect, use more biologicals,

14 stopped growing organics, stopped farming and

15 so forth. Did you want more information on

16 that? Okay.

17 CHAIRMAN STONE: Nick.

18 MEMBER MARAVELL: Thank you, Pam,

19 for your presentation, and let's say for the

20 sake of argument we all agree, which I think

21 most of us do, that there are alternatives and

22 that there are many apple and pear producers
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1 who do not use tetracycline and who are

2 certified organic. 

3 I'd like to just focus on the ones

4 that do for a second, and say some of the

5 practices that we have heard from the previous

6 speakers and that you've alluded to, may not

7 be in use by those who are still relying on

8 tetracycline. 

9 Are you in effect saying that we

10 have enough time for them to make a successful

11 transition away from tetracycline, or do you

12 think that we -- we're admitting this is far

13 less than 100 percent of the producers. Or

14 are we saying that there is indeed a

15 percentage of the producers that are not going

16 to be able to comply with organics? 

17 I mean how are you viewing the

18 eventual outcome of your recommendation?

19 MS. COLEMAN: Okay. Can I just

20 talk about apple growers for now?

21 MEMBER MARAVELL: Sure, sure.

22 MS. COLEMAN: Because as Harold
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1 pointed out, we have some flexibility with the

2 pear growers. What I'm saying is that we as,

3 must require organic growers to use

4 preventative cultural controls, and what I've

5 seen in Washington State as an inspector is

6 that they're not using them.

7 They should have started using

8 them, and when I say "they," I don't mean all. 

9 I mean some, okay. Back in 1995, growers

10 should have been planting orchards with more

11 resistant root stocks. I understand people

12 will say they're not all resistant, but there

13 is a continuum. 

14 It's been well-known for many

15 years, and it's information is available in

16 extension publications, that indicate that

17 when you grow an apple tree on a highly

18 dwarfing root stock, to get a very small tree,

19 it's more susceptible. But when you grow that

20 same apple on a larger, standard root stock,

21 it's less susceptible.

22 If you look at the acreage that's
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1 been planted in Washington State recently,

2 more and more of them are in highly dwarfing

3 root stocks. They're planted very close

4 together, and those are conditions that

5 exacerbate the probability of disease.

6 Can people who have not used what

7 I call proactive, preventative controls, now

8 go back and find a material to use? Perhaps

9 not. 

10 CHAIRMAN STONE: All right. 

11 Waldo.

12 MEMBER FOSTER: He just called me

13 Waldo. That's why I'm laughing.

14 CHAIRMAN STONE: They all heard

15 it.

16 MEMBER FOSTER: Yeah, yeah. When

17 you sent the survey out, from whom did it

18 come? If I had gotten the survey, who would

19 I have gotten it from?

20 MS. COLEMAN: We sent it out

21 actually in several different formats. We

22 sent it out as an email from Cornucopia, and
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1 we also sent it out as a Doodle poll, and we

2 also sent it out on paper.

3 But it would have come from

4 Cornucopia, although the paper form had my

5 name on it, and some people who responded knew

6 me, because I knew some apple growers in

7 Washington.

8 CHAIRMAN STONE: Thanks ma'am. 

9 MS. COLEMAN: Okay. Thank you all

10 very much.

11 CHAIRMAN STONE: So Natalie

12 Reitman-White is up, and Diane Dempster on

13 deck.

14 MS. REITMAN-WHITE: Hello. I'm

15 Natalie Reitman-White from Organically Grown

16 Company. Founded 30 years ago, we are the

17 largest distributor of organic produce in the

18 Northwest, wholly owned by farmers and

19 employees.

20 Today, I'm also representing the

21 Organic Produce Wholesalers Coalition, a

22 national group comprised of ten wholesale
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1 distributors. Our combined annual sales in

2 2012 exceeded $550 million. This represents

3 the majority of wholesale sales of organic

4 produce in the U.S. We sell to grocers,

5 restaurants and other customers.

6 Our members include Albert's

7 Organics, Charlie's Produce, Co-Op Partners

8 Warehouse, Earl's Organic Produce, Eastern

9 Carolina Organics, Global Organic Specialty

10 Source, Goodness Greenness, Heath and Lejeune,

11 Veritable Vegetable and OGC. Many of our

12 businesses were early participants in the

13 organic community.

14 We'd like to underscore the

15 significance of the NOSB decision on

16 tetracycline to the marketplace of organic

17 produce, and propose a workable solution in

18 the best interest of all parties. Produce is

19 a cornerstone of every grocery. In the last

20 decade, we've seen organic consumption grow

21 tremendously.

22 Of that, apples and pears are a
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1 staple item. We conducted a survey of our

2 members in 2011. Collectively, the OPWC

3 purchased 40 million of organic apples and

4 pears. Of that, 66 percent of apple purchases

5 and 79 percent of pear purchases were of

6 varieties that are known to be susceptible to

7 fire blight.

8 In accordance with organic

9 principles, we support a phaseout of the use

10 of antibiotics in organic tree fruit

11 production. That said, we firmly acknowledge

12 that organic growers need field-tested,

13 commercially available methods for controlling

14 fire blight, because the disease can be so

15 devastating.

16 We are very glad to see promising

17 results coming out of research on non18 antibiotic control for fire blight. However,

19 we understand a few more critical years are

20 needed for a successful trade-wide transition

21 to these alternatives.

22 The OPWC is very concerned that
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1 the 2014 expiration date is being rushed ahead

2 of the pace of science and on the ground

3 commercial feasibility, and will result in

4 many growing dropping their organic

5 certification, in order to protect against the

6 risk of losing entire orchards.

7 Given the market dependence on

8 fire blight susceptible varieties, this

9 outcome would be devastating to the U.S.

10 organic produce trade, taking years to rebuild

11 the domestic tree fruit market. In the last

12 six months, individual OPWC members supported

13 the work of the National Organic Coalition, to

14 craft a proposal that would take into account

15 the needs and concerns of the entire organic

16 community.

17 The centrist proposal authored by

18 Lynn Coody puts forward a workable solution

19 that addresses farmers' need for more time to

20 implement alternative practices, while

21 addressing the concerns of consumers about the

22 allowance of organic or antibiotics in organic
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1 production.

2 In order to protect consumer

3 confidence in the organic brand, we believe

4 there needs to be a clear acknowledgment of

5 the health and environmental impacts of any

6 antibiotics used by the organic community,

7 together with a commitment to an absolute

8 expiration date, and short-term allowance for

9 use only when it has been documented by

10 growers that all other management practices

11 have been exhausted.

12 Therefore, the OPWC unanimously

13 supports the proposal for a short, limited use

14 extension, a concise annotation dealing with

15 the specific disease management hierarchy that

16 must be followed, an annotation dealing with

17 how oversight from certifiers and the NOP will

18 be carried out.

19 OPWC members all believe it should

20 be within a 2016 or 2017 time frame. We

21 appreciate the opportunity to comment on the

22 issue. 
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1 CHAIRMAN STONE: Thank you. Jay.

2 MEMBER FELDMAN: Natalie, thank

3 you. I'm going to read this too and ask if

4 you know where this came from. 

5 "The Board expects members of the

6 industry to collaborate and coordinate efforts

7 in preparing for the eventual removal of this

8 material from the National List, specifically

9 optimizing the use of resistant root stocks

10 and cultivars, preventive management methods

11 and use of alternative allowed biological and

12 chemical controls whenever warranted."

13 Has that happened in the last two

14 years? I don't want to put you on the spot,

15 but do you think those kinds of activities

16 have happened in the last two years? That was

17 the 2011 annotation that we adopted when we --

18 MS. REITMAN-WHITE: I think

19 efforts have been made. I think that what I

20 understand is that the research is on the cusp

21 of being commercially ready to go, but it's

22 not there yet. We need a little more time,
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1 and that time is a critical couple more years

2 to make that happen. So that's our position.

3 MEMBER FELDMAN: Yeah, thanks.

4 CHAIRMAN STONE: Harold.

5 MS. REITMAN-WHITE: And let me

6 say, with that, I also think we really need to

7 clearly acknowledge as an organic community

8 that we are concerned about the health and

9 environmental effects, and we are committed to

10 a total phaseout. I think it's important for

11 restoring consumer confidence and trust in

12 organics.

13 MEMBER AUSTIN: With your

14 stakeholder group with our proposal, how do

15 you feel that will impact your stakeholders,

16 and the interactions with your customers and

17 the consumers, if we were to move this forward

18 to 2016, versus let it expire in 2016? Do you

19 think they would be willing to accept that,

20 knowing that the tree fruit industry is trying

21 their best to move away from that? Versus the

22 alternative of its ending in 2014, and the
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1 impact that that might have.

2 MS. REITMAN-WHITE: Sure. Well,

3 speaking for Organically Grown Company, I

4 think we feel it's critically important to do

5 an annotation, not that those practices aren't

6 already being followed. But we think it's

7 important to put that out there, to reassure

8 consumers and establish trust.

9 We also think we need to get

10 honest about recognizing that any antibiotic

11 use in the food system is, you know, a health

12 and environmental impact, and that we are

13 committed to doing away with it over time. We

14 think that needs to be publicly stated.

15 CHAIRMAN STONE: Thank you,

16 Natalie. Diane Dempster is up and Richard

17 Carr. Sorry for the confusion earlier,

18 Richard. Richard Carr is on deck.

19 MS. DEMPSTER: Hi. I'm here

20 representing Charlie's Produce. I am the

21 manager of Farmer's Own Organic Produce and

22 the organic specialist at Charlie's Produce. 
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1 I've been working there for 23 years, and I'm

2 the current president of Tilth Producers of

3 Washington. I served on the WSDA Organic

4 Advisory Board for nine years, and helped

5 write, draft some of the handling standards

6 for the State.

7 Charlie's Produce is the largest

8 independent wholesale produce company in the

9 Northwest, and one of the first wholesalers to

10 be certified organic by WSDA. We have five

11 warehouses and provide a full line of organic

12 produce to retail and food service customers

13 in Washington, Oregon, Idaho, Montana, Alaska

14 and Canada.

15 We buy locally when it is

16 available from all over the world -- buy

17 locally when it's available but from all over

18 the world when it is not. We commit to local

19 growers, and they can plant knowing that they

20 have a home for their produce.

21 Last year, we bought over 72,000

22 cases of organic apples, and 21,000 cases of
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1 organic pears, which was 8-1/2 percent of our

2 total organic sales. Sales of organic produce

3 have increased 69 percent in the last ten

4 years. Our customers' sales of organics have

5 also increased.

6 Now, most of our retail and food

7 service customers buy some organic produce. 

8 Sales have increased because the supply is

9 stable. If there was not a consistent supply

10 of quality, organic produce, stores would not

11 carry it and growers would not have a good

12 market.

13 Without a supply of organic pears

14 and apples, farmers would suffer and so would

15 the retail and the whole industry. We support

16 allowing the restricted use of tetracycline to

17 control fire blight in tree fruit production

18 until 2017. It was allowed as a last resort

19 in private certification standards and in the

20 first NOP rules, and it's not the time to ban

21 it now.

22 Research for products used by
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1 conventional growers is done by chemical

2 companies. Research for organic treatments

3 happens slowly, as money is available. Just

4 as growing a tree takes time, so does

5 research. Researchers are close to finding

6 solutions, and we need three more years to

7 make these solutions viable.

8 Since the blight is so deadly,

9 growers would not have planted pears and

10 apples if they did not have tetracycline as a

11 backup. Growers who lose an orchard or a tree

12 to fire blight can no longer afford to grow

13 organically. This would devastate a thriving

14 industry.

15 The recent public concern about

16 the use of tetracycline is based on fear, not

17 facts. People are scared because it's an

18 antibiotic, not because they know the full

19 effect it has on their bodies or the

20 environment. 

21 The Board makes decisions about

22 very complicated issues. The public and
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1 growers rely on you to analyze the facts, have

2 a full understanding of all the issues, and

3 make sound decisions based on good science. 

4 I trust that you will do that in this manner,

5 and allow the restricted use of antibiotics in

6 tree fruit production until 2017. Thank you.

7 CHAIRMAN STONE: Thank you. 

8 Question. Jay.

9 MEMBER FELDMAN: Thank you for

10 your comments. Do you know or have you

11 surveyed the growers that you buy from, and do

12 you know what percentage of them use

13 tetracycline?

14 MS. DEMPSTER: I have not surveyed

15 them, no. We buy from -- a lot of the growers

16 that we buy from are part of packing sheds who

17 would be pooled, so I don't know many of the

18 individual growers.

19 MEMBER FELDMAN: But you don't

20 know what percentage of those growers are

21 actually using tetracycline?

22 MS. DEMPSTER: I do not. I
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1 understand that it's only as needed for a very

2 limited use, from the growers that I've talked

3 to.

4 CHAIRMAN STONE: Harold.

5 MEMBER AUSTIN: Diane, thanks for

6 all of your hard work in the organic arena. 

7 It's appreciated. The customers that you're

8 selling the produce that you're purchasing,

9 have you had any talks with any of them,

10 regarding the current antibiotic issue and the

11 information that's out and about, and how do

12 you answer their concerns, if you have had

13 those conversations?

14 MS. DEMPSTER: I have not had any

15 conversations with customers, but I think that

16 they would trust that what has been happening

17 with the use of tetracycline and antibiotics 

18 being used only as a last resort effort, would

19 be the same as any restricted use product in

20 the organic, that's used in organic

21 production.

22 So I don't think that there's any
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1 difference in this use as -- and most

2 consumers would not, they don't know enough

3 about the organic rule to understand all the

4 ins and outs of it.

5 I personally think that if I went

6 to all the retail customers that we sell to,

7 to their produce buyers, they would be very

8 interested in having a consistent supply of

9 organic apples and pears, more than how much

10 they would worry about minute amounts of

11 antibiotics used on the trees before harvest,

12 before during blossom.

13 CHAIRMAN STONE: Thank you, Diane.

14 MS. DEMPSTER: Thank you.

15 CHAIRMAN STONE: Richard Carr is

16 at the podium and Jeff Falen, Fallon is on

17 deck.

18 MR. CARR: Hello. My name is

19 Richard Carr, and I am the technical

20 specialist at Oregon Tilth. I very much

21 appreciate this opportunity to stand before

22 you today, and not by Internet, okay. Oregon
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1 Tilth certifies over 2,500 acres of apples and

2 pears, mainly in the Pacific Northwest.

3 Oxytetracycline is a crucial tool

4 of last resort for organic orchards. If

5 allowed to expire without alternative fire

6 blight controls, substantial numbers of

7 orchards will reduce organic acreage in apple

8 and pear production, or surrender their

9 certification altogether.

10 Oregon Tilth encourages this Board

11 to objectively measure the potential risks and

12 likely costs that will incur if

13 oxytetracycline is not extended. The reality

14 is crops, organic or otherwise, are grown in

15 a shared world. Regardless of consumer

16 perceptions, organic does not exist outside of

17 our agricultural commons.

18 Everywhere is downstream, and

19 nowhere is this understanding more pertinent

20 than the risks associated with antibiotic

21 resistance. Tetracycline itself has been used

22 in crop production since the 1950's. It is
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1 used to control fire blight in both apples and

2 in conventional orchards, or both organic and

3 conventional orchards. 

4 If farmers are unable to protect

5 their trees from fire blight, they will likely

6 forego organic certification, and use

7 antibiotics outside of organic practices. 

8 Removing this tool from organic farmers will

9 not diminish the cumulative use of antibiotics

10 in tree fruit. 

11 Instead, the inertia we are now

12 seeing in the development of effective non13 antibiotic controls for fire blight will lose

14 its driving incentive. Research will

15 continue, but without the urgency and

16 creativity that necessitates innovation.

17 Antibiotics will be removed from

18 the National List. It is only a question of

19 when. Oregon Tilth urges the National Organic

20 Standards Board to consider a sunset date that

21 is based on realistic expectations, that will

22 allow research to draw significant
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1 conclusions. Commercial availability must

2 also be considered in this time line.

3 Further, OTCO does not support the

4 inclusion of annotations that reiterate

5 existing standards. We encourage the NOSB to

6 avoid amending 205.206 or the National List

7 with redundant or prescriptive annotations.

8 We do know this is going to be a

9 difficult vote. It will have consequences,

10 both real and perceived. In fulfilling your

11 mandate, we urge the Board to consider which

12 choice will bring us closer to a non13 antibiotic solution to controlling fire

14 blight.

15 We trust that you will make the

16 very best decision possible for the long-term

17 well being of farmers, consumers and the

18 organic industry as a whole. Thank you.

19 CHAIRMAN STONE: Thank you. 

20 Questions? Harold.

21 MEMBER AUSTIN: Thank you. In

22 your involvement in the organic arena and the
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1 changes that we've seen take place over the

2 last, oh wow, let's say the last five, six,

3 seven years, what impact have you seen in

4 farming practices, as we've seen the acreages

5 and the number of certified operations grow,

6 and the volume of the acreage of those

7 certified operations expand?

8 What impact have you seen that

9 have of any on, those that have maybe split

10 application, you know, split production,

11 organic and conventional, and possibly on

12 their conventional neighbors?

13 MR. CARR: So could you -- so your

14 question, you're asking what is the impact of

15 the growth of the industry?

16 MEMBER AUSTIN: No, the trends,

17 the practices. You know, mating disruption is

18 an example. We farm organic, we farm

19 conventional. We use mating disruption now on

20 everything that we do.

21 MR. CARR: Right.

22 MEMBER AUSTIN: That type of an
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1 impact from moving from the organic to the

2 split production type of programs, or out to

3 conventional farmers. In your day-to-day

4 operations, what have you seen is that impact?

5 I'm really looking at if we were

6 to allow the extension of the expiration date,

7 to allow the research for the organic

8 replacements and materials to continue to move

9 forward, would not that, if you've seen these,

10 wouldn't that have an impact also on the

11 conventional production?

12 MR. CARR: Yeah. No, I think very

13 much so. I think that there's a really good

14 opportunity here for organic, for solutions in

15 organics to cross the divide in the other

16 direction, to where we're taking those

17 solutions and being leaders in the entire tree

18 fruit industry.

19 So that's what I would expect, and

20 I think it's happened, cherries. There was

21 some -- David Granatstein had spoke to that

22 just the other day. So but I think that's a
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1 real possibility. 

2 CHAIRMAN STONE: Thank you,

3 Richard. We're moving down. Bill Denevan. 

4 You're up at the podium, and David Granatstein

5 on deck.

6 MR. DENEVAN: Hello. My name's

7 Bill Denevan, and let me tell you a little bit

8 about myself. I'm a member of the Board of

9 Directors of the California Apple Commission. 

10 From 1996 to 2006, I grew organic Bartletts

11 and apples on 120 organic acres in the Santa

12 Cruz-Watsonville area of California.

13 The companies that I had were

14 Denevan Apple and Happy Valley Farm. I have

15 35 years of experience working with growers,

16 assessing their crops and giving advice in the

17 U.S. and Chile. I've worked for almost 20

18 years as a grower rep with CF Fresh and

19 VivaTerra. 

20 My job has brought me in contact

21 with just about every region in the West where

22 fire blight is a problem. As an organic
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1 grower, I know quite a bit about blight. What

2 I did was manage the vigor, follow the

3 temperatures and moisture models, spray

4 copper, cut infections, burn infected wood and

5 pray.

6 I've fought it year after year. A

7 few times, I had to cut out nearly every

8 fruiting branch, leaving only five or six span

9 liters. It took years to get production back

10 up to that time. Every year, I had to do some

11 amount of blight cutting and burning just to

12 save the trees. My apples are much easier to

13 handle.

14 During my travels, I've seen

15 nearly 1,000 acres of organic and conventional

16 apples and pears bulldozed due to blight

17 attacks.

18 In many cases, the affected

19 growers went bankrupt. Eight years ago in

20 Tonaske I saw an orchard of 150 acres of

21 Bartlett, Conference, Comice and Anjou

22 completely wiped out, because the grower
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1 wanted to forego the needed antibiotic

2 treatment so he could sell his fruit to

3 Europe.

4 Ten years ago in Cuyama Valley, I

5 watched bulldozers take out 400 acres of

6 beautiful five year old pink, Pink Ladies, due

7 to a perfect storm of bad weather and

8 ineffective blight program. A couple of years

9 earlier than that at Pioneer Ranch, I watched

10 20 acres of 12 year-old Bosc get pushed out.

11 Five years ago, my 2,000 Bartlett

12 trees were abandoned. Today, they're in

13 piles, being burned as we speak. They did not

14 die directly from blight, but the treatment

15 plans I needed to do effective blight control

16 were just too expensive to keep the orchard

17 going.

18 Almost all the apple and pear

19 growers that I deal with -- almost all apple

20 and pear growers can do pretty well with heat,

21 bug, fungus, floods and market swings. But

22 dealing with blight infections is a special
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1 problem.

2 We all know that in a bad blight

3 year, you can easily destroy your life's

4 investment, and you have to find a new way to

5 provide for your family. I've been following

6 the recent research into organic blight

7 control pretty close. It looks promising for

8 the future, but the devil's in the details.

9 Right now, we're in bloom in

10 California. Growers Advisors, the California

11 Apple Commission, the Pear Advisory Board and

12 manufacturers of control products are

13 conducting trials. We need to see how

14 effective these new materials will perform in

15 our local microclimates before adopting new

16 practices.

17 What regimen might be effective in

18 Washington and Oregon might not work out so

19 well in California. We have less chill hours,

20 a more uneven bloom period, always more

21 moisture, and oftentimes more heat issues to

22 deal with.
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1 Getting new materials and

2 protocols figured out is going to take more

3 time. Approving material with California

4 Department of Pest Regulation takes much

5 longer than other states. There is no doubt

6 growers in my state will need more than four

7 years to get a product tested, approved and

8 manufactured in sufficient quantity to supply

9 growers' needs.

10 Most, if not all, of organic

11 growers believe in treading lightly on the

12 planet, and improving the environment they

13 live in. But they are also rational business

14 people who have to feed their families. 

15 It's not the growers' fault that

16 they have not gotten a new tool to fight their

17 blight. Growers don't make the new materials. 

18 Manufacturers, researchers and regulators do

19 this work. Growers have been working in good

20 faith with these people. 

21 Please give all of us a realistic

22 chance to succeed. We need four more years,
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1 not two. Anyway, any questions?

2 CHAIRMAN STONE: Thank you, Bill. 

3 Question, John?

4 MEMBER FOSTER: So Bill, in full

5 disclosure, Bill taught me most of what I know

6 about apple production in the Santa Cruz area

7 a long, long time ago. It's really good to

8 see you. My question is how -- so when you

9 say we need four more years, not two, tell me

10 more about it? 

11 MR. DENEVAN: Well, right now --

12 MEMBER FOSTER: Like in what ways

13 would four be adequate but two's not?

14 MR. DENEVAN: Well, right now we

15 have -- I have a couple of growers. We're in

16 bloom right now, and they're using the Blossom

17 Protect, and it seems like a pretty good job. 

18 But after bloom, we're concerned about having

19 to use copper. 

20 Now in the Northwest, they have a

21 lot less -- it's a desert, and they have a lot

22 less rain. But we worry about russet, and we
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1 can really destroy the fruit by putting russet

2 on it. Nobody will buy it, and being in a

3 coastal area where I am, we really can have a

4 lot of russet problems, especially on pears.

5 Now apples, I'm a little -- I

6 think it's a little bit less problematic. But

7 pears, there's no way that I could see that

8 we've developed a protocol that's going to

9 work.

10 We need more time to see what's --

11 I think there's about, oh about maybe a 1,000

12 acres in California that are being checked

13 with Blossom Protect at the most. But there's

14 a lot more than that that have apples and pear

15 growers, and especially pear growers. They

16 need to check it out.

17 So anyway, that's -- I think we

18 just need more studies and more results.

19 CHAIRMAN STONE: Thank you, Bill. 

20 Thank you for taking the time to be here. 

21 David Granatstein is at the podium, and John -

22 - I'm sorry, Carmela. Bill. Okay yeah, go
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1 ahead.

2 MEMBER BECK: Hello? Bill. 

3 Sorry. So I think you kind of touched on

4 this, but I might have missed it. But could

5 you give some more examples about the

6 conditions in California that affect the fire

7 blight, and the need for control?

8 MR. DENEVAN: Well, one thing that

9 I stated in my talk was that we have, we don't

10 have the adequate winter chill a lot of times. 

11 So we'll have a bloom that's scattered. So

12 the bloom period goes on for a longer period

13 of time.

14 It's harder to get the model right

15 when you're under attack, because when the

16 bloom is out there, that's when the blight is

17 coming into the flowers. So if you have a

18 flowering period longer, you have a lot more

19 chance of getting blight.

20 And then we also have more

21 moisture, you know. We're not a desert in

22 California. Even our driest areas have more
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1 moisture than the desert areas of the

2 Northwest. So this contributes to more of a

3 bad blight situation.

4 So we have, I can think of at

5 least five or six definitive climate

6 situations that need different treatment. So

7 you know, we don't have experiments going on

8 in those areas. We need to have all of the

9 areas covered, and we need to have more

10 product available for experimenting with.

11 We don't have this copper that we

12 hear about, that doesn't russet. I mean we've

13 seen nothing but russet from copper. So we

14 want to try that and see if it works, you

15 know, after we do the Blossom Protect. This

16 is what people are saying we need to use.

17 So you know, I've seen it in both

18 apples and pears this year already. We're

19 cutting it out and it's quite a problem right

20 now, as we speak.

21 CHAIRMAN STONE: Thank you, Bill. 

22 David Granatstein to the podium, and John Hyer
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1 on deck.

2 DR. GRANATSTEIN: Okay. You

3 should get my presentation here in a moment. 

4 My name is David Granatstein. I'm with

5 Washington State University in Wenatchee,

6 Washington. I'm the co-chair of the Organic

7 Tree Fruit Work Group that was requested by

8 the Board at the April 2011 meeting in

9 Seattle.

10 My comments represent my views as

11 someone who works extensively with organic

12 orchardists here in the Pacific Northwest, but

13 those views do not necessarily represent all

14 Work Group members. I want to make that

15 clear.

16 As shown in this time table --

17 which is the next slide, please -- research

18 into the fire blight disease and biological

19 controls has been occurring for many, many

20 years. The industry and growers have been

21 exploring these alternatives, but there's

22 really been a lack of success until recently.
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1 So it's not a lack of effort; it's

2 been a lack of success. And that's what we

3 are just on the edge of, I believe,

4 particularly with the OREI project and many

5 other things we heard about earlier today.

6 Next slide, please. I fully

7 understand the concern about the risk of

8 antibiotic resistance in human pathogens from

9 agricultural use of antibiotics. However, all

10 uses and materials do not appear to be the

11 same. 

12 In this slide, Dr. Jeff Ullman,

13 University of Florida, has recently published

14 some research looking at the environmental

15 fate of pharmaceuticals, and he shows in this

16 graph that tetracycline, which is in the lower

17 right corner, becomes absorbed to the soil

18 within about 24 hours, where it is no longer

19 biologically active.

20 The paper states, and I quote,

21 "Thus, residual antibiotics in soil do not

22 necessarily exert a selective pressure, and
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1 the degree to which the pharmaceutical remains

2 bioactive depends on the antibiotic. Efforts

3 to control antibiotic contamination would be

4 better directed towards compounds that retain

5 biological activity in soils," and

6 tetracycline is not one of them.

7 Next slide, please. Statements

8 that all organic apples and pears have

9 residues of oxytetracycline and streptomycin 

10 are simply not true, since only on average ten

11 percent of U.S. apple acres are treated each

12 year with this material, and few acres are

13 treated with both materials. So that's just

14 not correct.

15 Data on measurable residue levels

16 of oxytetracycline on fruit are scarce. We've

17 heard about the EPA data. Those results had

18 residues less than the limit of quantification

19 on most of the fruit.

20 But remember, in that study, no

21 one's mentioned this yet, these materials were

22 applied between 49 and 61 days pre-harvest. 
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1 The set pre-harvest interval is 60 days. So

2 they were pushing the limit. They were

3 applied at rates of .5 half label rate to 11

4 times label rate. So that study is not

5 representative of what's going on out there in

6 the world.

7 Next slide, please. So to try to

8 help with this, I coordinated a round of

9 residue testing last fall, to see whether

10 trees treated during bloom, which is the most

11 common scenario in this region, whether those

12 fruit would be free of residues at harvest,

13 due to the absence of fruit at treatment,

14 we're treating blossoms, the degradation of

15 oxytetracycline during the five month growing

16 season, we've heard about that, and the lack

17 of mobility of oxytetracycline into the plant 

18 where it might move around and come back into

19 the fruit.

20 Using the biggest current

21 analytical method, the laboratory found no

22 detectable residues on any of the samples --
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1 I think you need to hit -- yeah, there we go. 

2 Thank you.

3 On any of the samples from seven

4 different orchards in Washington State, that

5 were treated from one to five times during

6 bloom. And actually one orchard was treated

7 during mid-summer because there was a major

8 hailstorm that incited fire blight.

9 So zero residues. That's a real

10 small set of data points, but it's something

11 I think we can start to understand, what is

12 really going on out there with this type of

13 use.

14 Next, please. In this chart, I

15 have outlined the key elements of fire blight

16 control and their status at different decision

17 points the Board has taken.

18 For me, it's hard to see that

19 suitable alternatives were available when the

20 2008 and 2011 decisions were made, and how

21 expiration dates were chosen. Thank you.

22 CHAIRMAN STONE: Thank you, David. 
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1 Questions? Nick. You're still up.

2 MEMBER MARAVELL: Dr. Granatstein,

3 it's a pleasure to have you at the podium

4 again.

5 DR. GRANATSTEIN: Thank you.

6 MEMBER MARAVELL: You were at our

7 Seattle meeting. When we recommended an

8 extension to 2014, did you give us any

9 indication that that was sufficient time for

10 the research to, at that point, get funded,

11 let alone get conducted?

12 Was there any expectation that you

13 gave us that there would be adequate research

14 to provide alternative materials within that

15 time line?

16 DR. GRANATSTEIN: No. That is why

17 the petition was refiled immediately, because

18 we felt that the 2014 date was not related to

19 progress in the research and the availability

20 of information to the growers.

21 We were told by the NOP that the

22 only recourse or question that decision was a
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1 new petition. That's the only reason we are

2 where we are today.

3 MEMBER MARAVELL: Was it your

4 understanding that we on the Board were

5 looking for positive movement on the part of

6 the industry and the research community, and

7 that we were going to use our best auspices to

8 encourage funding for your efforts, and that

9 was the reason for the 2014 extension?

10 DR. GRANATSTEIN: Well, my

11 understanding is it was a political compromise

12 date. That's what I understood from that

13 meeting.

14 MEMBER MARAVELL: Okay.

15 DR. GRANATSTEIN: But that you

16 were expecting the Tree Fruit Work Group to be

17 formed, to keep you informed of what was

18 happening in the industry. But without a

19 petition, I was told that there would be no

20 action to reexamine the date, and that's why

21 the petition came forward.

22 MEMBER MARAVELL: Can you tell us,
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1 in your opinion, what would happen in 2015 and

2 2016 in a little bit of detail, if we were to

3 extend this date, and why that would be

4 important from your perspective?

5 DR. GRANATSTEIN: Well, I consider

6 the OREI research project on organic fire

7 blight control to be pretty central. It's

8 really the first project of its kind that's

9 specifically looking at non-antibiotic control

10 in organic systems. That's a landmark study.

11 It won't be completed until 2015. 

12 It will take some time for them to analyze,

13 write up the data. They'll typically want to

14 publish journal articles first out of that

15 sort of work, and then extension materials

16 normally flow from that. That's the very

17 typical sequence.

18 If you publish extension materials

19 first, the journals often will not publish

20 your results. So the key in many ways is

21 getting this into vetted, acceptable extension

22 educational formats for the growers to use,
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1 and it does take additional time, once the

2 research is completed, to do that.

3 MEMBER MARAVELL: Is the Previsto

4 product part of your research experiments?

5 DR. GRANATSTEIN: It is not part

6 of mine, because I'm not doing the research. 

7 But it is part of the folks on the ground

8 doing it, yes. Yes, they've already been

9 testing it, but it is not registered. That's

10 obviously -- it can't be used by the growers.

11 CHAIRMAN STONE: Tracy.

12 MEMBER FAVRE: Hi, thanks for your

13 information. Can you elaborate a little bit

14 about the difference in application between

15 the research that was cited in the EPA report

16 and the research difference between what you

17 just did with the residue testing?

18 DR. GRANATSTEIN: The testing I

19 did represents fruit that were treated at

20 bloom, except for the one orchard, where I

21 said there was a mid-summer application.

22 So it was at blossom time, which
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1 is the typical application, and then at

2 harvest we got the fruit samples, put them,

3 plastic bags, chain of custody to the lab, and

4 they were tested later in the fall, after

5 harvest.

6 The EPA study was done at a number

7 of locations around the country. As I say,

8 they had a range of rates, because they were

9 trying to establish a label rate at that time. 

10 So they went from half label to about 11 times

11 label rates. So very, very high application

12 rates, and they were putting those

13 applications on between 49 and 61 days before

14 harvest.

15 So when the growers are spraying

16 at bloom, it may be something like 150 days

17 before harvest. So quite a big difference in

18 time frame. And at the time it was applied in

19 the EPA study, you had fruit on the tree. So

20 you had a fruit surface on which the residue

21 would land and potentially persist.

22 At bloom, theoretically, and
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1 that's what I was curious about, there's no

2 fruit. There's a blossom that falls off the

3 tree. There should be -- and if there's no

4 translocation in the plant, there should be no

5 residue left on a fruit that begins to develop

6 at that point.

7 MEMBER FAVRE: Just as a follow-up

8 point of clarity or clarification. So the EPA

9 study, they applied up to 11 times, which from

10 everything we've heard --

11 DR. GRANATSTEIN: Eleven times the

12 rate. I don't know if it was 11 applications

13 or just the total amount. It was 11 times

14 what was being proposed as the label rate.

15 MEMBER FAVRE: But typically much

16 closer to harvest time --

17 DR. GRANATSTEIN: And closer than

18 the legal limit even. They went past the

19 normal pre-harvest interval, just to kind of

20 push the system and see what would happen.

21 MEMBER FAVRE: Okay, and so was

22 there any direct correlation between the
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1 application rates and the incidence or the

2 percentage of residue?

3 DR. GRANATSTEIN: No, there was no

4 dose-dependent effect, which you would have

5 expected with that spread of application

6 rates. But the data were just very scattered

7 and not very many positive detects.

8 MEMBER FAVRE: So we didn't see

9 the percent residue increase with the percent

10 application?

11 DR. GRANATSTEIN: That's correct.

12 MEMBER FAVRE: So there was no

13 direct correlation between them?

14 DR. GRANATSTEIN: Right.

15 MEMBER FAVRE: Okay, thank you.

16 CHAIRMAN STONE: Jay.

17 MEMBER FELDMAN: Are you familiar

18 with the way EPA sets tolerances? Have you

19 reviewed tolerance review documents?

20 DR. GRANATSTEIN: No.

21 MEMBER FELDMAN: Okay. Do you

22 think --
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1 DR. GRANATSTEIN: That's outside

2 of my expertise.

3 MEMBER FELDMAN: Do you think a

4 registrant of a pesticide or an antibiotic

5 would seek a tolerance level from the EPA, if

6 they could use their product and generate a

7 zero tolerance or zero residue, and then seek

8 to market it?

9 These are tests that are done,

10 field studies that are done. You keep

11 referring to it as an EPA study. These are

12 field studies that are done by the

13 manufacturer.

14 DR. GRANATSTEIN: Correct.

15 MEMBER FELDMAN: They're submitted

16 to EPA. Believe me, those manufacturers are

17 trying to show a zero tolerance or zero

18 residue so they can market their product with

19 an exemption from tolerance.

20 The reason they can't get a zero

21 tolerance is because there are residues that

22 are showing up in the finished food product,
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1 and if they were to take a zero tolerance and

2 not the tolerance above limits of detection

3 that they have -- even though they are

4 variable; no one's questioning that they're

5 not variable.

6 If they were not to take that

7 residue tolerance, the one you're criticizing,

8 their products would be violative. They would

9 be in violation of the law, and they would be

10 pulled off the shelves. So instead of doing

11 that, because of the variability in tolerance

12 that exists, it's not a flat line, you always

13 see variability.

14 Because of that variability, they

15 take the tolerance and ensure that when

16 growers use their products, that they will not

17 be pulled off the shelf. So you can always

18 show with any pesticide, even in conventional

19 crop production, that you go from below levels

20 of detection up to above levels of detection,

21 and you've got to go with the level that is

22 possible.
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1 Maybe infrequent, maybe frequent. 

2 We don't know. But it's there, and it's

3 found, and you know, this is not a study. 

4 This is a tolerance-setting protocol that is

5 used by EPA.

6 DR. GRANATSTEIN: Okay. Well, my

7 goal is to say what happens when you do use a

8 normal use pattern? Do we find residues on

9 the fruit, because that appears to be a lot of

10 the questions we've had over the last two

11 days.

12 MEMBER FELDMAN: But you're not

13 familiar with the tolerance-setting process,

14 so you didn't use the EPA protocol that's used

15 for all pesticide use in the U.S. So I

16 appreciate the work you're doing. I think it

17 might be something you should bring to EPA

18 perhaps at some point.

19 But for purposes of our relying on

20 scientific data that is useable for purposes

21 of finding the normalized rate of residuals

22 that are found, we can't go off of one study
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1 like this, unfortunately. But I appreciate

2 your work.

3 DR. GRANATSTEIN: Well, then

4 that's all it is. It's a single probing at

5 this issue, because no one else has delivered

6 anything, other than the EPA report, which

7 contains data from other studies.

8 MEMBER FELDMAN: Right, and that's

9 all we got. Sorry, thanks.

10 CHAIRMAN STONE: Jean.

11 MEMBER RICHARDSON: David, on a

12 slightly different tack, from your experience,

13 you know, the Canadians can't use antibiotics

14 in their organic pear and apple production. 

15 What are the materials that they're using

16 right now, do you know? And how effective are

17 they?

18 DR. GRANATSTEIN: I don't know

19 that. I'm not familiar with the Canadian

20 situation for fire blight.

21 CHAIRMAN STONE: Harold, I'll let

22 you wrap this up.
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1 MEMBER AUSTIN: David, thanks for

2 your presentation. I think this is probably

3 where we'll agree to disagree a little bit

4 amongst ourselves on the Board. I think the

5 study and the time and energy that you put

6 forth to go out and get those samples and test

7 for those residues really does have benefit,

8 because it does show, under normal testing

9 protocol, that there was zero detect on the

10 seven samples that you turned to the lab,

11 ranging from one application to five

12 applications.

13 My question to you is the one

14 sample that you talked about that was made to

15 fruit that had been hailed on, typically,

16 could you describe to the Board typically what

17 a hailed on piece of fruit would look like,

18 and wouldn't that have a tendency to show a

19 higher percentage of residue possibly because

20 of the imperfections that are created by the

21 hail?

22 DR. GRANATSTEIN: Hm. Well,
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1 hailed fruit is, depending on the severity of

2 the storm and where it sits on the trees, is

3 just pockmarked from the hailstones, depending

4 on the age of the fruit when the storm occurs. 

5 Sometimes the hail creates wounds that break

6 the skin, and sometimes it doesn't.

7 MEMBER AUSTIN: Yeah. That's one

8 of -- I guess I should have asked that

9 question before I made that statement. Did

10 the hailed on fruit that you had, were there

11 any perforations in the skin of the fruit

12 itself?

13 DR. GRANATSTEIN: I don't believe

14 so. No. I don't remember it being as really

15 horrible looking hail fruit that they brought

16 me. So they probably tried to get some of

17 the better fruit from that orchard as a

18 sample, yeah. Okay. Thank you very much.

19 CHAIRMAN STONE: Thank you for

20 your work and being here today. John Hyer to

21 the podium, and Patty Lovera on deck.

22 MR. HYER: Thank you for allowing
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1 me this time to comment. I am an organic

2 farmer, being farming organically for 16

3 years. In addition, I sit on the Washington

4 State Organic Advisory Board.

5 I am in favor of extending the use

6 of tetracycline to the 2016 date. I have

7 absolutely no interest in orchards, apples,

8 pears. I am a vegetable farmer, vegetable and

9 small grains, and I want to talk to some of

10 the issues that were brought up to shorten the

11 date.

12 One was this variety. You can

13 switch variety at will. My specialty is

14 potatoes. I've grown six different varieties

15 in ten years. Last year, my major buyer came

16 to me and said if you grow that variety again,

17 we will not purchase from you. So when you

18 say it's easy to switch variety, it's not easy

19 to switch variety, especially for an

20 orchardist. The market wants what the market

21 wants, and we need to find a way to produce

22 that acceptably.
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1 Root stock. I was going to bring

2 a friend with me today, but he had to work. 

3 He's a tree salesman for one of the largest

4 nurseries in the Pacific Northwest selling

5 trees. And I asked him about this resistant

6 root stock. He says if you want resistant

7 root stock and you ordered it today, I might

8 get it to you by 2017. So, yeah, they're

9 working on these things, but the time frame is

10 not where we need it to be yet.

11 There's also some discussion that

12 it's only the large growers who are concerned

13 about this. All the diseases and pests I've

14 ever fought have been indiscriminate. They

15 don't care if you're small, medium or large. 

16 They're a problem for everybody. So those who

17 have this problem with fire blight, it's

18 everywhere, and everybody's affected by it.

19 Other people who have testified

20 have talked about the fact that we don't exist

21 in a bubble with organic production. We

22 produce organically right next to our
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1 conventionally producing neighbors. We have

2 to get along with those people.

3 I think if you don't control fire

4 blight in your organic orchard, your

5 conventional neighbors will strive to put you

6 out to business, because it's a really serious 

7 problem in the orcharding industry, and you

8 can't have a source of innoculant sitting

9 there to spread into the rest of the fruit

10 production that's out there. That's all I

11 have for you. Thank you.

12 CHAIRMAN STONE: Thanks for being

13 here. Questions? Jay.

14 MEMBER FELDMAN: Thanks for being

15 here. If you knew that, even though you're

16 not in fruit production, that the use of an

17 input would affect public trust in the overall

18 organic market, that is, people would start

19 questioning, you know, their faith and trust

20 in the organic market, and that would have

21 rollover effect or secondary effects to other

22 markets that are not the fruit, apple and pear
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1 production.

2 I mean, we obviously don't have a

3 crystal ball on this, but how would that

4 affect your thinking at this point?

5 MR. HYER: I believe what you're

6 asking is what is the public's perception of

7 organic. That's anybody's guess. It means

8 something different to every single consumer

9 out there.

10 MEMBER FELDMAN: Thank you.

11 CHAIRMAN STONE: Thank you. Thank

12 you for being here. Oh, I'm sorry. Sorry,

13 Tracy.

14 MEMBER FAVRE: Sorry. One last

15 question.

16 MR. HYER: Sure.

17 MEMBER FAVRE: Since you're not a

18 fruit producer and you're obviously busy as a

19 farmer, what motivated you to come here today,

20 to take the time to make this testimony?

21 MR. HYER: Some of the diseases we

22 face in vegetable production behave very
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1 similar to fire blight. The particular one we

2 deal with is called late blight. It's a big

3 issue in potatoes. People talk as though

4 these things are easy to deal with, easy to

5 control. They talk as though, well, you just

6 do this, this, and this and you won't have a

7 problem. That's not the case. 

8 When weather patterns, winds,

9 disease pressures get just right, there really

10 does seem to be almost nothing you can do,

11 regardless of all the steps you have taken to

12 prevent something like that from happening.

13 CHAIRMAN STONE: Great. Thank you

14 very much. Patty Lovera, and Kenneth Mandley

15 on deck.

16 MS. LOVERA: Okay. Hi everybody. 

17 My name is Patty Lovera, and I work for Food

18 and Water Watch, which is a national consumer

19 advocacy group. 

20 So our supporters are extremely

21 interested in the organic standards because

22 they use them. They use this label for lots
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1 of purposes, in which foods they choose and

2 they're very, very, very motivated to make

3 sure that the standards are -- ensuring that

4 the label is telling them what they're looking

5 for and what they think it does.

6 So very quickly I'm going to talk

7 about aquaculture, and then I'm going to shift

8 to tetracycline. 

9 So we agree with what Center for

10 Food Safety, George Kimbrell presented this

11 morning, and I'm not going to reiterate that.

12 I did bring a memo that we had given to the

13 NOP a few months ago, to try to inject some

14 more information into what you're using, since

15 the recommendation came out in 2008. So I

16 will drop that off.

17 It does have some new data since

18 2008 about escapes from open net pen systems,

19 especially salmon systems, which is every year

20 we can reliably add to that data, because the

21 escapes keep happening. It is a fact of life

22 in those systems, and that's an environmental
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1 issue.

2 There's also some information in

3 there about using fish meal and fish oil as

4 feed, and just the last thing I'll say about

5 that is as you're looking at these materials,

6 I know that's the job has before it, we think

7 you do have to think about those materials in

8 both systems, since we don't yet have a

9 standard of what organic aquaculture's going

10 to be. We need to look it in an open system

11 and a closed system. There's a much different

12 environmental scenario about how you use

13 materials.

14 So to shift to tetracycline, in

15 the interest of time, Food and Water Watch

16 supports the minority position, and we oppose

17 any extension on the expiration date for

18 oxytetracycline for apple and pear production. 

19 I think the issue of consumer expectation has

20 been covered well here, but it's where we come

21 from as a consumer advocacy group, and I do

22 want to just point out a couple of things.
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1 I know that you heard yesterday

2 about the polling that Consumers Union did,

3 and that's been affirmed in our experience, in

4 our conversations with the folks who talk to

5 us, who come to us to do, learn more and take

6 action and things like that.

7 What we're finding out is that

8 they don't know that these materials are used,

9 and when they find out, they're not happy. I

10 think the point made earlier about what do

11 consumers know and whose responsibility is it

12 to tell them, I think it's an interesting

13 conversation and, you know, consumer groups

14 are having this conversation.

15 You've seen that we're talking to

16 our members. We're doing action alerts. The

17 word will be getting out there, and as we talk

18 about organic, it's a lot more complicated now

19 if we're going to talk about antibiotics, and

20 there's not a very, very firm plan to get

21 antibiotics out of organic.

22 The other thing I do need to say
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1 though is that as I am reminded regularly, in

2 Washington, D.C., especially, this is a

3 marketing program. I'm reminded of that all

4 the time when I talk about organic. So

5 marketing plays a role too.

6 So I think that we have to talk

7 about what marketing messages consumers are

8 getting about this label and about the use of

9 antibiotics.

10 So on Friday, we looked very, very

11 quickly on the Internet and found -- very

12 quickly on the Internet and found examples

13 from national food companies, one of whom is

14 represented on this Board. Sorry, Earthbound.

15 We found examples where folks are

16 not making a distinction between livestock and

17 other foods. They're saying organic does not

18 use antibiotics. That's what consumers are

19 learning. So it's time for organic to live up

20 to that expectation. 

21 So last, quickly, I will just say

22 on the residue issue, it's an important
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1 conversation. As a consumer, I'm obviously

2 motivated by thinking about what I'm taking

3 in. But we spend an enormous amount of time

4 outside organic talking about antibiotic

5 resistance issues, and we've been educated

6 about the reservoir of resistance in the

7 environment being the threat that keeps public

8 health officials awake at night.

9 So I think we really have to focus

10 on what we heard from Dr. Morris. There's

11 like some comments in the docket from places

12 like Johns Hopkins University that are talking

13 about any use of these materials start to take

14 away their effectiveness.

15 They build to that reservoir of

16 resistance in the environment, and organic

17 needs to be ahead of that curve, not begging

18 for more time. 

19 CHAIRMAN STONE: Great, thank you. 

20 Zea.

21 MEMBER SONNABEND: Thank you. 

22 Would adopting an annotation such as was
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1 proposed by Lynn and the centrist position

2 make you feel better or make you change your

3 message to your constituents in any way?

4 MS. LOVERA: I think, at this

5 point, what consumers need to hear is

6 something that's going to be hard to prove

7 without a time machine, is that it's going to

8 happen. We've had this experience with other

9 materials and other kind of controversies in

10 organic.

11 So I think we have to tell them

12 it's absolutely going to happen. There isn't

13 going to be any slippage. This is how. And

14 we're going to have to reserve judgment until

15 we hit that date, whatever the date is, and we

16 see if this material's still being used. 

17 That's the honest answer of where

18 we can come from. I think the strongest

19 signal the Board can send is to not extend the

20 date.

21 CHAIRMAN STONE: Colehour.

22 MEMBER BONDERA: Thank you. Thank
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1 you, Patty. I want very briefly for you to

2 address for me, at least -- and I know we're

3 switching topics; we're focused on this

4 tetracycline. But I would like from the Food

5 and Water Watch's perspective what you were

6 referring to. 

7 If you could just given what you

8 said, and you said, you know, you've passed

9 some of that around and what-not, what would

10 you -- I hesitate, because I'm not sure what

11 to say -- advise or suggest or encourage us as

12 the NOSB to do, given the information that

13 you're referring to and have provided, in

14 terms of, so, what's our next step, in your

15 opinion?

16 MS. LOVERA: On aquaculture?

17 MEMBER BONDERA: On aquaculture. 

18 Yes. Sorry, sorry, I apologize. Yes. I

19 apologize.

20 MS. LOVERA: Okay. Right. So, I

21 mean, this is a tough procedural spot that the

22 Board is in, and we appreciate that. So you
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1 have a recommendation that none of you were

2 around to make. It has not yet been made a

3 standard, and you're supposed to evaluate

4 materials for systems that you don't know what

5 they look like yet.

6 So, we get that. I don't envy the

7 position of the Board in having to navigate

8 that. So I think that's probably an agenda

9 question from the Program that we have an

10 opinion on, about whether you all should be

11 looking at materials yet, if we don't know

12 what these systems look like.

13 We would say no. And then I think

14 if it stays on your agenda and you're still

15 having these conversations, I think you sadly

16 have to do the extra work of thinking about

17 different scenarios of how materials are being

18 used, and you're not -- so that you're

19 thinking about all the possibilities before

20 you approve the material, because there's a

21 huge variation of what aquaculture can be. We

22 heard about that this morning.
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1 So I think it actually adds to

2 your work, if you're doing those materials

3 before we know what the systems are going to

4 look like.

5 CHAIRMAN STONE: Jay.

6 MEMBER FELDMAN: Thanks, Patty. 

7 Can you explain to the Board what Food and

8 Water Watch's stake is in the growth and

9 success of organic production?

10 MS. LOVERA: I mean, so, Food and

11 Water Watch talks to consumers most of the

12 time about what we don't like about, whether

13 you want to call it industrial agriculture and

14 conventional agriculture, and people logically

15 want to know then what am I supposed to do

16 tomorrow while these bigger challenges are

17 being tackled.

18 We would like to be able to

19 continue to say that organic presents an

20 option, and you know this, this and this

21 aren't happening, and this, this and this are

22 happening.
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1 So that's what we say, and we tell

2 people that, and we also try to put out

3 information that lets people know what

4 expectations they can have of organic that are

5 rational.

6 The more asterisks, the more

7 "excepts" we have to put on there, but they

8 don't use antibiotics "except" in this, or

9 they don't, you know, feed animals feed that

10 isn't 100 percent organic, "except" in

11 aquaculture, the harder it is for us to say

12 that that's an easy, you know, daily thing

13 that you can do to kind of avoid the ills

14 we're talking about in the mainstream system. 

15 So we want this to be the strongest program it

16 can be so we can credibly recommend it to

17 people.

18 CHAIRMAN STONE: Harold, if you'll

19 finish this up.

20 MEMBER AUSTIN: Hi, Patty. Hey,

21 quick question. You made a comment about all

22 of the things that you're involved with. 
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1 Question regarding the consumer survey, the

2 petition with the signatures and stuff. Do

3 you represent -- were those signatures, were

4 those strictly from organic consumers, or were

5 those from all consumers?

6 MS. LOVERA: Those are from people

7 who are on our email list. It was a very

8 small sample of our email list actually,

9 because it's been kind of a busy month when we

10 had to get those. So we sent that to about,

11 I think we sent it to about 40,000 people, and

12 about 7,000 responded, which is actually very,

13 very high.

14 These are people who identify with

15 Food and Water Watch. We ask them

16 periodically how they identify themselves. 

17 They are very interested in organic. I don't

18 think that they would say they are only

19 organic consumers. They're kind of all over

20 the range of interested --

21 MEMBER AUSTIN: Okay, so, I mean,

22 and that's what I'm trying to clarify. Are
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1 they truly, were they truly organic

2 stakeholders, or were they from the masses?

3 MS. LOVERA: I think there's some

4 of both.

5 MEMBER AUSTIN: Because that does

6 have an impact.

7 MS. LOVERA: I mean, so we ask

8 people about their demographics and what they

9 do about once a year, and there is a range. 

10 I don't know if anybody's 100 percent organic

11 all the time, and we don't ask them that. But

12 they respond to organic issues. They're very

13 invested.

14 CHAIRMAN STONE: Thank you, Patty. 

15 I have Kenneth Mandley to the podium and Neal

16 Manley on deck.

17 MR. MANDLEY: How did that happen? 

18 Good afternoon. My name is Ken Mandley. I

19 operate a small certified organic apple

20 orchard in northwest Wisconsin. But I'm here

21 today on behalf of the Organic Tree Fruit

22 Association, a group of organic tree fruit
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1 growers centered in the upper Midwest. To our

2 knowledge, the only formal organization of

3 organic orchardists east of the Rocky

4 Mountains. 

5 As growers, we've watched the

6 continuing debate concerning use of

7 antibiotics with concern. As is true of the

8 larger organic community, our members have a

9 wide range of opinions, practices and

10 philosophies regarding such use.

11 However, after much internal

12 debate, we developed a middle course between

13 outright ban and unrestricted use. Today, I

14 want to quickly address some common

15 misperceptions, and then offer our middle

16 ground proposal.

17 First, contrary to some

18 suggestions I've read, and this is important,

19 organic fruit growers, at least those in our

20 organization, are not trying to cheat, subvert

21 or water down organic standards. Our members

22 are generally small growers with an average
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1 commercial orchard size of less than ten

2 acres, the largest about 200 acres.

3 We are committed to providing

4 healthy fruit for consumers while being good

5 stewards of land and water. In fact, our

6 commitment to organic agriculture is so

7 strong, we put our money where our mouth is

8 every year, as we face the risk of financial

9 failure, while working to provide a crop of

10 saleable fruit.

11 The second misperception concerns

12 the practicality of replacing our orchards

13 with fire blight-resistant trees. This is not

14 economically viable in the short or medium

15 term. Commercial availability of the Geneva

16 series is limited. There are some cultivars

17 that are more blight-tolerant than others. 

18 There are blight immune cultivars.

19 The third misperception involves

20 the fear of antibiotic use will lead to

21 resistant bacteria infecting humans, and David

22 addressed that better than I can. In my
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1 written comments from our organization, we

2 reference some other scientific studies I want

3 to call your attention to.

4 The final misperception is that

5 there are viable alternatives to antibiotics

6 currently available. The truth is new

7 products developed for use in Washington State

8 may or may not work around the rest of the

9 country. In fact, early research conducted at

10 Michigan State University indicates that

11 Blossom Protect does not work at all in

12 Michigan growing conditions.

13 Further, such products do not

14 address the catastrophic potential of a post15 blossom infection brought on by the

16 combination of hail, high humidity and high

17 temps, a very real potential in the upper

18 Midwest.

19 The truth is many apple and pear

20 growers rely on antibiotics at certain times 

21 because there are no other options. The

22 suggestion that this is somehow the fault of
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1 growers is misguided, at best.

2 Growers turn to antibiotics

3 because they cannot afford to put their

4 orchards at risk of total loss. Having said

5 that, we also understand the philosophical

6 concern of some, but not all, organic

7 consumers.

8 We propose that the current rule

9 be allowed to expire as scheduled in 2014, and

10 be replaced by a rule that allows antibiotic

11 use only when blight risk is high, as

12 predicted by computer models or actual orchard

13 observation.

14 The organic system plan must

15 address prevention through measures such as

16 sanitation and pruning, as well as other

17 preventive inputs. In this period, it would

18 hopefully allow time for other alternatives to

19 be developed in increased quantities of

20 blight-resistant root stocks.

21 Finally, after that period,

22 transition to an even more restrictive rule,
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1 and I understand there might be some legal

2 complications with this. But a more

3 restrictive rule, that allows use of

4 antibiotics in emergency situations, and in

5 that case, the fruit treated with antibiotics

6 would not be sold as organic that year.

7 Sacrificing one year's crop in

8 order to save the entire block seems to be a

9 reasonable compromise. If you have any

10 questions about the differences between the

11 Midwest and other parts, like Washington, why

12 orchards planted since 1995 are still at risk,

13 and why some growers don't use antibiotics and

14 others do, I'd be glad to answer those.

15 CHAIRMAN STONE: Very good. 

16 Francis.

17 MEMBER THICKE: Thank you. It's

18 good to hear from somebody from the Midwest. 

19 I'm curious. In Wisconsin and the Midwest, is

20 tetracycline used widely, or is it mostly

21 strep?

22 MR. MANDLEY: It is not used
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1 widely. It is used -- strep would be more,

2 would be more commonly used, and even strep is

3 not used widely. The data that I heard from

4 Cornucopia, that only a relatively small

5 percentage of growers have used antibiotics,

6 would include me. I respond to that, and in

7 six years I have had my organic orchard and I

8 took over an abandoned orchard. In the six

9 years I've managed organically, I have never

10 used antibiotics.

11 But it is in my plan, simply

12 because certain conditions I would have no

13 other options. But it would be strep that

14 would be probably more commonly used.

15 MEMBER THICKE: And can you review

16 again what your recommendation is? Did you

17 say four years or five years of allowing it,

18 and then an amnesty program after that?

19 MR. MANDLEY: We suggested that

20 the current rule expire as scheduled in 2014,

21 and it be replaced by a more restrictive rule,

22 and then, you know, our hope is other things
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1 will happen after that point.

2 But if they don't, that then

3 would, after another sunset, would be replaced

4 by an even more restrictive rule, that would

5 say organic fruit can't be sold as organic in

6 the year that an antibiotic is used.

7 Taking away that consumer concern

8 that I'm consuming antibiotics, even though

9 what research we have seen indicates that it's

10 not so.

11 CHAIRMAN STONE: Calvin? John?

12 MEMBER FOSTER: Can you bring that

13 recommendation to the next meeting? 

14 MR. MANDLEY: We'll try.

15 MEMBER FOSTER: Okay, thanks.

16 MR. MANDLEY: We will certainly

17 bring it in some fashion. 

18 CHAIRMAN STONE: Nick.

19 MEMBER MARAVELL: Do you have any

20 experience or knowledge of any of your growers

21 in that region using some of the materials

22 that we have been discussing here, lime,
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1 sulfur, copper and the Blossom Protect,

2 outside of the research environment? But have

3 you any of your growers started down that road

4 already?

5 MR. MANDLEY: Oh, way more than

6 started. Copper in late dormancy is a common

7 protectant. Most of the growers that I've

8 talked to personally about this issue practice

9 orchard sanitation and good pruning.

10 One of the things that needs to be

11 understood is you never, ever, ever get rid of

12 fire blight. Once it's in your orchard, it

13 will always be in your orchard until you burn

14 the orchard.

15 So you can protect against

16 outbreak, but you can't do anything in the

17 current environment to assure that you will

18 not have an outbreak. What I should be doing

19 right now, rather than being here in Oregon,

20 is spraying copper. That was on my plan. So

21 the next week.

22 MEMBER MARAVELL: Are you aware of
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1 anybody that's using the Blossom Protect?

2 MR. MANDLEY: No. As I said, the

3 initial research at Michigan State that they

4 did indicated that it simply didn't work, and

5 scientists there tried to explain why,

6 probably, and it kind of went over my head. 

7 But it has to do with humidity and the product

8 itself.

9 CHAIRMAN STONE: Jay, you want to

10 finish this up, please?

11 MEMBER FELDMAN: Well thanks for

12 your creative thinking. We appreciate it. We

13 need it.

14 One of the reasons that there's

15 sort of a concern about writing an annotation

16 on National List material is that we have this

17 tendency of extending those things. And how

18 would you feel about removing the material and

19 putting it in an emergency use category that

20 would be dependent upon a national or state

21 finding of an emergency, which given what

22 we've heard, wouldn't seem to be too
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1 difficult?

2 And then following the rest of

3 your proposal, which is to allow its use, not,

4 you know, retain certification without being

5 able to market in the year of use?

6 MR. MANDLEY: Yeah. I would be

7 against that, solely because I might have a

8 hailstorm, and my neighbor five miles from me

9 might not have the hailstorm. So the issue of

10 the emergency use wouldn't cover what we

11 experience in the Midwest, and that's very,

12 very localized conditions, where I need it and

13 someone else doesn't.

14 MEMBER FELDMAN: Localized

15 conditions. No, but if it could address

16 localized conditions. I mean --

17 MR. MANDLEY: If it somehow could

18 address localized conditions --

19 MEMBER FELDMAN: EPA uses

20 emergencies all the time on a county by county

21 basis. It just has to be declared by the

22 governor, you know, or his representative. So
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1 the question is would you feel comfortable? 

2 I guess in this case it could be declared by

3 NOP. But would you be comfortable, assuming

4 there could be --

5 MR. MANDLEY: Let's see. How long

6 does the NOP take to do this?

7 (Laughter.)

8 MEMBER FELDMAN: They could --

9 well, the way I would see it working is they

10 would have to have a standing allowance, based

11 on certain conditions, that that would qualify

12 as an emergency.

13 MR. MANDLEY: And I think that's

14 sort of what we were suggesting, because we do

15 understand the difficulties and the reasons

16 why unrestricted use is not wise. We do

17 understand that.

18 MEMBER FELDMAN: Okay, thank you.

19 CHAIRMAN STONE: All right. Thank

20 you very much for taking time to be here.

21 MR. MANDLEY: Thank you.

22 CHAIRMAN STONE: Neal Manley to
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1 the podium. No Neal. Melody Meyer? Melody's

2 coming this way, and Sal D'Auria on deck.

3 MS. MEYER: Hello. Thank you for

4 letting me be here to speak about

5 oxytetracycline. Let me begin by emphasizing

6 that I work for UNFI, and UNFI is completely

7 and absolutely committed to ending the use of

8 antibiotics in apple and pear production.

9 I've worked in the organic

10 industry for 36 years, and mostly with organic

11 fruits and vegetables. So I have great

12 experience with organic apple and pear

13 farmers. 

14 A little bit about UNFI. You saw

15 it on the board. UNFI is the leading

16 independent national distributor of organic

17 foods and organic produce in the U.S. We have

18 national distribution coverage in all 50

19 states, including Canada. We're the leader in

20 providing organic foods in North America, with

21 7,000 associates, serving 27,000 customers

22 with 65,000 products.
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1 We're also a member of the Organic

2 Produce Wholesalers Coalition, which Natalie

3 mentioned as well. That coalition is a group

4 of founding members of this industry, and

5 we're very concerned about this issue.

6 Organic apple and pear sales are a

7 critical sales category for Albert's Organics,

8 which focuses on the distribution of organic

9 produce for UNFI. Organic apples rank number

10 two in sales, only behind berries. Organic

11 Northwest apples represent 22 percent of all

12 fruit sales, and are nine percent of total

13 produce sales for Albert's Organics.

14 Last year's sales from Northwest

15 apples alone were $16 million, as the slide

16 showed. Our year-over-year growth for

17 Northwest apples was 21 percent, making this

18 category one of our fastest-growing.

19 Organic apples and pears are not

20 only an important category to us at Albert's

21 and UNFI, but they're also a source of

22 nutrition, great pride and flavor for us, in
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1 that we make these apples and pears available

2 to people all across the U.S. and Canada.

3 Additionally, organic apples and

4 pears are the source of livelihood for over

5 100 organic growers that we purchase from in 

6 the Northwest. Many of these producers rely

7 entirely on their organic fruit production to

8 support their families. We have known and

9 worked with these producers for over three

10 decades. Put simply, many are like family to

11 us.

12 Many and most of our growers have

13 told us that if the tools currently needed to

14 fight fire blight are taken away too early,

15 and without viable alternatives, they may have

16 no choice but to convert to conventional

17 production. A typical orchardist has a

18 $20,000 per acre and a five year investment in

19 their orchard.

20 Pears take 10 to 12 years at

21 minimum to start producing. In seasons of

22 severe fire blight, the very hard decision
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1 will come down to do I lose my entire orchard,

2 or do I convert to conventional production and

3 save my investment?

4 Losing an entire orchard is not a

5 temporary setback. It's devastating on a

6 personal and family level. Losing an organic

7 producer is devastating to this industry, and

8 affects everything all the way down to the

9 consumer. It has ripple effects.

10 If the selected extension date

11 does not provide enough time for scientific

12 remedy to be developed and the proper tools to

13 be acquired, to the grower, the decision is a

14 clear one.

15 Please support our producers and

16 family farmers who are the real backbone of

17 rural communities. They will bear the

18 greatest impact of any premature deadlines.

19 UNFI and Albert's is absolutely

20 committed to ending the use of antibiotics in

21 pear and apple production. A 2017 expiration

22 date will support current research and
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1 testing, and allow for grower education and

2 success.

3 The expiration dates need to be

4 based on research-based time lines, not

5 political compromise. The original deadline

6 that we have now was put forward without

7 public comment.

8 Expiration dates that are the

9 result of -- and thank you very much. I have

10 more experience with some consumers, if you

11 want to ask me those questions as well. Thank

12 you.

13 CHAIRMAN STONE: Thank you,

14 Melody. Harold.

15 MEMBER AUSTIN: Could you go ahead

16 and explain to us your experience with your

17 consumers?

18 MS. MEYER: Absolutely. Since

19 we've had a lot of the consumer associations

20 and people coming out with quite frankly some

21 misinformation, that your gut is full with

22 every bite of apple, we've had a lot of
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1 consumers, retailers and their consumers

2 calling us.

3 We put together some really

4 educational talking points about the minuscule

5 amounts that are used, it's used during

6 blossom primarily, and also the effects of if

7 this is done prematurely, it will drive many

8 organic orchardists into conventional

9 production, in which case we have more

10 antibiotics used, potentially more chemicals,

11 because they're in conventional production.

12 There won't be as many apples and

13 pears, so that will drive the price up, and

14 the average organic consumer won't be able to

15 feed organic apples and pears to her children,

16 his or her children.

17 So the ramifications are huge, and

18 just to have that information to those

19 consumers and give them a balanced approach

20 rather than misinformation is very, very

21 important, and I think that we can manage

22 that, serve the grower community and the
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1 consumer community as well.

2 CHAIRMAN STONE: Great. Thank you

3 very much.

4 MS. MEYER: Thank you. Thanks for

5 all the work that you're doing. 

6 CHAIRMAN STONE: Sal D'Auria is to

7 the podium, and David Mostin on deck.

8 MR. D'AURIA: Well, thank you very

9 much, and thanks, Mac. My name is Sal

10 D'Auria. Thanks for pronouncing it correctly. 

11 My wife and I have an organic orchard up in

12 the upper Hood River Valley.

13 I met a number of you earlier this

14 week, and I think in the fun part of your week

15 when you're actually outside seeing trees and

16 not stuck in a room here.

17 Thank you for doing the job you're

18 doing. You guys have a very, very difficult

19 decision to make. You've got a difficult job. 

20 I definitely do not envy you, because the only

21 thing I'm sure about your decision is that

22 whatever the decision is, is that some people
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1 will not be happy with it. That's the only

2 thing that's for sure.

3 But I think that you should take

4 some comfort in the thought that if you apply

5 science and logic and a healthy dose of

6 pragmatism, you'll be doing a great job for

7 everybody, and that's a terrific thing. 

8 I've really enjoyed the last day

9 or two here. I've learned a lot. I've been

10 inspired, but I've also been somewhat

11 disappointed. Some of the presentations I've

12 seen mixed, a lot of different language.

13 The language like "possible" and

14 "probable" are two very different words in the

15 science world, and some people I saw mix those

16 things in ways that I think could be

17 misleading.

18 I think that the mixture of facts

19 and opinions is something one needs to watch,

20 and I'm going to try my best to stick to a

21 bunch of facts and tell you when I tell you my

22 opinions on those various things. 
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1 Jay, you did a great job the other

2 day of helping me frame this massive amount of

3 information that we're putting together here,

4 and I should tell you that my background's in

5 science, and I spent the last 25 years in the

6 world of developing products in the R&D

7 environment and dealing with very complex

8 problems. 

9 So if I could have the slide. I

10 can't find my slide. If you can't find the

11 slide, I'll just say that -- just to keep

12 track of things, I said, okay, how do we frame

13 this to kind of like do a report card of where

14 we are. Hopefully, we'll get this and I can

15 get a few minutes back here.

16 The thing that Jay really

17 impressed me with the other day was the

18 concept that what you're dealing with is a

19 balancing act between need and hazard. I

20 think those were some of the words that I

21 heard a number of times from you, Jay, and

22 they were very important for me to hear and
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1 help frame this thing.

2 So if you look at -- did you find

3 it? Okay, thank you. So if we look at this

4 balancing act that you all are dealing with

5 and look at these sort of two columns, the

6 need column on the left and the hazard column

7 on the right and see how it all adds together.

8 I can tell you again I'm trying to do my best

9 to give you the facts of the real world of my

10 own orchard.

11 On the needs side, we've heard

12 this and you've heard it many times, popular

13 varieties are at risk. I know that we, our

14 highest values pears are Comice and Forelles,

15 and Star Crimson next. Those are very at-risk

16 varieties. 

17 We also heard that the

18 combination, the vectors coming together of

19 gross cycle, climate and weather will cause

20 this very severe problem, and some people will

21 have it based on their geography and some

22 people will not. But if you provide cultural
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1 practices, sanitation practices and you do

2 those every single day, every part of the

3 cycle, that helps the process.

4 But, but, if you don't do that and

5 if you don't have the tools of

6 oxytetracycline, you will lose your trees. 

7 Now, let me ask you, you know, how many

8 products, how many materials are on the list

9 that have to do with losing a crop, period? 

10 I know lots of products, you know, these

11 products will make your fruit bigger. These

12 will make them more colorful. These will stop

13 them from dropping off the tree.

14 This product is about stopping

15 death in the orchard. How many others are on

16 the list? I don't know too many. I know I

17 don't use any other products that have that

18 effect on my crops.

19 So on a scale of sort of nice to

20 have, because it makes better color, to

21 critical because I'll lose my orchard, I think

22 you can guess that I would say, if it's about
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1 death, if it's about critical, I don't know

2 what your scale is, but I would say it pins

3 the scale for any logic I know.

4 On the hazard side, I think you

5 need to break it down. I think this is

6 really, really important, because it's so

7 important, you know. Hazard both to the

8 consumer and also to the environment. We have

9 to think about that. We are organic farmers. 

10 We believe in this.

11 Jay asked me the other day, why do

12 you do this? Well, we do this because we want

13 good food for our kids, our families, for now

14 and in the long future. 

15 The reality is that, in our

16 orchard, this is never sprayed on mature

17 fruit. It's sprayed at bloom, and when those

18 vectors are and the Cougar model tell us it's

19 a bad thing, and my certified consultant tells

20 me and signs a paper that this is the time I

21 need to use it.

22 Last year, we had blossom about
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1 May 1st on our Comice, and we picked them

2 October 1st. That was five months later. 

3 The earliest pear was four months later from

4 the bloom. So four to five months before the

5 picking.

6 I want to make it clear -- can I

7 get a couple of minutes more, because of my --

8 or did you reset it? I just want to say that,

9 you know, from a -- are we okay? I have a

10 minute. So again, this product is not

11 synthetic. It is naturally occurring. I

12 heard some people say, oh, it's synthetic. 

13 It's not. You guys, I think, know that.

14 I took Jay's advice last night and

15 I looked and looked and I found 273 hits on

16 your website, looking for some primary

17 research on residue.

18 I'm sorry I didn't read every

19 single one of them, but I couldn't find one. 

20 I heard some great things today. I think

21 there's some great science out there that

22 should not be disregarded.
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1 And again, relative to scale, from

2 a consumer perspective, you know, from what

3 I've heard and what I know to be factual, I'd

4 think that on the relative scale this is on

5 the low scale relative to consumer, immediate

6 consumer hazard.

7 On the environmental side, there's

8 no question. I think that we all want to see

9 -- the doctor today did a great job of

10 explaining to us about the long term impact of

11 those things. We want to see those things go

12 away. We want to see other products that we

13 can use to help get us around this.

14 But, but, organic is -- I'm saying

15 less than five percent. It really was less

16 than -- a lower number than that, you know. 

17 It's a very, very small number, and on the

18 relative scale, it doesn't move the scale that

19 much.

20 I believe that those are facts on

21 this chart. The next slide, just real

22 quickly, just to say, if I were to summarize,
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1 I'd say that on the needs side, in this

2 balance, the need is critical. These are dead

3 trees. I don't know how you don't pin it to

4 critical.

5 On the hazardous side, I'd say,

6 pragmatically speaking, all things considered,

7 this is my opinion, that the hazard for both

8 the consumer perspective and the long-term

9 environmental perspective is relatively low. 

10 Thank you.

11 CHAIRMAN STONE: Thank you very

12 much.

13 MR. D'AURIA: Any questions?

14 CHAIRMAN STONE: Great. Thank you

15 very much. Thank you for helping to educate

16 us on the tour as well. 

17 MR. D'AURIA: You're welcome.

18 CHAIRMAN STONE: David Mostin to

19 the podium, and Addie Pobst on deck.

20 MR. MOSTIN: Good afternoon. I'm

21 David Mostin. I'm a third generation pear

22 grower in Lake County, California, in the
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1 coastal mountains north of San Francisco. My

2 oldest block of trees was planted in year

3 1900. We call it the old orchard. I've been

4 an owner operator for 33 years. I've been

5 certified organic since 2002. 

6 I also operate other orchards that

7 are both conventional and organic. I am

8 concerned with the loss of an effective

9 material, such as oxytetracycline, without the

10 opportunity to replace it in a reasonable

11 amount of time.

12 Following is my experience with

13 replacing materials and new materials. In

14 1996, the University of California Cooperative

15 Extension began field trials of pheromone

16 confusion products. I had several of my

17 orchards involved. The problem was the

18 increased resistance of codling moth to

19 organophosphate. After many years of field

20 trials, we were able to drop out the

21 organophosphates. Yet we still had it

22 available if the pressure got out of hand. 
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1 Eventually, the developed pheromone program

2 replaced the organophosphates as a standard

3 for conventional production.

4 After several years of proven

5 stand-alone effect of this pheromone program,

6 I saw the opportunity of transitioning to

7 organic production. Even though pheromones is

8 now the industry standard in our area for both

9 conventional and organic, the research

10 continues. In the 2011 California Pear

11 Research Report, three of the four projects

12 were about pheromones.

13 During that same time period, my

14 orchards were involved in the A506 BlightBan

15 trials. This material is a live bacteria that

16 is applied to out-compete other bacteria, one

17 of which is blight. Two weeks ago, we began

18 testing, or actually last week, a new

19 material, Blossom Protect. Never used it

20 before.

21 We've heard about the Michigan

22 trouble with it. This is a yeast-based
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1 material that out-competes blight. It does

2 not kill it. It's also double the cost of

3 antibiotics. In the 2011 California Pear

4 Research Report in the Plant Pathology

5 section, three out of three projects were on

6 fire blight. In the 2012 California Pear

7 Research Report, three of four projects were

8 on fire blight.

9 Next year, we hear that there will

10 be a new Blossom Protect material that

11 combines copper with yeast. The combination

12 has been shown to be more effective than

13 either material by itself. 

14 This year, I will apply four

15 different materials to control fire blight,

16 not including the tests with new products. 

17 Every year is different. This year, we

18 received 80 percent of our annual rainfall in

19 less than six weeks, and then went two months

20 with nothing.

21 Now we are in the middle of bloom,

22 and we have no frost threat, but we have
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1 storms every four to seven days. The 16 years 

2 of experience with pheromone BlightBan

3 research showed us it is easy to get good

4 results on a good year, one with light

5 pressure.

6 When things turn ugly and there is

7 ideal conditions for blight infection, then

8 you find out how effective your product is. 

9 During the years of research, the rates and

10 timings of these new products were developed. 

11 Even when the new product becomes the

12 standard, we strive for better.

13 For many years, during the

14 pheromone transition, we had materials

15 available, yet we did not use them unless the

16 pest population became unmanageable. The same

17 holds true for fire blight materials.

18 A year or two of exceptional

19 weather conditions can make all the difference

20 in the world for a new standard of grower

21 inputs to this operation. Thank you.

22 CHAIRMAN STONE: Thank you. 
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1 Questions for David? Nick.

2 MEMBER MARAVELL: Yes. I want to

3 get an idea of how familiar you might be with

4 Blossom Protect, and what some of the

5 potential pitfalls might be of that, since

6 you've had a lot of experience introducing new

7 products into your orchard.

8 What's your, just, you know, off

9 the top assessment, what could be some of the

10 problems with that?

11 MR. MOSTIN: When we started the

12 A506 project, there was a lot of monkeying

13 around with timing and rates, and it took a

14 couple of years in different kind of

15 springtime weather conditions, to figure out

16 what works, you know. You know, you can put

17 it on in an easy year and, you know,

18 everything's fine.

19 But you get an odd year and you

20 find out what, you know. So yeah, I would

21 expect and Blossom Protect, six days ago, I

22 never used it before. So I've got like zero
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1 experience. In fact, I'm supposed to put it

2 on again tomorrow. I've got to get out of

3 here.

4 But you know, the A506 material,

5 they went to like one shot early in finger

6 stage, you know, worked great. Multiple

7 shots, and it changed, based on the weather

8 conditions.

9 So I expect the yeast material is

10 very similar. You've got to play with it, you

11 know, and if we have a secondary material that

12 is similar to A506 that out-competes it, okay,

13 from what I understand, that new tissue,

14 there's nothing on it. The bacteria will

15 colonize it, and unless you take up the sites

16 and blight is always there. Blight is always 

17 there.

18 In 1982, we had a killer hailstorm

19 come through the first week of June. At that

20 time, we were using copper, copper dust. 

21 That's like old school. What a mess. I don't

22 want to do that again. So you know, and I've
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1 been doing for three years the delayed dormant

2 copper application. Never done that before in

3 my life.

4 And all these research programs,

5 they're for the total California pear

6 industry, not just the small amount that's

7 organic. And yet like the pheromone and the

8 A506, they weren't developed for organic. 

9 They just developed them and we're using them

10 good.

11 CHAIRMAN STONE: Tracy.

12 MEMBER FAVRE: First of all, I'd

13 like to thank you for coming. We should all

14 be humbled by folks like yourself, who take

15 time out of your busy schedule to make the

16 time and effort to come to speak to us, and it

17 is appreciated. So thank you.

18 My question for you is should you

19 not have the option for oxytet in your organic

20 pear program, what do you think your

21 alternatives would be?

22 MR. MOSTIN: I think it's -- I
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1 think that using multiple products that are

2 allowed, it's a matter of timing and rates and

3 research, a track record of what works and

4 what doesn't. Not having a material like

5 that, it's going to hurt. It's going to hurt.

6 When we phased out the

7 glutathione, we had really good success, and

8 it's been 16 years, and we had a research

9 project on it this last year. They're trying

10 to get the application amounts to half of what

11 the standard is this year. So we're trying to

12 reduce the materials put out there, and yet

13 maintain the effectiveness.

14 And you know, two years from now,

15 maybe there's something else that comes on the

16 market that will help us. But the fact

17 remains that if you do get a hailstorm post18 bloom, then you're in trouble. In that 1982

19 event, I had trees that had 20 cases of blight

20 in it. We probably cut ten percent of our

21 crop onto the ground because of the blight

22 infection.
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1 And you can't wait. If it hails

2 now, I walk out my back door, jump on a spray

3 rig and start spraying. You can't call

4 anybody or get permission. You've got to go. 

5 We spray when the trees are wet. We don't

6 even wait for it to quit raining. 

7 Usually, it's just like a five

8 minute hailstorm, and I may get hit. My

9 neighbor a quarter mile away doesn't. That's

10 what happened. It was like a half mile wide

11 swath right through the pear growers in the

12 Valley, and you can't wait for a disaster

13 declaration, like in the -- like the crop

14 disaster stuff that, you know, have to have 30

15 percent loss over the total county.

16 It doesn't happen. We've got six,

17 seven different microclimates. The guys in

18 Scott's Valley, they get hailed on almost

19 every year. I'm out in Big Valley. I see it

20 coming, and hope it goes left or right. So

21 yeah, no. It's just, if we don't got it, then

22 you just sharpen up your chainsaw. We had to
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1 take trees out because we could not control

2 it.

3 MEMBER FAVRE: But leaving the

4 organic program would not be a consideration

5 for you?

6 MR. MOSTIN: Oh geez. Well

7 probably if I would leave the program if I got

8 wiped out. Let me put it that way, okay?

9 CHAIRMAN STONE: Francis, if

10 you'll finish this out.

11 MEMBER THICKE: Real quickly. I

12 just wanted to thank you for what you're

13 doing, you know. You're the innovator that we

14 really need to get out there, the pioneer to

15 do it. Thanks.

16 MR. MOSTIN: Okay, thank you.

17 CHAIRMAN STONE: Thank you, David.

18 MR. MOSTIN: If I don't get home,

19 I put my wife on the sprayer.

20 (Laughter.)

21 CHAIRMAN STONE: Yeah. You'd

22 better get home. Addie Pobst to the podium
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1 and Nate Lewis on deck.

2 MS. POBST: Hi. My name is Addie

3 Pobst, and I'm with VivaTerra Organic. We are

4 a Washington-based sales agent with 20 years

5 of experience marketing organic fruits and

6 vegetables. Organic apples and pears are the

7 core of our business.

8 In 2012, we worked for U.S.

9 growers with over 3,000 combined acres of

10 organic apples and pears, and their harvests

11 brought them over 9.8 million in returns. We

12 represent independent organic growers, ranging

13 in size from four to four hundred acres.

14 On their behalf, I urge you to

15 support an extension for tetracycline. A

16 premature transition to non-antibiotic

17 alternatives that are not consistently

18 effective will undermine apple and pear

19 production in the U.S.

20 The sunset time frame must be

21 extended, so that alternatives can be

22 developed, tested, proven and made
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1 commercially available to growers. The

2 importance of antibiotic controls is difficult

3 to overstate. Fire blight does not cause

4 trees to die back; it causes them to die, and

5 quickly.

6 It does not respect orchard

7 boundaries, size or ideological purity. It

8 spreads incredibly fast. It does not infect

9 just a few trees; it spreads across acres and

10 acres of orchards, and it kills them. The

11 only cure for fire blight is a bulldozer and

12 a bonfire.

13 Antibiotics do not cure fire

14 blight, but they can protect orchards from

15 contracting this devastating bacterial

16 infection. In years when predictive models

17 indicate spring conditions are ripe for an

18 outbreak that would overwhelm the protection

19 granted by other techniques, antibiotic

20 controls are critical.

21 This is not a debate about a

22 substance used to grow prettier or larger
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1 fruit, or for some other convenience. It's

2 about the actual life of the trees, and by

3 extension, the livelihood of growers, workers,

4 their families and communities. 

5 The risk of losing entire orchards

6 representing years of work and thousands of

7 dollars is simply too high. Growers already

8 face all the inherent uncertainties of

9 agriculture. A year's crop can be lost due to

10 late frost, hailstorms, windstorms, heat

11 waves, labor disruptions and market upheavals. 

12 Any farmer can tell you a dozen such stories.

13 But after these disasters, growers

14 still look ahead with hope to the next year's

15 harvest. Fire blight doesn't leave a stricken

16 orchardist with even that hope. 

17 As long-time members of the

18 organic community, our company and our growers

19 emphatically agree on the goal of phasing out

20 antibiotics. Great strides have been made

21 towards the development of effective non22 antibiotic controls for fire blight.
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1 However, simply wanting an

2 alternative to exist by a certain date does

3 not make it so. Research takes time. 

4 Prematurely eliminating antibiotics will drive

5 organic growers back to conventional methods. 

6 Maybe not in the first year, because fire

7 blight doesn't strike everywhere every year.

8 But when that fateful spring comes

9 and conditions put their orchard at high risk,

10 growers will surely choose to use antibiotics

11 and lose their organic status, rather than

12 watch their orchards die. Once a grower has

13 taken that step and lost his or her organic

14 status, economic realities will mean going

15 full-blown conventional, in order to compete

16 in the conventional market.

17 Eliminating antibiotics from the

18 allowed synthetics list in 2014 will not

19 reduce the amount of antibiotics in U.S. fruit

20 production. Instead, it will increase the

21 risks faced by organic growers beyond what

22 they can stand. It will reduce the
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1 availability of U.S.-grown organic apples and

2 pears for consumers. 

3 Most damaging of all, it will

4 hobble efforts to develop non-antibiotic

5 alternatives that can eventually be used by

6 all producers, conventional and organic. 

7 Thank you for your time. Please support the

8 extension to give researchers the time they

9 need to develop the solutions we all want. If

10 you have any questions about consumers or how

11 the organic tree fruit market works, I'd be

12 happy to answer them.

13 CHAIRMAN STONE: Thank you. 

14 Harold.

15 MEMBER AUSTIN: Thanks, Addie. 

16 What conversations have you had with your

17 customer base and consumer base in this

18 regard?

19 MS. POBST: We receive emails from

20 end consumers, as well as from our direct

21 customers who are retailers and wholesalers

22 regarding this issue. More so in the last
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1 four or five months, there's been a definite

2 up-tick in interest. 

3 Prior to that, we've had an FAQ

4 available on our website for years, in case

5 anybody was interested. We certainly weren't

6 hiding the fact that tetracycline was used, or

7 antibiotics were used, in organic tree fruit

8 production.

9 The questions that we've gotten

10 are generally just very straightforward, you

11 know, something along the lines of, you know,

12 my mom told me that she heard a radio program

13 that said that antibiotics were used in

14 organic tree fruit. Is that true?

15 And we answer back with an email

16 that says, yes, that's exactly true, but here

17 are the reasons why and, you know, this is how

18 it's allowed, this is how it's regulated, you

19 know. We're very open with that information,

20 because we would really like everybody

21 involved in the organic community to actually

22 understand that this is not some nefarious
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1 scheme or conspiracy. This is just a reality

2 of agriculture.

3 Typically, I don't hear back from

4 them again after that, so I can't really say,

5 you know, how it goes from there. But I feel

6 like at least we've done our part to be open

7 and honest with anybody who's interested.

8 CHAIRMAN STONE: Great. Thank you

9 very much.

10 MEMBER FELDMAN: Thanks, Mac. 

11 Thank you. How would you feel about the

12 possibility of labeling apples with some

13 language that indicates they've been treated?

14 MS. POBST: You know, honestly, I

15 can't see that even working a little bit. Not

16 because we couldn't put labels on boxes. We

17 can put labels on boxes. We do that all the

18 time. That's a normal occurrence for us. 

19 But I would say, if you look at

20 how the country of origin labeling has been

21 instigated or actually effectively implemented

22 in the country, I go regularly into retail
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1 stores where I see fruit that has a PLU

2 sticker on it that very clearly says "Chile,"

3 say, as the country of origin, and directly in

4 front of that there's a little handwritten

5 sign, or maybe it's a little chalkboard or one

6 of those little, you know, POP signs that

7 sticks up, and it says "California."

8 If we can't even get country of

9 origin labeling on a one-word label correct at

10 the retail level, I mean, a sentence that

11 says, "This fruit was grown in an orchard that

12 was treated last spring with tetracycline in

13 order to control fire blight." To actually

14 get that at the retail level on display, you

15 know, in a way that's going to make sense to

16 anybody in any kind of accurate way, just

17 strikes me as not likely.

18 CHAIRMAN STONE: Thank you, Addie. 

19 Nate Lewis to the podium and Anne Schwartz on

20 deck.

21 MR. LEWIS: Distinguished members

22 of the Board, my name's Nathaniel Lewis, and
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1 I work as one of three certification

2 coordinators at Washington State Department of

3 Ag. My role covers the coordination of our

4 input material registration program, the

5 organic certification of processors and

6 handlers, and our periodic residue sampling

7 program.

8 I'm owner and operator of a

9 certified organic livestock operation, located

10 about 90 minutes north of Portland, Lincoln

11 Creek Ranch, where we're now starting to

12 implement biodynamic practices. I'm also a

13 father and organic consumer who doesn't feel

14 betrayed by the limited use of oxytetracycline

15 in organic apple and pear production.

16 While today I'm representing the

17 views of WSDA in the following public comment,

18 nothing I'm about to say conflicts with my own

19 personal opinions as an organic producer and

20 consumer.

21 The minority position within the

22 Crop Subcommittee recommendation on
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1 oxytetracycline uses previous public comment

2 from my colleague at WSDA, Katherine Withey,

3 to support conclusions that are uninformed and

4 inaccurate.

5 Since our organization is

6 specifically called out in the recommendation,

7 we felt it appropriate to comment directly on

8 these statements. First, there are no

9 producers in full compliance with the USDA

10 organic regulations that rely on

11 oxytetracycline. Compliant producers rely on

12 their preventative management plan and use the

13 oxytetracycline only when their plan is

14 failing.

15 Second, the minority concludes

16 that since, in 2010, 96 producers grew apples

17 and pears for EU export, meaning without

18 oxytetracycline, they must be doing something

19 fundamentally different than producers who had

20 applied antibiotics.

21 This is an uninformed and

22 therefore illogical conclusion. Many
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1 producers who grow apples and pears in

2 compliance with the EU restrictions, without

3 oxytetracycline, also grow varieties of

4 organic apples and pears that receive

5 oxytetracycline treatments.

6 These split operations do not

7 implement different preventative practices on

8 their various production sites. Rather, these

9 producers fall victim to the unpredictable and

10 hyper-locale-specific nature of this disease.

11 Third, the minority advocates for

12 the use of other 601 listed materials, lime

13 sulfur, dormant oil, copper, et cetera, as

14 part of a prevention program for fire blight. 

15 To advocate for the use of one synthetic

16 disease control material over another is

17 inconsistent with the current requirements of

18 the Pest, Weed and Disease Prevention Practice

19 Standard, and we find encouraging these

20 practices to be problematic.

21 I would like to provide general

22 comment on the use of expiration dates and
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1 National List annotations. We feel the use of

2 any annotations that are redundant to the

3 current practice standards in OFPA, like

4 expiration dates, required pest prevention

5 hierarchy, detracts from the certification

6 process.

7 These type of annotations demand

8 to certifiers utilize their communication

9 resources to convey the myriad of changes and

10 restrictions on specific materials. This

11 inherently detracts from our efforts to

12 communicate the requirements of practice

13 standards. The appearance of focusing on

14 materials runs counter to the process-based

15 approach of organics we all champion.

16 The Board should use the power to

17 annotate carefully, and it's absolutely

18 critical to any annotation, whether redundant

19 to the current standard or not, have adequate

20 defensible justification.

21 Lastly, this phase-out of

22 oxytetracycline has highlighted the importance
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1 of fostering our land grant university

2 cooperative extension and farmer collaborative

3 process.

4 The Subcommittee resolution urging

5 certifiers to encourage an increase in

6 specific preventative practices is a challenge

7 we're excited to meet. We strive to make

8 strategy our strength and not disaster. 

9 CHAIRMAN STONE: Great. Thanks,

10 Nate. Questions? Very good. Thank you very

11 much. Very informative. 

12 Anne Schwartz to the podium, and

13 Jeff Falen on deck.

14 MS. SCHWARTZ: To members of the

15 NOSB, my name is Anne Schwartz. I'm a mixed

16 vegetable and berry producer. I've been

17 farming organically since 1979, and I've been

18 certified since 1980. I have devoted my life

19 to the development of organic farming systems.

20 I represent Tilth Producers of

21 Washington, a state-wide association of

22 organic and sustainable growers, researchers
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1 and agricultural businesses. Our growers

2 represent a wide diversity of crops, regions

3 and scale across the state. We are asking the

4 Board to approve the Crops Subcommittee

5 proposal providing an extension of the use of

6 tetracycline in tree fruit until October 2016.

7 This time table supports the

8 growers, and ultimately consumers, who both

9 want safe, healthy food, as well as supporting

10 family farmers and rural communities, which we

11 believe is the backbone for a sustainable

12 farming system.

13 Many consumers have been misled by

14 the lies perpetuated by consumer groups that

15 presumably have their best interest at heart. 

16 The use of antibiotics in organic agriculture

17 is far too complicated to explain in 30

18 seconds. Distilling it to erroneous

19 statements does much harm to our industry.

20 "It's hard to believe, but every

21 time you bite into an organic apple or pear,

22 you get a mouthful and a gutful of
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1 antibiotics." This doesn't help any of us. 

2 Rather than guiding consumers to

3 an understanding of how and why antibiotics

4 are used, that they are based on naturally5 occurring compounds, that the industry is

6 working tirelessly to find alternatives to

7 these exceptions, these groups have instead

8 presented antibiotics as evil, ignoring the

9 truth that may be found in the carefully

10 developed rules of the Organic Foods

11 Production Act.

12 The original language of OFPA

13 specifically allowed limited and restricted

14 use of antibiotics in both livestock and

15 cropping systems. This allowance was not a

16 loophole. It is based on a national dialogue,

17 which is based on science, review and process,

18 all of which are transparent and in the public

19 record.

20 We believe it is a disservice to

21 consumers to have complicated issues reduced

22 to sound bites. The reason that less than one
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1 percent of Americans are farmers has something

2 to do with the risks and the amount of work it

3 takes to operate a successful, sustainable

4 farm.

5 As growers grapple with the

6 constant realities of farming, even informed

7 citizens don't really understand what it takes

8 to produce food and stay in business. We

9 believe that the American people don't want to

10 do farm work for five or ten dollars an hour,

11 and the alternatives are relying on imported

12 food.

13 Consumer and environmental

14 organizations should be educated and taking

15 action about the most important causes of

16 antibiotic resistence, which are non17 therapeutic use of antibiotics in livestock

18 feed and injectables, and in the regular,

19 routine use of anti-microbial soaps used by

20 consumers today.

21 At the core of Tilth's mission in

22 Washington is the promotion of ecologically
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1 sound and economically viable farming

2 practices, that improve the health of our

3 communities and natural environment. We

4 educate growers and support efforts to allow

5 for the continued expansion of organic and

6 sustainable agriculture.

7 These issues are complicated. The

8 work that all of you do, NOSB and NOP staff,

9 is important and thankless. With only one

10 percent of Americans choosing to struggle

11 daily with nature and the uncertain markets to

12 provide healthy, fresh food, our culture has

13 lost the insight into what it takes to create

14 a sustainable food system within sustainable

15 rural communities.

16 I would argue that until you see

17 your life work die in front of your eyes, you

18 really don't understand what it takes to

19 invest your life into growing food. I've

20 committed my life to making our food system

21 better. I left my farm 300 miles to the north

22 to speak on behalf of farmers and the
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1 communities they live in.

2 We share the same commitment to

3 organic agriculture, but I also want to speak

4 to the commitment that the people in our

5 orchards, who are working to do better by the

6 rest of us. I hope we continue to provide our

7 commitment to ensure that organic farmers have

8 the necessary tools to succeed. Thank you.

9 CHAIRMAN STONE: Thank you very

10 much. We appreciate you driving those 300

11 miles. That's one reason we moved the meeting

12 around the country, to have access to voices

13 like yours. 

14 Questions? All right. Thank you

15 very, very much for making the effort to be

16 here. Jeff Falen to the podium, and Michael

17 Crupain on deck. 

18 MR. FALEN: Good day. My last

19 name rhymes with that of Sarah Palin. I have

20 found a use for a politician. So it's Falen,

21 thank you. 

22 My wife and I own and operate
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1 Persephone Farm, where we raise 15 acres of

2 organic vegetables and eggs two hours south of

3 here. When I moved onto the farm in 1985, I

4 entered a depleted landscape. By adhering to

5 organic principles of crop rotation, cover

6 cropping and biodiversity enhancements, we

7 have seen dramatic improvements in the health

8 of the farm ecosystem.

9 These practices have resulted in

10 higher quality produce, improved soil tills, 

11 reduced fertilizer usage, a stable pH, greater

12 cold tolerance in our crops, and elimination

13 of problems with lepidoptera and aphids. 

14 At the same time that we are

15 witnessing these improvements, I became aware 

16 that some other organic growers were relying

17 more heavily on inputs, and giving minimal

18 regard to organic practices. We are currently

19 participating in a case study analysis of

20 several West Coast organic farms that use a

21 systems approach.

22 This study, sponsored by Oregon
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1 State University, hopes to document the

2 positive changes that organic practices can

3 bring to the farm as a way to encourage other 

4 growers to focus more on practices and less on

5 materials.

6 It is my belief that the NOP

7 should assist in this effort by pressuring

8 certifiers to encourage growers to view their

9 farms as a living, breathing organism, rather

10 than a substrate to which various materials

11 are applied. The focus on materials offers

12 band-aids to problems that often can and

13 should be solved through good practices.

14 Inputs are sometimes needed, but

15 more band-aids encourage growers to gloss over

16 deeper problems. I admit that I don't know

17 enough to make a science-based argument

18 concerning the materials before you. I hope

19 you carry more knowledge than I do to your

20 decisions. But I ask you to weigh heavily

21 some basic principles of necessity,

22 transparency and human health. 
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1 I recently spoke with an organic

2 pear and apple grower who does not use

3 antibiotics for fire blight control, relying

4 instead of resistant varieties. He also gave

5 me information which I'm sure you're aware of,

6 of research results showing effective

7 biological controls as an alternative to

8 antibiotics.

9 This is one data point, of course. 

10 But I think it's important to remember that

11 many people, including myself, are alive today

12 because of these drugs, and I have personal

13 experience with antibiotics losing their

14 effectiveness.

15 If there truly is an effective

16 alternative, why take the risk of human

17 pathogens developing resistance to

18 agricultural antibiotics? I ask you to end

19 their use in organic agriculture as soon as

20 possible.

21 And not that polyoxin D should be

22 left out -- I haven't heard many people talk
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1 about it -- so I hope you will consider that

2 broad spectrum fungicides harm beneficial

3 fungi as well as harmful fungi. More

4 importantly, is it appropriate to use a

5 material for which some of the ingredients and

6 processing are a secret?

7 The people who purchase and eat

8 our produce value transparency. So I feel it

9 my duty to advocate for them. I ask that this

10 petition be denied until more information

11 about the material is made available. 

12 I appreciate the role the NOSB

13 plays in maintaining the integrity of organic

14 farming. I don't envy you for the judgments

15 you have to make.

16 I hope you will ask of these

17 materials, is this an unnecessary band-aid

18 solution, or does it contribute to the NOSB

19 definition of organic agriculture as, and I

20 quote, "an ecological production management

21 system that promotes and enhances

22 biodiversity, biological cycles and soil
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1 biological activity." It is based on minimal

2 use of off-farm inputs, and on management

3 practices that restore, maintain and enhance

4 ecological harmony?

5 Thanks for listening. Whoa. 

6 Right on time.

7 CHAIRMAN STONE: Pretty good. 

8 Terry, I don't know about that one. Thank

9 you, Jeff. Questions? Very good. Thank you

10 for being here.

11 MR. FALEN: Okay.

12 CHAIRMAN STONE: Michael Crupain,

13 please correct to me of the mispronouncing of

14 your name, and Jessica Shade is on deck.

15 DR. CRUPAIN: Good afternoon. My

16 name is Dr. Michael Crupain. You got it

17 right. I'm from Consumers Union and Consumer

18 Report. So I work with Dr. Urvashi Rangan,

19 and I direct the daily operations of our food

20 safety and sustainability center. 

21 I'm a physician licensed in the

22 State of New York. I'm board-certified in
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1 preventive medicine. I have a Master's in

2 Public Health. I teach graduate and

3 undergraduate students at Johns Hopkins

4 University. And I've come here today to talk

5 about what is considered to be one of the

6 world's most pressing public health problems,

7 antibiotic resistance.

8 This problem is a major focus of

9 our work at Consumer Reports, as well as other

10 groups and government agencies, numerous

11 medical societies, and is a topic that I

12 lecture on at Johns Hopkins. 

13 I want to stress that the basic

14 science around antibiotic resistance is not

15 controversial. Further research is always

16 helpful, but we know enough right now and

17 don't need any more research to understand the

18 dangers of using antibiotics in agriculture.

19 So let's start with the basics. 

20 Antibiotics are drugs that either kill or

21 inhibit the growth of bacteria. Prior to the

22 1940's, we had very few useful tools to treat
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1 people who had antibiotic-resistant

2 infections. Back then, hospital wards were

3 filled with people who suffered and died from

4 infections that have now become relatively

5 simple to treat.

6 Antibiotic resistant bacteria make

7 treating those simple infections much more

8 complicated. These organisms are able to

9 survive and flourish in the presence of these

10 antibiotics that would normally kill them, or

11 stop their growth, and infections with

12 antibiotic-resistant bacteria can prolong

13 human illness, increase suffering and increase

14 the risk of death. 

15 To compound the problem, each day

16 we use antibiotics more and more resistance

17 develops, while at the same time each year we

18 introduce fewer and fewer new antibiotics. 

19 Antibiotic resistance occurs when bacteria

20 acquire genes to give them the ability to

21 resist the power of these drugs. This can

22 happen spontaneously when genes mutate, but
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1 more commonly can occur when bacteria share

2 these genes with each other, and as Dr. Morris

3 said, they're very promiscuous.

4 Antibiotic-resistant bacteria is a

5 normal part of the evolution of bacteria. 

6 However, the process is accelerated by the use

7 of antibiotics, and greatly accelerated by the

8 inappropriate use of low doses in antibiotics.

9 Antibiotic use promotes the

10 development of resistant bacteria in all

11 venues. This includes hospitals, clinics, the

12 community, animal agriculture and orchards. 

13 The environment including orchards is filled

14 with bacteria, and they are able to share this

15 resistance readily with each other. 

16 So we must consider resistance

17 that develops anywhere in any of these

18 settings a major public health threat, and of

19 course the prevalence of antibiotic-resistant

20 genes in our environment, the more of those

21 there are, the more likely there are to be

22 resistant bacteria that can make people sick.
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1 Tetracyclines are a highly

2 important class of drugs for human medicine,

3 and we must do everything in our power to

4 limit their use so as to prolong their

5 efficacy in treating human illness.

6 The science of antibiotic

7 resistance, again, is not new. In 1945,

8 Alexander Fleming received a Nobel Prize for

9 his discovery of the antibiotic penicillin. 

10 In his Nobel address on penicillin, he said,

11 and I'll read it to you:

12 "The time" -- it's better with a

13 Scottish accent -- "The time may come when

14 penicillin can be bought by anyone in shops. 

15 Then there is a danger that the ignorant man

16 may easily under-dose himself and by exposing

17 his microbes to non-lethal quantities of the

18 drug, make them resistant."

19 Here is a hypothetical

20 illustration. Mr. X has a sore throat. He

21 buys some penicillin and gives himself not

22 enough to kill the streptococci, but enough to
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1 educate them to resist penicillin. He then

2 infects his wife, Mrs. X. She gets pneumonia 

3 and is treated with penicillin.

4 As the streptococci are now

5 resistant to penicillin, the treatment fails. 

6 Mrs. X dies. Who is primarily responsible for

7 Mrs. X's death? Mr. X, who negligently used

8 penicillin, and changed the nature of the

9 microbe.

10 We all have a responsibility for

11 the development of antibiotic-resistant

12 bacteria. One way consumers should be able to

13 lessen this is by buying organic.

14 Organic food is believed by

15 consumers to be produced without the use of

16 antibiotics, and we need to make sure that the

17 label is consistent and lives up to this

18 expectation. That's why we support the

19 expiration in 2014. 

20 CHAIRMAN STONE: Thank you. 

21 Harold.

22 MEMBER AUSTIN: First off, I've
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1 got a very bad allergy to penicillin, as does

2 my son. It's been probably passed down

3 through our family, not something that we've

4 come into contact with out walking about and

5 stuff. But that's not my question. 

6 You kind of made a broad-brush

7 approach, and a referral to the tetracycline

8 in orchards, to the resistance and the amount

9 of bacteria, stuff that is, you know, that's

10 out there, physically out there, that we're

11 going to -- we could build up some resistences

12 and tolerances to. 

13 What's that based on? Is it from

14 personal experience?

15 DR. CRUPAIN: It's based on basic

16 science. We know that there's bacteria

17 everywhere. We know from the literature that

18 there's bacteria in orchards. There's lots of

19 studies looking at tetracycline resistance in

20 orchards, or some studies. But there's

21 bacteria everywhere. So we know they're

22 there, and if they're there, they'll become
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1 resistant.

2 MEMBER AUSTIN: Okay. But, you

3 know -- okay. Let's just leave it at that.

4 DR. CRUPAIN: We don't ask

5 questions like -- we don't measure the speed

6 of light in the Hilton in Portland compared to

7 the Hilton in Washington, D.C., because of

8 basic science.

9 CHAIRMAN STONE: All right. Thank

10 you very much. Jessica Shade to the podium. 

11 Angela Vasquez didn't sign in. Before uou

12 start Jessica -- Elizabeth Whelan? Didn't

13 sign in either. Rick Walsh. Rick did. I

14 think Rick is here. Rick on deck, please. 

15 Okay. Thank you, Jessica. Go ahead.

16 MS. SHADE: Hi. My name's Jessica

17 Shade, and I'm the Director of Science

18 Programs for the Organic Center. My Ph.D. is

19 from UC-Berkeley in integrative biology. So

20 my comments are from a scientist's

21 perspective, and I agree with the testimony of

22 others here that the use of antibiotics needs
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1 to be phased out of organic agriculture.

2 I had the good fortune of being

3 able to visit the field testing sites with Ken

4 Johnson, and it looks like if we can get

5 farmers to adopt the non-antibiotic

6 integrative management systems, the new

7 products, when used in combination, could be

8 as effective, if not more effective, than

9 oxytetracycline at managing fire blight.

10 I come at this from a field

11 biologist's perspective. My dissertation

12 focused on field biology, and as such, I'd

13 like to stress the importance of allowing time

14 for testing in the field and farmer education

15 in the phase-out process.

16 For field testing results to be

17 deemed replicable and trustworthy, the studies

18 need to be carried out over several years. 

19 Unfortunately, biological field studies are at

20 the mercy of the environment. So any year

21 with fluke weather patterns or biotic

22 anomalies could give unreplicable results.
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1 The work that's been done at

2 Oregon State University is excellent, but

3 farmers aren't going to trust a single year of

4 data. They need more when their livelihoods

5 are at stake, especially since the 2013 season

6 will be the first real scale-up and test under

7 commercial conditions of Blossom Protect, and

8 Previsto hasn't even been registered yet.

9 Additionally, the dissemination of

10 scientific results does not happen

11 instantaneously. The non-antibiotic methods

12 for preventing fire blight require the

13 integration of multiple products to be applied

14 at specific floral stages throughout the

15 growing season, and education and training are

16 going to be crucial for the success of these

17 practices.

18 This is not unique situation. 

19 These issues are important for the success of

20 all scientific studies. Too often the step

21 between science and educating the public is

22 ignored, and then you have a situation where
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1 the research results aren't getting to the

2 audience that they're targeting.

3 Without taking the time to test

4 the management strategies in the field and

5 educate farmers about the integrated

6 techniques they need to implement to

7 successfully prevent fire blight without the

8 use of antibiotics, these methods will not be

9 adopted and we're in danger of losing organic

10 apple and pear farmers to conventional

11 farming.

12 Our goal is to decrease the use of

13 antibiotics. But if we don't take the time to

14 fully test the new product and educate growers

15 on how to use them, our good intentions may

16 backfire. So thank you so much for listening

17 to me. I know it's been a long day.

18 CHAIRMAN STONE: Thank you,

19 Jessica. 

20 Questions? Thank you very much. 

21 You're welcome. Rick Walsh to the podium and

22 Marty Mesh on deck.
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1 MR. WALSH: Hello. My name's Rick

2 Walsh. I'm a farmer down in Klamath County,

3 about five and a half hours south of here in

4 Southern Oregon, and I'm here today because I

5 want the NOSB to uphold principles of organic

6 production in agriculture. 

7 I'm particularly concerned about

8 the allowance of tetracycline for the control

9 of fire blight. If antibiotics are consistent

10 with organic principles, why are they allowed

11 only in apples and pears? Antibiotics are not

12 allowed for my vegetables I grow, not for

13 chickens, cows, pigs or any livestock.

14 I believe that antibiotics should

15 be eliminated from all agricultural, organic

16 agricultural now. My customers support my

17 farm because they do not want food grown with

18 antibiotics or other synthetic material. They

19 question me quite often on this.

20 Consumers who learned about

21 antibiotics are used in organic apples may

22 decide to stop buying organic apples. They
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1 may also decide to stop buying organics

2 altogether, because they lose their trust in

3 organic certification. That hurts all of us

4 organic farmers.

5 I was a conventional farmer before

6 I started this. I was growing about 1,000

7 acres of potatoes, hay and grain, and the alar

8 scare come along with the apples. All of a

9 sudden, the apple industry was hurt pretty bad

10 financially, and that tells me there that

11 consumers do care what they have, are getting

12 in their food.

13 Some orchards claim that

14 antibiotics are essential for apple and pear

15 production, but this is not the case. 

16 Orchardists in Europe do not use antibiotics

17 on their crops. With so many orchardists can

18 succeed without antibiotics, it is time to

19 require all organic producers to abandon

20 antibiotics.

21 There are cultural controls,

22 natural materials and biological controls
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1 available, like the kind that I use in my

2 operation, and this is what organic farmers

3 should be using. Unfortunately, using

4 antibiotics may be simpler, easier and cheaper

5 than prevention.

6 I became an organic farmer partly

7 because I was concerned about the effects of

8 pesticides on human health. I'm also

9 concerned about the effects of antibiotics

10 used on human health. In areas with intense

11 apple production, antibiotics can be sprayed

12 into the air over thousands of acres of

13 orchard.

14 This exposes the farm workers to

15 the antibiotic residue on the trees, and

16 exposes consumers to antibiotics residue in or

17 on the fruit. I do not want to see farmer

18 workers or consumers exposed to antibiotics. 

19 I ask you to please reject this petition and

20 take actions to take antibiotics out of this

21 organics. 

22 I know that it sounds like I'm in
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1 a minority here, as being outside of one

2 saying take it out and not extend it. As

3 being a farmer and an organic farmer, I would

4 say that Mr. Mandley out in the Midwest had a

5 pretty good solution, you know.

6 Take it out of production, take it

7 out of the organic production for a year if

8 they use the product, and that will give the

9 consumer confidence that they're not getting

10 antibiotics in their food supply. Thank you

11 for allowing me this time.

12 CHAIRMAN STONE: Thank you, Rick,

13 for taking, making the effort to drive the 5-

14 1/2 hours to be here, and the Board was

15 listening closely.

16 MR. WALSH: Thank you.

17 CHAIRMAN STONE: Are there

18 questions? Jay.

19 MEMBER FELDMAN: Ditto. Thank you

20 so much for coming. I'm interested in your

21 perspective on the agricultural community,

22 because we're hearing these different points
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1 of view, and sometimes I think if you dropped

2 into this room from maybe another planet or

3 even another county, you might think that

4 folks don't get along too good.

5 So I'm wondering what your

6 perspective is in terms of the environmental

7 community overall. Why do we have these

8 differences of opinion on an issue like this,

9 which some people see so clearly on one side,

10 and some people see so clearly? You seem to

11 have a pretty clear vision of how you view the

12 situation.

13 MR. WALSH: In my situation, I

14 take it like the buying organic seed to plant

15 in your farm. When we first started it,

16 buying, you had the option of buying

17 conventional, non-treated and had this, and it

18 was always cheaper. So I kind of did that.

19 Pretty soon, the certifier says,

20 hey, you're not buying much organic, and he

21 says -- and kind of said you need to start

22 buying more organic seed. So I started buying
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1 a little more, but it was always in the back

2 of my mind. Boy, it's a lot cheaper to buy

3 this, and then it comes down that you're going

4 to have to buy organics, and we started buying

5 the organic seed.

6 At that time, I started realizing

7 if I were not going to buy the organic seed,

8 that meant that he, the producer out there, is

9 not going to produce it, because there was not

10 a demand.

11 If I bought it and all my other

12 farmers bought it, well, then the price of

13 that seed would come more in line with

14 conventional seed, and then it's there. I'm

15 seeing that now, is that there's more

16 conventional.

17 I think a lot of the tetracycline

18 that they're using, it's an easy way out to

19 me. I don't quite understand it. I don't

20 grow fruit, a lot of fruit. But to me, I know

21 that I've went to a lot of schools and done a

22 lot of workshops on it, and teas, they're
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1 talking about using your teas and your

2 preventative programs to control your

3 diseases.

4 I use a lot of that in my

5 production of food now. It's just like if I

6 use a PyGanic, it's the last resort. If I

7 mention I used PyGanic at the farmers market,

8 well, what's that? Well, that's a pesticide

9 and, man, they just back up. So there's a lot 

10 needs to be education to the consumer what it

11 is, and that's what we have to do.

12 CHAIRMAN STONE: John.

13 MEMBER FOSTER: What is it that

14 you grow down there?

15 MR. WALSH: Well, we have about 15

16 acres of certified organics, and we're in the

17 high desert. But we are kind of in a certain

18 situation. We have a lot of geothermal, and

19 so we have an acre of certified organic,

20 geothermal heated greenhouses. 

21 So we support a CSA year-round. 

22 We grow tomatoes and strawberries and herbs
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1 and microgreens and broccoli and cauliflower

2 all year long, and support about a 50-member

3 CSA down there. Plus we sell to the co-ops

4 down in Southern Oregon.

5 MEMBER FOSTER: I used to do a

6 bunch of work down there. What town or what

7 city?

8 MR. WALSH: Klamath Falls, Oregon.

9 MEMBER FOSTER: Klamath, okay. K

10 Falls.

11 MR. WALSH: Yeah. 4,200 feet. It

12 snowed two days ago.

13 MEMBER FOSTER: And so did I hear

14 right, no apples or pears right now?

15 MR. WALSH: No. I've just done

16 some research, and I'm thinking about trying

17 to put them into the grow tunnels inside, and

18 put the heat in the ground about 36 inches

19 down, and seeing what would happen there, and

20 what it wouldn't do.

21 MEMBER FOSTER: Oh, cool. Nice. 

22 Just one more. How did You hear about the
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1 meeting to come, because --

2 MR. WALSH: I'm a member of the

3 Cornucopia Institute, is where I heard about

4 it.

5 MEMBER FOSTER: Thank you so much.

6 MR. WALSH: I enjoy you folks

7 coming down here, at least coming out to the

8 West Coast and giving us an opportunity to

9 speak. It's kind of exciting.

10 MEMBER FOSTER: All right, thank

11 you.

12 CHAIRMAN STONE: Very good. Did a

13 good job as well. Appreciate you making the

14 effort to be here. Last, and certainly not

15 least, Mr. Marty Mesh.

16 MR. MESH: My name is Marty Mesh. 

17 I'm the Executive Director of a non-profit,

18 Florida Organic Growers, and the legal name is

19 Florida Certified Organic Growers and

20 Consumers, and I always took very serious my

21 responsibility to balance the needs of being

22 an organic farmer versus obviously my own self
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1 and my own family eating organic products, and

2 what consumer expectations were.

3 We operate a certification program

4 called Quality Certification Services,

5 accredited in the original accreditation

6 round, and I started farming organically in

7 1973, after spraying apples in 1972 and the

8 lightbulb going off.

9 A lot of other folks have done

10 really good articulated comments, well

11 written-out, and so you won't hear that from

12 me. But know that I'm the last speaker, so

13 the exit strategy is nearby.

14 You know, I want to support Anne's

15 comments. I heard Anne speak, and a lot of

16 consumer comments as well, and I know that you

17 guys are in a hard position to be in. I

18 didn't want to not support George's

19 aquaculture presentation. It occurred to me

20 that for over -- since the last millennium,

21 I've been up here talking about organic

22 aquaculture. To see George's time line, then
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1 you go, wow, it's been that long since the

2 last millennium, was kind of hard to see and

3 hard to know that it's languished for so long.

4 But getting to the apples, the

5 middle suggestion that you all heard was 2016,

6 that middle ground, and then what I was

7 attracted to was the farmer who brought up,

8 really referenced 205.672, the government9 mandated spray program section, that says, you

10 know, if you use a material under a

11 government, if you sprayed under a government12 mandated spray program, it can't be sold as

13 organic, but you don't lose the certification

14 of it. 

15 I believe that the Board could

16 look at that option after 2016, you know,

17 while products are waiting for registration,

18 and look at it and say if the material is

19 used, then you can't sell it as organic,

20 period, and relieve the consumer expectation

21 that the material is not used, and have the

22 farmer take a bit of risk.
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1 Then as materials are registered,

2 actually get registration, extension

3 publications are published, growers get the

4 messages from the researchers in 2017-2018,

5 take it, prohibit it totally.

6 So that was -- I was drawn to his

7 suggestion and thought it was worthy of your

8 deliberation and consideration. And with

9 that, we'll get you all out of here early,

10 unless you all have got questions. I saw

11 Jay's light bulbs going off when I was saying

12 something, so I'm sure he's got a question.

13 MEMBER FELDMAN: I'll talk to you

14 later.

15 (Laughter.)

16 CHAIRMAN STONE: Great. All right. 

17 Thanks, Marty. I appreciate you being here.

18 MR. MESH: All right.

19 CHAIRMAN STONE: So, Board

20 members, did really good. We ran about 45

21 minutes long, maybe closer to -- yeah, 45. 

22 But we did great. I think I appreciate the
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1 questions. The audience did a great job of

2 presenting and responding to questions. So a

3 couple of just scheduling.

4 First of all, if there's someone

5 from the Portland area that can direct me to

6 a cigar store. My oldest daughter had a

7 healthy baby boy just about a couple of hours

8 ago. 

9 (Applause.)

10 CHAIRMAN STONE: I want to remind

11 everyone that just outside these doors,

12 there's the organic apple and pear tasting,

13 hosted by OTA, OMRI, Oregon Tilth and several

14 others, and a reception in the adjoining room

15 just down the hall.

16 Any Board members have anything we 

17 need to bring before we adjourn for the

18 evening or recess for the evening? With that,

19 we will be here promptly at eight o'clock in

20 the morning. 

21 (Whereupon, the above-entitled

22 matter went off the record at 6:25 p.m.)
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Chairperson 1:12

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challenge 117:14

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challenged 287:5

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challenges 55:16

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438:16

champion 489:15

chance 115:19

145:8,9 204:4

255:22 274:7

305:21 402:22

405:19

chances 145:10

360:4

Chandler 279:21

change 12:2 28:3

85:3 103:9 122:2

151:18 190:10,13

210:12 214:20

253:6 314:18

354:5 435:2

changed 11:20

37:10 94:6 97:4

214:8 267:7

287:22 473:7

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changes 9:22 10:18

10:19 11:3,3,22

12:1,15 29:7

84:22 94:16 105:3

279:7,9 287:6

396:1 489:9 497:2

changing 10:19

180:10 302:17

channel 36:2

chaotic 136:14

characteristics

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Charlie's 380:7

386:20,22 387:7

chart 170:9 411:14

466:21

cheaper 163:6

513:4 515:18

516:2

cheat 442:20

check 273:10

280:20 305:17

404:16

checkboxes 223:8

checked 132:15

404:12

checks 90:6

chelated 150:11

chemical 66:18

74:1 207:12 252:7

269:20 274:5

384:12 389:1

chemicals 74:4

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chemistry 250:20

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chemotherapy

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cherries 342:1

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chick 160:11

chicken 144:2

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180:13,17 237:5

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children 346:8,9

458:15,16

Chile 398:17 485:2

chill 401:19 405:10

chimera 119:14

Chino 186:12

chitin 329:2,18

334:13 335:3

336:13

chitinase 329:11,20

chitinases 329:9

chlorine 99:9,10

choice 221:6

240:10 362:15

368:21 395:12

455:16

cholera 270:22,22

choose 185:1

346:21 369:2

430:1 481:10

choosing 91:3

494:10

chose 179:11 287:2

chosen 411:21

Christiano 208:3

Christopher 46:6

chronic 213:7

chronology 47:14

cigar 523:6

circle 51:2

circumstances

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citation 176:10

citations 279:18

cite 139:7 143:10

cited 415:15

cities 171:4

citing 279:18

citizen 23:5 27:11

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citizens 493:7

city 518:7

claim 30:18 302:11

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claims 47:12

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class 52:8 504:2

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clay 206:4 248:8,16

clean 206:19

clear 118:19

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172:1 173:6 175:6

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clearance 76:19

clearly 232:22

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clients 217:19

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climate 228:6

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climates 201:17

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clinical 69:5 133:20

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clock 5:17 195:19

close 165:1 252:16

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closely 48:18

105:22 106:3

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closer 247:17

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522:21

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closing 104:22

105:17,19

cluster 239:1

coalition 291:6

357:15 379:21

382:13 454:2,3

coalitions 169:9

coast 61:6 62:17

171:3 361:3,9

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coastal 295:15

404:3 468:1

cockroaches 336:3

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code 344:13

codes 119:20

codling 468:18

cognizant 97:6

coincidal 328:1

Coke 11:8

cold 72:12 189:6

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cold-blooded 72:11

Colehour 1:17 7:1

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18:16 36:21 37:12

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Coleman 365:10

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coli 212:9,11

234:17 239:6,9

coliforms 237:7

collaborate 384:6

collaboration 8:2

19:7 20:16 21:17

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128:12 130:5,14

collaborative 127:8

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collected 206:16

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collective 128:18

Collectively 381:2

College 216:4

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colonize 473:15

color 5:7 463:20

Colorado 204:12

colorful 463:12

column 83:8 462:6

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columns 462:5

combination 85:1

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combine 146:20

combined 146:9

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come 46:21 47:21

60:16 68:12 78:13

106:7,8,9 107:2

115:21 121:16,21

123:14 125:6

126:11 127:2

132:10 142:8

161:4 167:5

189:22 191:20,21

194:14,15 232:10

243:12 244:12

256:12 259:3

264:20 287:7

306:13 316:22

320:13,22 340:16

378:18 379:3

410:18 428:19

431:20 432:5

435:18 456:1

473:19 474:16

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60:11 81:16

138:10 143:19,21

156:11 162:1,7

172:15 177:19

199:17 240:8

475:15 481:8

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460:4

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Comice 399:21

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coming 5:6 14:11

36:19 53:15 54:2

57:18,19 74:17

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191:13 217:9

242:21 245:15

256:7 264:4

265:13 271:20

280:17 331:3

381:17 405:17

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462:18 474:13

476:20 514:20

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88:16 92:21

102:15 105:19

107:13 110:9

111:14 112:13,14

113:17 114:20

122:14 129:17

131:21 132:1

133:2,9,14 134:6

172:20 173:3

181:6,22 186:20

192:10 280:8

283:3 296:20

298:7 311:15

314:12 315:21

340:11,22 344:13

383:21 425:1

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commenters 21:13

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commenting 26:21

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27:2 28:22 41:19

77:18 93:13

102:18 105:18

113:18 114:12

115:2,20 122:21

123:9,19 124:8,15

144:14 147:18

175:8 181:19

186:17 218:19

281:10 290:14

291:14 294:20

297:22 298:15,19

340:21 344:15

345:4,5 347:17

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Comment/Livest...

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Comment/Policy

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commerce 112:5

commercial 44:6

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Commission 398:9

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commitment 367:9

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committee 4:14

11:13 12:7,11

20:2 28:21 79:1,4

99:2 107:3 111:1

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committees 11:4

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commodities

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commonly 270:11

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389:2 398:13

433:13

companion 223:11

company 27:13

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187:15 200:5

202:14 207:12

251:3 274:6

284:17,20 291:6

310:22 341:22

379:16 386:3

387:8 480:18

compare 85:13

compared 76:7

136:2 296:13

507:6

comparison 140:1

compatibility

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315:11

compatible 96:3

compete 233:18

481:15

competing 50:7,10

50:13 59:10 201:2

competition 63:6

174:3,7

complaint 104:18

complete 114:22

135:9,10 138:1

143:6,11 145:17

150:14 370:8

completed 49:9

110:6 156:4

282:19 299:3

414:11 415:2

completely 60:18

96:5 191:19

255:11 349:15

352:22 399:22

453:6

completion 299:6

complex 74:13

120:18 121:9

127:14 137:3

179:5 287:20

288:6,16 306:11

306:13 461:7

complexity 118:6

128:10 181:9

368:1

compliance 219:11

224:18,21 226:12

487:9 488:2

Compliant 487:11

complicated 116:7

118:18 121:18

125:21 127:14

389:22 432:18

491:17 492:21

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complications

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complies 76:2

comply 226:13

347:9 376:16

complying 368:17

component 153:19

222:5 328:18

components 102:5

279:2

composition 279:7

compost 76:1 80:2

composting 223:12

compound 208:8

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compounds 325:15

409:4 492:5

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comprehensive

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compressed 98:8

comprised 379:22

compromise

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compromising

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concentration 90:5

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concentrations

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concepts 122:11

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178:21 184:1

205:19 238:9,18

238:19 239:12

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244:14 249:22

255:15 258:19

261:14 277:6

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concerned 23:8

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concise 383:14

concluded 338:10

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condense 9:18

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conditionally

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conditions 72:21

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conducting 401:13

conference 47:22

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conferences 227:8

confidence 267:17

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confidential 120:1

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confirmation

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confluence 306:14

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Conn 310:21

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conservative 93:19

conserve 170:15

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conserving 171:10

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129:16 130:2

330:6,17 395:2

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considering 21:9

21:12 27:2 104:6

283:21

consistency 122:18

297:3 315:12

consistent 47:8

108:18 137:19

222:12 388:9

392:8 505:17

511:9

consistently 478:17

consists 12:7 45:13

conspiracy 484:1

constant 493:6

constituents 435:3

constitutes 120:17

286:3

constraints 322:20

constructed 97:9

consultant 141:15

464:19

consultants 225:15

Consulting 350:6

consume 60:12

consumed 64:15

consumer 169:11

217:10 300:12

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457:19 458:14

459:1 464:8 466:2

466:5,6 467:8

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500:17 501:9

514:9 517:10

520:2,16 521:20

consumers 135:19

217:21 297:2,11

302:1 305:6,12

343:11,11,20

344:20 345:2,5

349:14 351:12

354:11,16 356:21

357:9 358:3,7,11

360:9 363:9

365:22 367:18

368:5 370:1 374:8

374:8 382:21

385:17 386:8

392:2 395:17

432:2,11 433:7,18

435:5 438:11

440:4,5,19 443:4

445:7 457:10,17

458:1,1,19 482:2

482:10,20 491:8

491:13 492:2,21

493:20 500:17

505:12,15 511:20

512:11 513:16,18

519:20

consumes 368:11

consuming 82:15

448:8

consumption 46:20

47:3 95:15 164:9

189:14 380:20

contact 20:13

191:15 259:3

398:20 506:4

contacts 20:19

contain 347:5

contained 175:11

containment 72:21

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contains 157:13

422:7

contaminants 75:9

contaminated

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contemplate 90:10

contemplated 90:9

contemplating

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content 7:19 34:4

136:9

contentious 352:20

context 270:1,3

307:1

continual 31:1

continually 221:5

continue 68:13

103:8 104:13

106:5 123:4 126:4

130:20 184:17,22

185:1 231:12

303:3 316:19

367:17 368:3

369:20,22 394:15

397:8 438:19

495:6

continued 294:13

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298:14 306:3

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continues 128:17

469:10

continuing 184:19

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continuous 67:3

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continuum 377:13

contracting 479:15

contractor 159:5

contrary 47:7

169:19 297:16

442:17

contrast 361:8

contribute 207:4

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contributes 297:5

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339:16,17 340:1,3

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355:19 356:1

362:6 368:21

370:22 371:7

373:1,4 381:18

388:17 394:1

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427:3 429:5

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controlling 253:12

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controls 319:13

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371:19 372:19

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384:12 393:6

394:13 407:19

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convenience

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177:18 225:18

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420:18 427:5

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456:2 458:8,11

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283:5 342:21

432:13,14 434:1

conversations

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conversion 74:8,10

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convert 455:16

456:2

converted 54:14

convey 489:9

convinced 371:21

Coody 343:7 350:1

350:4,5 355:7

357:14 382:18

cool 266:15 518:21

Coop 290:17

cooperative 123:20

124:6 468:14

490:2

coordinate 384:6

coordinated 410:8

coordinating 131:4

131:5

coordination 486:3

coordinators 486:2

copied 99:19

copies 347:21

359:1

copper 90:3 137:13

200:4,6,9,13,17

201:21,22 202:4

202:13 203:20

249:11,13 250:13

250:16 252:8

264:15 267:20

268:21 269:7,12

271:20 272:18

273:17 303:17

318:20 319:4,6,9

319:11 322:2,15

327:14 362:3

372:18 399:4

403:19 406:11,13

449:1,6,20 470:11

473:20,20 474:2

488:13

coppers 247:12,18

273:19 327:4

copper-based

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copy 79:3 176:19

372:4

core 478:7 493:21

corn 63:5 101:12

157:11 187:14

Cornell 359:11

corner 408:17

cornerstone 380:19

Cornucopia 21:11

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24:21 27:10,19

28:22 29:22

122:20 167:8

296:5 297:12

370:16 372:4

374:20 378:22

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Cornucopia's 27:2

296:3

correct 33:13

154:16 177:1

255:11 329:7

350:2 371:8

409:14 418:11

419:14 485:9

500:13

correctly 459:10

correlation 256:22

417:22 418:13

Corvallis 197:9

cosmetic 200:20

332:20 333:6

cost 63:5 470:2

costs 105:3,14

393:12

Cougar 464:18

Council 111:19

counsel 13:9

count 34:8 344:9

counter 168:1

489:14

countries 129:13

205:16

country 174:18

217:18 370:1

416:7 444:9

484:20,22 485:3,8

495:12

country's 176:16

county 295:14

451:20,20 467:22

476:15 511:2

515:3

couple 31:14 63:17

95:11 104:22

161:21 194:8

196:2 213:3,10

234:5 266:3 275:8

277:7 279:18

310:4,20 385:1

400:8 403:15

431:22 465:7

472:14 523:3,7

course 87:4 105:11

169:13 172:8

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findings 119:9,11

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fine 8:18 11:14

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Fund 45:20

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Glenn 228:17

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GMOs 26:8

Gnaw 6:4

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141:17,19 143:8

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149:2 152:7 160:5

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190:13 197:4

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234:9 235:14

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307:12 309:18

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grass 186:4 225:9

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334:20 336:17,18

338:21 339:7,13

348:17 397:5

408:14 413:5

414:9 424:15

430:4 431:5

437:11 465:16

506:19

looks 35:20 55:11

55:16 56:8 193:1

328:7 341:5 401:7

508:4

loophole 30:22

492:16

loopholes 30:13

31:6

Lorraine 11:8

lose 183:5 389:11

394:13 456:1

463:6,21 481:11

512:2 521:13

loses 209:16,17,18

213:11

losing 295:2 369:4

382:6 456:4,6

463:9 480:5

498:13 510:9

loss 184:2 361:11

369:11 445:4

468:8 476:15

losses 369:2

lost 43:19 159:17

343:15 367:14

480:9 481:13

494:13

lot 4:6 8:22 9:20

34:3,5,7 35:2 51:7

56:11 57:11,12

66:7 68:18 71:16

72:8 90:22 98:17

100:12 118:5

132:22 143:20

144:3,3,6,9 148:9

151:17 154:17

159:8 166:15

167:18 189:2

198:21 200:1

201:2 211:6,17

232:5 236:9 240:9

241:21 242:13

245:22 248:19

252:15 267:2,15

267:16,17 272:22

274:1 283:12

285:2 288:17

317:15 318:7,18

319:6,8 321:9,19

322:7,17 323:9

335:6 338:1

356:20 358:2

364:7 390:15

403:21,21 404:4

404:14 405:10,18

421:9 432:18

457:19,22 460:9

460:12 472:6,12

516:2,17,20,21,22

517:4,9,18 520:9

520:15

lots 34:16 112:11

112:11 137:11

166:10 199:10

236:8 429:22

463:10 506:18

Louisiana 46:4

love 6:8 106:12,13

166:22

Lovera 424:21

429:14,16,17

435:4 436:16,20

438:10 440:6

441:3,7

loving 6:8

low 73:8 87:4

213:13 239:14

255:16,22 256:5

262:2 308:18

322:12 333:9

338:10 346:7

466:5 467:9 503:8

lower 136:5,8,9

214:22 361:20

362:1 408:16

466:16

lowest 67:19

lucky 56:16 150:17

ludicrous 171:19

lunch 107:12 193:5

194:4 195:6

196:17 271:21

341:20

lung 136:20

luxury 195:14,15

196:1

Lynn 343:7 345:8

350:1,4 355:2,4

357:5 358:14

365:2 382:18

435:1

lysine 112:19 114:8

143:4 147:10

148:15

L-methionine

153:22

M

M 178:5

Mac 1:12,15,22

32:17 44:14 77:19

105:7 106:20

107:17 108:2,22

109:17 115:15,16

116:1 192:12,14

196:16 309:19

459:9 484:10

machine 158:6

160:15 435:7

macroalgae 62:11

88:22

macrocystis 62:16

mad 178:6

Madam 192:9

magazine 188:6

magnitude 86:8

mail 372:5

mails 265:3

main 20:2 168:9,21

168:21 172:8

364:12

Maine 45:15 50:18

52:3 53:19 54:4

54:22 55:8 83:10

106:8,8,9

mainstream 439:14

maintain 15:20

39:21 70:9 76:21

100:8 475:13

500:3

maintaining 64:9

339:7 499:13

major 47:5 99:11

138:14 154:18,18

171:21 197:13

204:15 231:13

236:11 240:14

263:10,11 304:6

322:13 361:7

411:7 425:15

501:8 503:18

majority 29:5

125:21 237:5

281:15,18 288:13

290:15 291:10

292:6 294:13

296:4 297:16

301:12 302:15,21

304:9 305:8 310:5

312:10 325:18

364:14 380:3

majority/minority

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making 14:2 33:6

94:1 104:11 221:6

369:13 433:16

454:17 494:20

495:15 514:13

519:13

males 66:21

mammalian 67:10

95:22

man 504:15 517:9

manage 83:20

221:7 243:6 320:9

399:2 458:21

managed 74:15

371:22 447:9

management 67:4

71:3,17,19 73:9

73:15 76:4 81:21

99:19 185:19

197:16 207:3

220:10,15,19

221:11 223:11

224:7 226:4

227:17 228:7,13

295:21 321:7,8,12

352:14 356:2

367:16 373:13

383:10,15 384:10

487:12 499:20

500:2 508:6 510:4

manager 83:15

186:12 216:1,15

386:21

manages 125:15

managing 216:17

324:9 356:5 508:9

mandate 151:9

170:15 364:16

395:11

mandated 521:9,12

Mandley 429:14

441:15,17,18

446:22 447:19

448:14,16 449:5

450:2 451:6,17

452:5,13,21 514:4

Manley 441:16

452:22

manner 97:9 300:3

390:4

mantis 5:15
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manufactured

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manufacturer

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manufacturers

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manufacturing

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manure 76:1 210:7

manures 210:1,3

maps 74:19

Maravell 1:20

12:13 39:1 42:12

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159:21 160:4,17

181:21 185:8

262:13 265:16

375:18 376:21

412:2,6 413:3,14

413:22 415:3

448:19 449:22

472:2

March 248:14

310:19 331:17

332:1,4

Margaret 48:6

Marge 5:5

margins 333:8

marine 69:19,21,22

82:14 176:14

marked 298:12

markers 233:19

market 62:21 65:9

67:5 114:1 121:12

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193:11 216:16

318:18,19 333:9

382:7,11 388:12

400:21 419:8,18

425:20,20 427:18

427:20 451:5

475:16 480:11

481:16 482:11

517:7

marketed 47:11

108:10 332:22

marketers 354:11

marketing 1:1

433:3,5,7 478:5

marketplace 50:7

105:3 114:14,16

115:11 118:8

119:18 123:16

351:2 380:16

markets 74:17

427:22 494:11

marks 217:16

Marty 510:22

519:15,16 522:17

Maryland 229:14

masses 441:2

massive 461:2

Master's 229:3

501:1

match 48:9,10

100:18

material 8:13,21

18:10 28:1,7,19

29:2,6,13 122:10

122:13 140:22

199:14 200:1,3,4

201:21 202:3,4,13

202:22 203:2,20

206:4 220:6,13

221:20 224:21

227:14 246:9

247:21,22 248:20

251:16 252:7,8,19

259:6 260:10

270:2 272:18

273:2,10,20

274:10 277:12

279:7 284:4 290:2

301:3,14 306:6,7

307:4 311:22

315:2 317:18

318:3,8 319:1,10

319:19 320:4,11

320:14 324:11

325:3 326:12

328:7 338:14

340:7,16,19 341:5

341:8 351:14

353:14 373:9

378:8 384:8 402:3

409:12 437:20

450:16,18 468:9

469:15,19 470:1

470:10,13 473:4,9

473:11 475:4

486:4 488:16

499:5,11 511:18

521:10,18,21

materially 29:16

materials 14:10

18:17 20:7,17,20

21:14,18 28:15,16

30:5 42:18 44:1

45:4,4 78:18 99:1

99:3,10 109:6

200:13 222:3,14

223:21 246:13,14

246:17 248:8

251:18 253:4,19

268:22 273:3

276:16,17 283:21

290:10 299:12

304:2 305:11

309:20 315:19

317:15 318:17,18

319:14 320:17

321:20 322:9

324:2,8,16 325:5

325:19,20 327:5

327:13,15,20

328:1,2,3 352:14

353:5,11 356:1

366:19 369:3

372:18 374:16

397:8 401:14

402:1,17 408:10

409:13,21 412:14

414:15,18 422:15

431:5,7,13 432:8

434:13 435:9

437:4,11,17 438:2

448:21 463:8

468:13,13 470:15

471:14,17 475:12

488:12 489:10,14

497:5,10,11,18

499:17 512:22

522:1

material's 435:16

mathematical

241:4 258:20

261:9

mating 396:17,19

matter 107:6 125:5

194:19 300:17

339:6 342:11

475:2 523:22

matters 15:3 17:22

49:4 285:13

mature 464:16

maturity 154:22

155:2 157:20

343:18

maul 329:3

maximizing 24:20

27:20

maximum 68:3

83:20 157:16

Mayo 46:5

Mayo's 63:9

ma'am 166:20

192:17 370:5

379:8

McEVOY 2:12 5:1

35:21 102:7

153:12 285:19

McManus 211:11

213:18

meal 56:14 67:14

68:2,8,13 82:9,22

95:15,21 96:6

101:10 137:18

143:22 144:2

157:11 161:8

168:22 431:3

meals 147:15,15,16

149:9

meal/fish 69:18

mean 43:8 82:20

85:3 97:14 131:1

152:19 197:21

221:3 243:22

251:5 252:1 274:4

275:15 279:13

325:13 330:7

376:17 377:8,9

406:12 428:2

436:21 438:10

440:21 441:7

451:16 481:14

485:10

meaning 487:17

means 15:22 22:19

24:14 40:1 50:19

66:18 74:1 77:3

81:11 121:1 126:8

149:15 219:12

235:11 255:19

303:22 316:8,22

345:2 358:18

428:7

meant 348:5 516:8

measurable 345:1

349:11 409:15

measure 393:11

507:5

measured 81:15

measures 70:10,14

73:10 445:15

measuring 87:3

meat 138:15

143:22 144:5

147:15

meats 136:7 149:8

mechanism 14:3

15:1,21 17:3,14

17:20 23:14,22

25:13 29:18 39:22

307:9

mechanisms 36:8

media 35:16

medical 23:10
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Medicine's 230:15

medium 426:15

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meet 67:9 70:5

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meeting 1:4 4:4

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meetings 15:9,12

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meets 356:6

Melissa 2:16 43:7

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126:18 127:1

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Melody 453:1

457:14

Melody's 453:1

member 7:4 8:1,12

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13:3 18:7,15 22:6

23:4 27:9 29:5

32:6,15,16 33:16

37:8,14,22 38:3,6

38:12,13,14,15,16

38:17,18,19,20,21

38:22 39:1,2 40:5

40:8,12,15 41:4

42:1,2,3,4,5,6,7,8

42:9,10,11,12,13

48:7 79:10 81:3

84:7 85:16 87:17

89:1,17 90:12,16

91:13 92:9,11

98:2,20 101:7

107:17 108:22

109:2,5,10,14

115:15 116:4

131:12,22 133:6

139:4 140:18

146:8,19 147:6

148:18 149:22

152:6,13 157:2

159:2,21 160:4,17

165:18 166:1

172:20 173:19

175:1 176:6,20

177:2,4 178:13

181:5,18,21 184:5

184:12,21 185:6,8

191:8 192:11,22

193:7 196:16

204:3 215:21

228:16 230:15

242:18 243:10

246:7 249:15,17

251:8,13 252:20

253:21 256:9

257:13 258:10

260:4 261:22

262:13 265:16

268:18,19 269:16

271:15 272:9

274:18,20 277:17

278:15 279:17

280:1,4,13 281:11

281:16,21 283:4

283:11 284:6,8

285:12 286:9,11

301:10 305:16

310:16 311:17

313:5 314:14,15

315:14 317:12

324:20 325:2,8

326:4,20 328:22

330:2,13 334:4

335:9 338:19

340:9 348:4,21

349:3 355:4 357:5

363:14 364:10,12

370:6 374:13

375:18 376:21

378:12,16 384:2

385:3,13 390:9,19

391:5 395:21

396:16,22 398:8

403:4,12 405:2

412:2,6 413:3,14

413:22 415:3,12

417:7,15,21 418:8

418:12,15,17,21

419:3,15 421:12

422:8,11 423:1

424:7 427:14

428:10,14,17

434:21 435:22

436:17 438:6

439:20 440:21

441:5 446:17

447:15 448:12,15

448:19 449:22

450:11 451:14,19

452:8,18 454:1

457:15 472:2

474:12 477:3,11

482:15 484:10

505:22 507:2

514:19 517:13

518:5,9,13,21

519:2,5,10 522:13

members 1:14 7:12

10:7,9,12 12:11

13:7 16:19 18:3

20:8,12 24:5,11

24:14 28:6 29:11

29:12,19 30:18

32:8 33:11 34:15

41:19 43:20 78:8

79:5,7 93:1,9

118:13 130:12,19

141:12 186:16

195:13,21 243:3,8

283:7 285:20

286:1,2 342:15

380:6 381:2

382:12 383:19

384:5 407:14

432:16 442:8,21

454:4 480:17

485:21 490:14

522:20 523:16

membership 10:19

11:3 12:16

membranes 336:1

memo 430:12

Memorial 45:21

230:7

men 65:11

mental 44:4

mentality 373:18

mention 219:20

326:8 330:22

517:7

mentioned 9:11,20

10:8 31:15 35:21

66:1,17 85:9

129:11 144:9

150:15 239:2

269:10 295:19

323:15 336:2,11

349:5,6 409:21

454:3

mercy 508:20

Mesh 510:22

519:15,16,16

522:18

mess 473:21

message 435:3

messages 433:7

522:4

messy 274:1

met 220:12 299:21

315:8 459:13

metabolic 140:11

metabolism 140:11

metabolite 76:13

metagenomic

213:19

metallic 319:9

meter 73:14 81:2

86:9,20,21,22

meters 79:13 80:6

methionine 96:1

112:19 114:7

134:11 137:1,7

140:9,9 143:4

147:10 148:16

153:17,18,21

154:21 155:7,13

155:18 156:9

157:22 158:1

160:7 161:7

182:21 183:7,14

183:15 184:13

185:11 186:17,22

187:10,13,16,20

189:8,12

method 79:20,21

120:17 124:5

190:19 314:19

374:16 410:21

methodology

374:17

methods 42:19

51:6,13 67:1

71:17 77:7 116:3

116:10,18,21

117:1,9,13,17

118:2 119:14

121:2,8 122:4

123:3,7 125:12,17

126:8 130:22

227:10 381:13

384:10 481:5

509:11 510:8

methyl 140:10

Meyer 453:1,3

457:18 459:4

mic 4:21

Michael 347:1

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Michigan 178:14

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275:2,11,14,20

276:5,7 303:11

345:12 444:10,12

450:3 469:21

Michigan's 294:4

Mick 178:7,7

Mickey 178:8

microalgae 61:20

61:21 88:22

microbe 505:9

microbes 207:5

326:2 337:1

504:17

microbial 204:17

240:16 241:19

330:17 359:13

microclimates

304:4 401:15

476:17

microflora 328:18

328:19

micrograms

210:15 255:2

microgreens 518:1

micronutrient

89:19,22

micronutrients

88:7,11

microorganism

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microorganisms

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microphone 7:1

mid 199:5

middle 53:4 155:15

161:5 276:21

442:12,15 470:21

521:5,6

Midwest 362:16

442:1 444:18

446:11,18,19

451:11 514:4

mid-afternoon

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mid-summer 411:7

415:21

mid-80's 137:10

migrate 257:19

migratory 73:18

171:14

mile 234:12,16

476:9,10

miles 2:12 4:19,21

35:20 43:5 102:6

451:8 494:21

495:11

millennium 520:20

521:2

milligrams 255:4

million 188:19

210:14 254:18,22

257:3 293:13

349:7 380:2 381:3

454:15 478:11

millions 178:19

363:2

mimic 113:6

mind 29:8 125:5

150:6,12 152:15

163:16 240:8

283:18 302:18

316:1 331:3 351:6

354:2 516:2

mine 154:18

169:11 415:6

mineral 221:13

247:22

minerals 78:19

96:11 99:4 115:10

142:11 150:11,12

minimal 496:17

500:1

minimally 70:5

minimize 73:1 76:8

76:9,14 129:3

232:1 271:13

minimum 67:9

69:16 75:17 87:13

91:4 100:7,20

149:2 157:7

158:20 372:15

455:21

Minnesota 48:1

197:11

minor 189:17

minority 288:14

290:19 296:5,21

297:11,13 298:14

302:16,21 305:17

308:15 309:11

310:5 312:16

313:1 431:16

486:21 487:15

488:11 514:1

minuscule 255:13

255:21 359:19

458:4

minute 22:19 116:6

120:2 168:3 197:1

232:21 281:8

287:14 316:5,16

342:7 392:10

465:10 476:8

minutes 31:10

138:16 141:8

163:15 168:1

194:7 280:21

281:3 310:1

316:16 342:20

359:4 461:15

465:7 486:10

522:21

Miscellaneous 15:6

39:8

misconception 72:8

misguided 445:1

misinformation

457:21 458:20

misleading 460:17

misled 491:13

misperception

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misperceptions

442:15

mispronouncing

500:13

missed 66:15

154:10 405:4

missing 334:8

mission 217:20

218:4 321:21

493:21

Mississippi 63:8

mistake 138:21

mistakes 151:1

mitigate 300:11

mitigated 146:9

mitigating 308:12

mitigation 204:17

mix 200:9 369:21

460:15

mixed 250:13

360:7 460:12

490:15

mixture 460:18

mobility 410:17

mode 322:9 326:21

329:1,8 330:9

335:20 336:11

339:11

model 170:7

405:14 464:18

models 222:11

225:14 226:7

241:4,6 242:14

258:20 259:12

261:9 268:3,4

399:3 445:12

479:16

moderate 189:17

322:12

modern 123:6

Modernization

231:2

modes 322:6

339:21

modification 11:9

19:8 184:13

modified 19:6

66:22 120:6 125:2

modify 41:12

192:14

modifying 19:11

Mohamed 149:16

153:8 161:11

moisture 144:6

399:3 401:21

405:21 406:1

mold 324:13

molecular 204:21

263:13,16 264:5,6

264:16 268:3

molecules 250:20

262:8,9 329:21

mollusk 74:12

mollusks 48:20,22

molting 335:2

mom 483:12

moment 8:15 33:7

232:4 313:3 407:3

Monday 40:17 41:7

money 164:14

201:14 245:22

389:3 443:7

monitor 70:8

373:11

monitoring 57:10

57:15 58:10 75:4

223:3 224:5

225:21 226:6

monkeying 472:12

Monosex 66:18

Montana 387:13

month 61:13 258:9

332:7 336:21

410:15 440:9

months 60:16

62:20 74:10 75:16

84:20 118:11

125:7 126:3,16

182:19 331:1

347:15 382:12

430:13 465:2,3,4

470:19 483:1

moored 51:20

morning 4:5,13,19

5:1,3 7:5 9:8 13:3
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morphed 287:22

Morris 228:18

229:18 231:3,4

242:19 243:15

244:10 255:8

257:14,21 258:11

260:16 269:16

270:5 306:2

434:10 503:2

mortalities 56:4

mortality 337:16

MOSA 122:19

124:15 291:11

292:7

Mostin 459:7

467:18,20,21

472:11 474:22

477:6,16,18

moth 468:18

mother 178:6

217:9 346:7

motion 29:8 37:15

40:4,6,10 287:15

289:8,9,18 312:6

315:3

motivated 428:19

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motivation 231:22

Mount 197:22

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mountain 295:15

mountains 442:4

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Mousa 149:16

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Mouse 178:8

mouth 443:7

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478:3,5,6,10,12

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481:13,21 482:1,6

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483:21 486:5,9,13

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organization 50:4

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organizations

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organophosphate

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organophosphates

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organs 336:3

origin 66:16 484:20

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original 237:1

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originally 169:14

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OTCO 395:3

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ought 66:9

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outbreaks 360:22

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outcome 129:5

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outline 19:11

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outstanding 324:12

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overall 181:15

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overfeeding 189:19

overlap 126:9,11

overload 101:18

overloading 210:6

overly 113:15

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overseas 50:9

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overseeing 156:17

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overstate 479:3

overuse 323:5

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overwhelm 265:5

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overwhelmed

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oxytocin 363:16,16

oyster 46:6 60:19

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packing 390:16

page 15:7 39:8,17

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Palin 495:19

Pam 365:10 370:12

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Pamela 370:15

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panel 196:18,21

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panelists 195:7

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paper 136:13 177:1

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papers 25:17

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parasites 72:4

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parasiticides 72:4

Pardon 37:19

part 13:13 41:1

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participants

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participate 132:18

participating 132:3

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participation 24:3

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particles 210:20

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part-way 281:9

pass 22:9 133:2

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passion 150:1,2

passthrough

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pasture 30:9

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pasture-based

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Pat 345:12

patch 163:13

pathogen 198:22

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Paul 167:21 176:1

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peck 183:11

pecking 183:1,22

peer 31:8

peer-reviewed

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pen 58:13 73:21

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Pennsylvania

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Pentacles 5:6

people 5:2,3 7:22

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107:12 128:8,11

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357:19 375:5,7,7

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379:5 389:17

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426:19 427:2,18

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439:2,3,17 440:6

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502:1,3 503:22

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people's 167:1

274:21

perceive 88:16

perceived 395:10

percent 67:5 68:4

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368:12 372:6,9

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454:17 466:15

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percentage 105:1

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423:19 447:5

perception 428:6

perceptions 393:16

perch 65:20 158:11

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percussive 58:21

perennials 220:18

perfect 262:20

263:11 400:7

perforations

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perform 401:14

performance

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period 52:2 55:14

55:18 56:2 74:8

76:17 110:9

111:14 150:17,18

203:7,9,12,14,19

258:8 272:13,21

273:2,5,7,7,21

274:2 276:16

283:3 311:16

314:12 401:20

405:12,12,18

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469:13 521:20

periodic 486:6

periodically 440:16

periods 14:5 15:12

39:13 199:6

278:21 308:19,19

permanent 225:8

permissible 134:8

permission 162:22

476:4

permitted 116:16

perpetuated

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Persephone 496:1

persist 207:4

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persistence 208:4

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328:17 330:3,5

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persistent 67:19

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persistently 6:2

persisting 330:9

person 151:21

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personal 132:14

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personally 10:13

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personnel 10:20

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persons 18:22 22:1

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perspective 92:21

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197:2 231:10

285:20 414:4

436:5 466:2 467:8

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pertaining 13:15

pertinent 393:19

perturbation

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perturbations

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pest 71:19 220:9,16

221:1 225:2

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pesticide 269:21

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Peter 176:1

petition 18:22

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108:5 142:1,5

313:14 315:1,5

petitioners 100:1,2

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petitions 20:7 21:1

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87:20 94:2 99:15

106:1 290:21

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144:21

Pew 45:21

pH 279:9 330:4

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pharmaceutical

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pharmaceuticals

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phase 55:20 101:8

101:9 111:8 128:2

290:2

phased 475:6 508:1

phaseout 300:18

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philosophical

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phosphorus 176:16

photos 98:9

phrase 15:17 39:18

physical 73:22

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physician 231:11

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phytotoxic 200:16

phytotoxicity

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pick 5:14 158:12

picked 465:1

pickers 266:14

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pictures 137:20

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piece 69:18 82:5,6

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PIER 297:12

Pierce 60:1

Piercy 5:5

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pigment 62:8

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pile 159:18

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places 70:11

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plan 14:18 20:2

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224:16 225:14,19

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planet 402:12

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planning 88:2

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plans 223:5 224:6

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plant 6:4 44:3

62:12,14,15 87:20

88:5 89:3,6 91:10

95:18 96:13 100:8

147:10 197:8,10

197:11,12,14

204:8,11,16

205:20 207:7,16

208:17 209:5

211:14 223:11

282:11 289:14

313:20 314:20

315:5 328:3 333:1

335:22 348:19,21

348:22 349:1

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387:19 410:17

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378:1,3 389:9

446:12 468:2

planting 6:18

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plantings 225:10

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88:8,15,20 91:2

91:21 92:5 96:10

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103:3,7,12 164:17

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plasma 139:18

plasmid 212:1,7

plasmids 211:18,22

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plastic 416:3

play 5:6 288:17

292:2 473:10

playing 305:5

plays 433:5 499:13

please 104:17

117:1 152:1 160:3

179:15 207:1

298:7,17 320:18

343:1 346:13,21

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402:21 407:17

408:6 409:7 410:7

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500:13 507:14

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pleasure 231:5,7

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PLU 485:1

plus 188:19 518:3

pneumonia 505:2

Pobst 467:19

477:22 478:2,3

482:19 484:14

pockmarked 424:3

podium 316:15,21

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392:16 398:4

404:21 406:22

412:3 424:21

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459:7 467:19

477:22 485:19

490:12 495:16

507:10 510:21

poem 5:4,4

point 9:5 18:8 32:6

41:6 56:19 57:5,8

69:3,4,6 83:1

92:22 95:2 97:3

100:21 123:9

126:19,20 130:4

154:2 170:15

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236:18 237:15

241:3 243:1,2

245:18 263:21

264:6,8 266:20

268:12 279:19

295:17 301:7

305:20 310:1

323:9 337:8

343:21 346:2

360:15 412:10

417:6,8 421:18

428:4 431:22

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pointed 242:1

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258:6 377:1

pointing 343:16

points 20:15 49:21

127:15 168:9

234:14 284:9

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polar 51:2

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pole 5:10

policies 7:15 13:10

15:7 27:17 39:8

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16:19 17:10,12

19:4,5,18 20:16

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351:13 352:6

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polluting 165:5

pollution 170:22

polyculture 66:14

polyoxin 309:21

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327:17,21 329:14

331:12,16 332:8,9

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339:10,15 340:6

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98:11 338:13

ponds 74:9 75:14

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POP 485:6

Poposka 280:1,4

Poposki 280:2

popular 374:5

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population 176:17

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populations 170:20

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232:3 236:13

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241:2,10 242:17

245:3 257:20

258:2,7,14 259:15

259:17 261:6,11

277:2 279:8

373:15

Port 278:3

portable 264:5

portion 177:6

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Portland 1:11,12

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523:5

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poses 297:18

position 28:7

168:14 221:6

281:13 290:15,19

295:17 296:3

298:2 301:12

302:16 305:17

312:16 339:13

358:10 364:15

385:2 431:16

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positions 302:20

positive 16:17

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possibility 104:6

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261:2 398:1

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possible 4:19

212:21 239:15

263:22 286:13

304:18 317:3

346:17 348:1

395:16 420:22

460:13 498:20

possibly 255:7

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post 341:2 444:14

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postdoctorate

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26:9,17 40:2

110:7 127:10

283:1 284:18

288:3 311:14

314:10

posting 16:4 25:9

25:22

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238:15 286:13

338:8

rare 205:3 210:8

226:3 241:7,13

242:15 259:13

261:7,10

rarely 138:10

350:22

rate 157:18 190:15

410:3,4 416:9

417:12,14 421:21

rates 54:17 213:1

325:14 338:10

410:3 416:8,11,12

418:1,6 471:9

472:13 475:2

rating 269:18

ratio 175:19

ration 154:4

rational 402:13

439:5

rationale 312:10

rations 112:17

ratios 184:13

raw 114:13,13,16

144:19

reach 6:14 263:10

reached 137:5

343:18

reaching 6:14

react 128:4,7

130:19

reactive 373:16

read 25:17 162:4

166:7,10 254:15

255:8 281:22

287:14 288:3

291:13,14 344:15

384:3 442:18

465:18 504:11

readily 110:20

232:17 236:19

238:14 259:17

503:15

reading 24:17

34:18

reads 15:5 19:7

282:12 289:22

ready 251:22

272:14 274:7,10

274:17 276:11

294:15 310:12

384:21

real 5:10 6:6,7,7

105:8 117:14

149:5 163:2

166:21 238:9

274:2 275:22

299:11 360:13

363:4 395:10

398:1 411:9

444:17 456:16

462:9 466:21

477:11 509:6

realistic 188:17

292:22 394:21

402:21

realities 368:6

481:14 493:6

reality 58:18

163:19 368:8

393:13 464:15

484:1

realize 262:11

348:13

realizing 516:6

really 8:19,20 23:8

32:17 34:1 50:1

56:18 58:12 69:6

69:17 70:10 71:20

74:22 84:8 94:1

97:20 102:3

104:21 117:21

118:3 121:2,4

123:2 126:8

130:10 142:3,20

142:21 143:5

144:11,22 145:19

149:9 154:16
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161:22 162:10,17

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166:14 176:9

183:18 185:4

188:11 191:11

192:15 193:15,20

193:22 197:19

210:9 215:17

217:1 232:11

233:18 237:16,19

242:20,21 243:22

244:1 245:1,2

248:6 249:5 250:3

250:19 252:17

253:19 255:15

256:7 257:5 260:2

263:10 267:13

268:1,10 271:17

274:14 275:21

277:11 306:2,6

307:8 319:1,20

334:9 340:13

346:11 361:1

385:6 397:5,13

403:7 404:1,3

407:22 411:12

414:8 423:7

424:14 427:6

429:9 434:9 458:3

460:8 461:16

464:6,6 466:15

475:7 477:14

483:20 484:4

493:7 494:18

520:10 521:8

522:20

reason 27:21 52:13

57:22 68:6 144:22

148:3,14 166:1

178:9,20 201:5

203:21 207:16

275:12 339:5

354:13 413:1,9

419:20 492:22

495:11

reasonable 28:5

164:2,3 367:7,14

446:9 468:10

reasonably 202:20

reasons 10:18 52:6

93:4 95:16 96:18

450:14 452:15

483:17

reassure 354:16

386:7

reassuring 84:8

Rebecca 45:19

rebuild 382:10

recall 100:1 313:13

receipt 224:15

receive 13:17 21:1

114:20 286:1,14

482:19 488:4

received 8:17 16:1

16:6,17 21:2,3

40:2 119:8 139:6

229:1 282:3

287:17 289:3

290:14 299:14

310:18 311:18,18

313:11 334:5

356:12 372:5

374:22 470:18

504:8

receiving 19:20

183:7

reception 523:14

recess 523:18

recipient 212:17

recirculating 65:18

reclassification

172:12

reclassified 172:10

recognition 230:10

recognize 51:11

124:12 134:10

141:1 234:1 296:7

352:21

recognized 97:19

323:22 355:16

recognizes 13:7

292:1 358:10

recognizing 386:10

recombinants

119:21

recommend 97:13

179:14 180:5

208:19 353:13

354:14 439:16

recommendation

8:8 15:4 17:16

18:5 19:8,20 37:1

37:17,21 39:5,6

44:8,9 78:12

142:16 154:6,9

157:7 158:18

160:1,6,8,18,22

169:12,13 172:5

172:10 185:14

192:19 313:16

376:18 430:15

437:1 447:16

448:13 486:22

487:6

recommendations

19:14 49:7 57:1

102:11,13,19

106:3 123:14

125:6 134:13

136:3,4 185:9

332:1

recommended 49:2

68:2 117:3,12

412:7

recommending

30:2 47:2 49:3

recommends 14:21

292:11

reconciling 257:14

reconsider 95:5

152:2

reconsideration

29:2 41:17 94:21

record 12:8 70:9

107:6 168:8

170:10 194:19

223:4 301:21

304:15 342:11

344:16 475:3

492:19 523:22

records 226:19

227:13

recourse 412:22

recuse 286:4,7

recusing 315:7

recycled 53:16

recycling 66:13

73:15 74:6

red 22:20 62:5

141:9 316:17

reduce 14:10 393:7

475:12 481:19,22

reduced 67:17

71:12 73:4 492:21

496:11

reduces 135:21

reduction 174:10

369:15

redundant 304:21

322:8 395:7 489:2

489:18

reemphasize

356:22

reexamine 413:20

reference 103:18

116:20 176:7,21

348:10 444:2

referenced 307:15

521:8

references 225:14

referencing 79:6

referral 506:7

referred 114:12

314:4

referring 330:13

419:11 436:6,13

refiled 412:17

reflect 148:9

reflects 226:16

refugee 141:13

regain 43:18

regard 168:20

199:9 338:15

482:18 496:18

regarded 326:5

regarding 22:2

332:3 333:6

391:10 440:1

442:10 482:22

regardless 228:12

393:15 429:11

regards 168:15,19

169:22 225:2

regime 362:2

regimen 401:17

region 367:18

398:21 410:11

448:21

regions 67:18

361:5 362:16

491:2

registered 199:15

250:17 251:10

272:13 303:19

333:19,20 339:19

339:20,22 340:5,6

341:13,19 347:8

415:9 509:8 522:1

registers 308:1

registrant 419:4

registration 202:5

202:11 249:20

252:3,18 254:15

272:1 323:14

324:15 326:13

486:4 521:17

522:2

registrations

323:12

regs 148:17

regular 20:6 24:7

34:16 161:17

165:10 240:7

493:18

regularly 433:1

484:22

regulated 111:16

111:20 483:18

regulation 112:2

222:12 224:14,19

353:18,21 354:3

402:4

regulations 103:2

103:19 104:7
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regulator 216:16

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402:18

regulatory 19:19

112:7 162:17

295:5 332:11,12

332:14,15

Reid 46:7

reinforce 239:12

reiterate 40:16

175:7 285:19

293:3 395:4

430:11

reiterated 113:18

reiteration 357:3

Reitman-White

370:13 379:12,14

379:15 384:18

385:5 386:2

reject 370:22

513:19

related 13:10 93:11

309:9 412:18

relative 250:2

268:21 330:2

466:1,4,5,18

relatively 85:2,4

137:1 270:15

296:10 317:22

447:4 467:9 502:4

release 279:1,6

reliably 430:20

reliance 361:21

relied 29:15 360:17

relieve 521:20

relieved 151:10

relist 286:18

relisted 292:14

rely 227:15 307:2

390:1 444:20

455:6 487:10,11

relying 177:8 376:7

421:19 493:11

496:16 498:3

remain 85:1,4

96:19 99:20

remains 240:3

409:1 475:17

remarks 35:22

104:22 176:18

272:20

remedy 456:12

remember 87:7

129:21 253:5

255:4 256:21,21

409:20 424:14

498:10

remind 78:4

195:12 316:1

523:10

reminded 433:1,3

reminder 116:12

196:1

remote 261:2

removal 287:18

296:14 384:7

remove 28:15

67:21 286:15

289:10 303:1

removed 103:21

286:21 301:3

352:17 394:17

removing 394:8

450:18

rendered 76:20

renewal 224:11,15

rep 398:18

repeat 160:2

replace 95:18

327:3 468:10

replaced 11:12

445:10 447:21

448:3 469:2

replacement 31:2

188:22 189:1

replacements

301:4 366:13

397:8

replacing 101:11

272:4 443:12

468:13

replicable 508:17

replies 374:22

reply 331:19,22

report 48:19 67:16

107:22 110:5,5,7

116:2,2,6 119:3

126:14 127:13

130:16 131:18,19

139:18 141:21

142:14 143:9

144:14,20 191:13

227:11 254:15

255:9 275:18

282:17,18,19,20

311:9,10,12 314:3

314:4,6,8 324:21

325:3 331:20

334:11 338:2

415:15 422:6

461:13 469:11

470:4,7 500:18

reported 170:11

218:18 375:2

reports 139:1

218:16 282:22

332:2 501:9

reposted 26:10

reposting 26:13

represent 187:3

284:12 285:21

302:3 322:6

343:10 365:13

407:10,13 440:3

454:11 478:12

490:20 491:2

representative

365:17 410:5

451:22

represented 78:5

288:20 433:14

representing 78:10

293:4 379:20

386:20 480:6

486:16

represents 50:4

323:11 365:19

380:2 415:19

reproductive 67:17

135:3

request 19:13,15

19:21 110:4 191:9

314:2 333:21

347:4

requested 311:8

407:7

requests 19:5 20:8

109:21 282:8

311:1 313:18

369:5

require 58:11 62:8

66:9,12 67:2,2

73:8 74:5,8 75:1,2

75:7,12 175:17

193:13 220:14

222:8,8,21 223:6

223:18 224:4

227:12 333:10

377:3 509:12

512:19

required 31:5,7

51:15 57:14 59:6

62:7 74:19,21

75:19,21 87:1

116:15 225:20

226:5 301:2 489:4

requirement 58:15

79:12,18 82:7,8

98:18 137:2

140:15 157:7

158:20 227:3

requirements 70:2

70:5,8 75:4 96:17

99:8 134:14

135:10 136:13

140:12 185:15

220:11,12 222:22

225:12 488:17

489:12

requires 85:7

332:21 354:9

research 25:17

111:19 134:3

136:3 156:13,17

164:8 197:13

198:12 204:6,15

204:19 256:17

263:6 264:13

268:17 270:21

271:16 274:22

277:4 287:3 290:9

291:18 292:22

294:14 296:10,17

299:2 305:4

319:19 325:9

329:22 341:21

352:15 359:10

363:19 364:2

366:10,12 367:10

367:11,16 369:12

370:17 371:6,10

371:13,21 372:21

373:20 381:17

384:20 388:22

389:2,5 394:14,22

397:7 401:6

407:17 408:14

412:10,13,19

413:6 414:6 415:2

415:4,6,15,16

444:9 448:9 449:2

450:3 456:22

465:17 469:9,11

470:4,7 471:3,9

474:4 475:3,8

481:3 498:6

501:15,17 510:1

518:16

researcher 216:15

researchers 247:2

294:18 353:5

367:1,4 389:5

402:18 482:8

490:22 522:4

research-based

291:20 293:9

457:4

research-wise 94:6

reserve 435:14

reservoir 297:6
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reservoirs 338:13

reset 465:8

residency 229:4

residents 344:12

residual 408:21

residuals 421:21

residue 254:2,11,20

369:9 409:15

410:9 415:17

416:20 417:5

418:2,9 419:7,18

420:7 423:19

433:22 465:17

486:6 513:15,16

residues 23:10

213:12 254:9

257:1 307:14

347:5 348:13,16

348:19 349:7,12

349:15,16,18,20

409:9,18 410:12

410:22 411:9

419:21 421:8

423:7

resist 233:8 502:21

505:1

resistance 204:17

205:7 206:11

207:5 210:10

212:5,12 214:7,13

215:7,13 221:3

231:19 232:2,11

232:15 233:15,19

235:1,3,5,9,13,16

236:2,6,9,10,12

236:15 237:13,17

237:21 238:10,20

239:13,18,20

240:12,15,18,20

240:22 241:15

242:7,8 255:18,21

259:7 261:4

271:14 294:5

297:15 308:16,18

309:3,10 327:11

327:14 339:8,9

359:22 360:5

393:21 408:8

434:5,6,16 468:18

498:17 501:7,14

502:16,19 503:15

503:16 504:7

506:8,19

resistant 209:12

221:1 223:10

231:15 232:2

234:20 235:7,12

236:5 239:7,9,10

241:17 259:1

297:6 353:2

372:13,14 377:11

377:12 384:9

426:5,6 443:21

498:4 502:6

503:10,22 504:18

505:5 507:1

resistence 232:13

232:13 493:16

resistences 506:11

resolution 287:14

289:22,22 292:1

295:22 304:10,11

305:2 357:7,11

364:21 490:4

resort 354:19

388:18 391:18

393:4 517:6

resources 36:9

179:15 218:14

489:9

respect 479:6

respectful 316:18

respond 95:8

111:18 306:20

441:12 447:6

responded 372:7

375:5,7 379:5

440:12

respondents

361:13

responding 523:2

response 27:5

36:16 37:3 38:9

41:20 71:4 230:1

314:5

responses 122:17

responsibilities

24:17

responsibility

13:14 70:7 100:10

302:1 432:11

505:10 519:21

responsible 182:16

230:3 505:6

responsive 71:4

rest 167:22 366:4

427:9 444:8 451:2

495:6

restaurants 380:5

restock 60:19

restore 500:3

restoring 385:11

restrict 183:20

restricted 155:11

203:8 388:16

390:5 391:19

492:13

restrictions 75:11

219:12 300:1

304:19 488:2

489:10

restrictive 445:22

446:3 447:21

448:4

result 16:4 277:5

279:5 308:17

309:3 351:11

353:6 382:3 457:9

resulted 496:9

resulting 183:2,22

206:8

results 151:17

275:19 351:7

360:5 364:5

381:17 404:18

409:17 414:20

471:4 498:6

508:16,22 509:10

510:1

resumed 107:7

194:20 342:12

retail 216:15

387:12 388:6,15

392:6 484:22

485:10,14

retailers 365:22

458:1 482:21

retain 409:4 451:4

retained 188:4

292:14

rethink 177:21

rethinking 177:11

return 225:19

258:8

returned 295:7

returns 196:12

478:11

Reuben 9:7

reversal 169:16

review 9:2 13:17

14:10 18:17 20:7

20:17,20,22 21:18

28:1,7,19 29:3

31:8 68:12 110:2

116:7 117:5 139:5

187:19 222:16

224:12,17,19

278:17 282:15

301:14 307:16

311:7 314:1 326:5

329:1 353:10

371:20 418:19

447:15 492:17

reviewed 20:5

117:2 282:16

301:2 317:15

418:19

reviewers 225:13

reviewing 41:8

318:11

reviews 226:20

revised 37:18,22

331:16 355:18

revising 41:9

revisiting 177:6

revolution 99:11

revolutionary

324:5

revolutionized

58:12

revolved 78:18

revote 29:20

rhizopus 329:17

rhymes 495:19

ribeyes 145:22

Rice 229:2

Richard 167:11

178:2,5 320:20

331:7,9 386:16,18

386:18 392:15,19

398:3

Richardson 1:21

38:16 42:5 81:3

84:7 101:7 116:4

170:14 181:5,18

246:7 252:20

324:20 325:2,8

348:4,21 349:3

422:11

Rick 507:13,13,14

507:14 510:21

511:1 514:12

rid 449:11

rifle 348:2

rig 476:3

right 6:22 7:12

27:6 35:10 41:8

43:2 50:2,6 51:3

56:5 59:11 61:2

75:21 89:17 90:8

95:19 100:15

102:1 106:17

107:1 108:4 109:9

135:8 138:13

140:19 141:10

143:10 145:3,3,11

147:19 148:1,3,10

148:20,21 153:7

154:22 156:21

163:2,8,15 174:5

176:13 178:2

182:11 186:8

189:15 196:7

199:22 201:4
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289:7 303:5

304:12 310:14

335:10 346:21

355:1 370:11

378:10 396:21

401:9 403:11,14

403:16 405:14

406:19 408:17

418:14 422:8,16

426:22 429:9

436:20 449:19

452:19 462:7

476:11,20 495:14

500:6,17 501:16

507:9 518:14,14

519:10 522:16,18

rights 188:5

ripe 479:17

ripple 456:9

rising 231:19

risk 71:3 200:18

201:10 205:9

212:21 222:11

228:8 232:1

240:14 242:16

247:6 253:8,9,10

253:13 262:14

268:5 308:5

344:22 349:19

351:18 359:20

363:3,7 382:6

408:7 443:8 445:4

445:11 446:12

462:13 480:5

481:9 498:16

502:14 521:22

risks 205:10,11

225:6 253:6,7

308:13 369:14

393:11,20 481:21

493:2

River 198:6 459:12

rivers 338:13

Riverside 321:5

roach 334:15

road 263:21 264:4

265:15 309:5

449:3

Rob 63:9

robbing 176:1

Robert 46:5

Roberts 29:4

robust 227:5

Rocky 442:3

Rodale 368:13

Rodenticide 308:8

role 15:17 39:18

292:1 353:10

359:17 433:5

486:3 499:12

rolfsii 319:15

rollover 427:21

Ron 45:22 56:17

room 4:7 53:1

194:9 207:15

358:16 459:16

515:2 523:14

root 294:5 329:16

353:2 361:22

372:14 377:11,18

377:20 378:3

384:9 426:1,6,7

445:20

roots 328:15

rot 324:13

rotate 317:2

rotated 52:1

rotation 52:9 71:18

220:17 223:10

326:20 496:5

rough 184:6

round 15:15 23:14

23:18 350:12

352:19 410:8

520:6

route 91:4

routes 73:18 259:4

routine 493:19

routinely 264:9

row 225:9

ruin 328:18

rule 30:9,20 43:6

44:7 78:13 89:8

94:19 104:1,8

108:18 116:15

121:6 140:7 302:6

320:15 392:3

445:8,10,22 446:3

447:20,21 448:4

rulemaking 45:9

49:11 68:14

102:14,16 103:5

rules 29:4 302:2

304:12 388:20

492:10

ruling 154:10

ruminant 136:8

run 27:13 126:12

140:10 149:3

171:15 181:16

196:9 202:17

217:18 232:7

rundown 108:8

running 268:2

runs 6:12 489:14

rural 456:17

491:10 494:15

rushed 382:1

russet 201:19

403:22 404:1,4

406:12,13

Rutgers 204:14

R&D 461:6

S

s 4:1 15:15

sac 55:15

Sacrificing 446:7

sad 156:3

sadly 437:15

sadness 159:8

safe 164:9,13 182:6

201:7 202:2

298:18 308:3,4

341:5 491:9

safely 338:15

safer 200:10

201:21 202:1

safety 114:17

167:16 229:19

230:11,14,22

231:2 323:4 332:3

332:6 333:6,8

430:10 500:20

sake 291:12 370:7

375:20

Sal 453:2 459:6,9

saleable 443:10

sales 293:11,13

351:17 380:1,3

388:2,2,4,8 454:6

454:7,10,12,13,14

478:4

salesman 426:3

salmon 47:9 50:14

52:20,22 53:9,15

53:16,21,22 54:11

54:15,18,20 55:2

55:9,11 56:6 62:7

62:17 69:22 73:20

86:10,18,19 102:3

171:13,15 174:18

175:19 176:7,14

430:19

salmonella 125:1

salmonids 69:20

salt 310:18 311:2

311:19 312:7

318:13 331:12,16

332:8,10,22 333:2

333:4,7,12,14,17

333:22 335:20

336:8,12 338:7,12

339:16 340:6

sample 361:14

423:14 424:18

440:8

sampled 234:15

samples 234:15

264:21 278:11

410:22 411:3

416:2 423:6,10

sampling 245:3

266:8 267:17,18

486:6

San 468:1

sand 97:3

sanitary 75:2

sanitation 199:1

220:20 223:12

264:15 372:16

445:16 449:9

463:1

Santa 398:11 403:6

Sarah 495:19

Satisfying 302:4

save 399:12 446:8

456:3

saving 291:12

saw 73:3 74:6

76:22 77:4 90:18

119:12 137:11

142:18 277:21

285:10 399:20

453:14 460:15

469:6 522:10

saying 31:21 92:8

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variability 112:15

420:11,13,14

variable 420:4,5

variables 87:3

variation 204:20

228:13 437:21

varies 228:9

varieties 219:11

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223:10 228:6

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372:14 374:5,6

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488:3 498:4

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367:19 369:21

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various 78:10

147:8 195:15

259:4 292:18

334:6 460:22

488:8 497:10

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vast 325:18

vector 119:14

180:4,19 223:10

vectors 462:18

464:18

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359:10 380:11

425:8,8 428:22

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vegetables 298:9

453:11 478:6

496:2 511:12

vegetarian 175:12

vehicles 24:2

venison 136:8

venues 503:11

verbally 10:5

verification 129:20

227:13

verify 81:8 84:21

226:12,14 227:16

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380:11

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346:6

versus 85:18 86:10

86:11 225:5 239:8

255:6 269:14

299:5 364:21

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178:10,12

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68:22 69:4 118:14

119:19 179:19

vetted 285:17

414:21

viable 292:15 294:1

303:2 367:17

389:7 443:14

444:5 455:15

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335:14

victim 488:9

victory 300:21

video 57:16 58:10

view 56:20 57:5,9

69:3,4,6 83:2

100:21 126:19

142:15,16 374:15

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viewed 58:20 270:3

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vigilant 56:3

vigor 399:2

violation 420:9

violative 307:21

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247:16

virtually 82:22

235:4 361:2

virus 180:16

viruses 53:21

vision 515:11

visit 106:8 159:6

162:14 508:3

visual 78:3

vital 8:1 359:17

vitamins 78:19

99:3,6,7 115:9

142:10

vitro 336:5

VivaTerra 398:19

478:3

voices 495:12

volume 396:6
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waking 5:3

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walked 295:2

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266:5 269:17

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295:18 380:8

warehouses 387:11

warm 77:6

warmer 276:9

warranted 384:12

wash 208:10

washed 208:17

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65:5 67:6 68:20

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weigh 497:20

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welfare 100:8

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well-established

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107 3:15

11 302:9 410:3

416:10 417:9,12

417:13

11th 33:5 43:7,8

282:3

11:29 194:19

11:30 194:4

12 45:13 60:3 68:4

78:8 106:22

157:20 161:2,4

282:12 289:14

302:6 342:7

361:13 400:10

455:20

12:45 194:15

12:48 106:22

12:50 194:20 195:2

120 398:11

13 39:17 109:21

365:16

133 3:17

133324 315:4

136 218:22

14 215:1

15 69:8 71:11 83:10

86:11 187:1,2

194:7 372:12

496:1 517:15

15th 262:8

15,000 187:15

150 63:7 399:20

416:16

16 288:1 425:2

471:1 475:8

17 155:3 160:1,19

161:1

18 155:3 157:21

160:11 161:4

18th 331:21

18,000 187:4

180 50:4 169:16

1900 468:3

1930's 371:11

1940's 501:22

1945 504:7

1950's 393:22

196 3:20

1969 121:14

1972 520:7

1973 520:7

1974 148:11

1975 121:15

1978 150:2

1979 490:17

1980 490:18

1980's 350:11

1982 473:18 475:18

1985 496:3

1988 359:8

1995 301:22 343:14

343:17 377:9

446:12

1996 216:14 398:10

468:14

1999 47:15 197:8

2

2 15:17 39:17 154:3

154:4

2,000 303:15

400:11

2,500 393:1

2.7 161:6

2.8 161:5

2.95 161:1

20 69:8 86:20 87:3

168:5 297:11

318:6 398:17

400:10 475:19

478:4

200 63:7 75:8 187:3

210:13 230:17

443:2

2000 176:15 229:11

2002 216:8 468:5

2003 48:11

2004 48:11 150:1

2005 45:12 48:14

168:7 229:15

230:6 254:6

317:13

2006 48:19 148:9

282:20 398:10

2006-2007 169:3

2007 49:1 169:7

187:11 229:12,16

2008 49:6 141:19

411:20 430:15,18

2009 313:15

2010 10:22 46:22

49:10 218:19

317:13 487:16

2011 275:17,19

282:19 287:5

295:2 313:17

314:7 381:2

384:17 407:8

411:20 469:10

470:3

2012 25:2 26:9

109:20 110:6

154:8 188:15

219:5 275:19

282:3 293:11

310:19 311:11

313:12 331:18

380:2 470:6 478:8

2013 1:8 25:4 26:11

37:18,22 217:15

272:8 303:16

509:5

2014 202:8 260:11

272:2,8,9,12

282:14 289:11

296:15 299:3,4

366:11,16 370:22

382:1 385:22

412:8,18 413:9

445:9 447:20

481:18 505:19

2015 202:12 272:14

414:1,11

2016 287:12 289:16

290:4 292:8
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305:10 352:11

355:20 363:17,21

366:3 369:7

383:20 385:18,18

414:2 425:6 491:6

521:5,16

2017 291:17 293:8

294:16 299:14

366:19 383:20

388:18 390:6

426:8 456:21

2017-2018 522:4

2023 299:15

205.200 222:21

205.203 76:2

205.206 220:8

221:9 354:8 395:6

205.206(e) 221:19

205.402 224:13

205.403 226:10

205.406 224:13

205.600 117:6

205.601 221:21

222:3 282:9

289:12 311:2,21

312:7 313:19

205.603 109:22

205.672 521:8

206 356:10

21 454:17

21st 282:14 286:16

287:11 289:11,16

355:20 366:3,16

369:7

21,000 387:22

22 3:11 25:5,18

239:8 454:11

22nd 18:3 332:4

23 387:1

24 188:15 218:2

372:9 408:18

24,016 290:22

24,545 291:2

25 25:2 48:7 68:3

73:13 79:13 80:5

81:2 86:10 168:2

173:11 189:13

198:16 254:22

256:12 330:4

461:5

25th 217:16

250 34:2 255:4

262:4

26 235:1

27 15:7 39:8 188:13

290:17

27,000 293:5

453:21

273 465:15

28 178:12

28,581 344:10

281 290:20

3

3 312:9 315:6

3rd 108:14

3,000 478:9

3:15 281:10

3:23 342:11

3:35 342:8

3:36 342:12

30 25:18 27:1 46:15

86:20 99:12 101:1

237:1 280:21

281:8 318:7

379:16 476:14

491:17

30th 109:20

30,000 344:7

300 33:22 494:21

495:10

317 3:22

32 178:10 330:14

375:1

32-day 331:2

32.5 330:4

320 290:14

33 137:7 468:4

333 219:7

34 219:9

35 60:17 254:17

255:2 257:9

290:16 398:15

350 176:14

36 64:11 74:10

75:15 453:10

518:18

361 218:20

39 239:5

4

4 312:9

4th 310:19 331:17

332:7

4,200 518:11

40 46:15 210:1

235:11 287:21

288:4 381:3

40,000 440:11

400 400:5

44 3:13 147:7

45 215:1 219:10

522:20,21

49 409:22 416:13

5

5 315:7 410:3

514:13

5,000 255:5

5,897 344:14

5:30 196:5

5:40 196:6

50 156:4 159:15

336:20 453:18

50-member 518:2

500 9:16

56 372:6

59 156:5

6

6 15:6 39:7

6th 1:11 332:1

6,000 347:16

6,544 291:1

6:25 523:22

60 211:20 235:2,6

410:1

601 315:5 488:12

61 218:9 409:22

416:13

65 218:8

65,000 453:22

6518(n) 18:20

66 381:4

68 234:19

69 388:3

7

7 3:8 290:12 330:4

7,000 293:4 440:12

453:21

70's 371:14

70-week 188:22

700 374:19

719 218:20

72 374:22

72,000 387:21

73 333:19

736 219:20

76 219:6,9

77 234:17

79 381:5

8

8 19:11 312:4

313:12 315:2

8-1/2 388:1

8:00 1:10

8:01 4:2

80 144:6 237:7

470:18

80's 151:2,5 371:14

84 230:19

9

9 176:17,18

9.8 478:11

9:48 106:22 107:6

90 86:9 210:2

486:10

90's 138:16 371:14

92 361:13

921 1:11

94 229:18

96 229:18 487:16
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 

598

National Organic Standards Board

USDA

04-10-13

Portland, Oregon
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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)

 + + + + +

 THURSDAY

 APRIL 11, 2013

 + + + + +

 The National Organic Standards

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

Portland & Executive Tower, 921 Southwest 6th

Avenue, Portland, Oregon, Mac Stone,

Chairperson, presiding.

MEMBERS PRESENT

MAC STONE, Chairperson

HAROLD AUSTIN

CARMELA BECK

COLEHOUR BONDERA

JOSEPH DICKSON

TRACY FAVRE

JAY FELDMAN

JOHN FOSTER

WENDY FULWIDER

NICHOLAS MARAVELL

JEAN RICHARDSON

ZEA SONNABEND

JENNIFER TAYLOR

FRANCIS THICKE

CALVIN WALKER
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STAFF PRESENT

MILES McEVOY, Deputy Administrator, National 

 Organic Program

MICHELLE ARSENAULT, Advisory Board Specialist

MELISSA BAILEY, Director, Standards Division,

 National Organic Program

LISA BRINES, Standards Division, National 

 Organic Program
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S

Call to Order . . . . . . . . . . . . . . . . .5

Handling Subcommittee: Presentation of

Subcommittee Proposals and Summarization of

Written Comments

 John Foster, Chairperson . . . . . . . . . . .7

Public Comments related to Handling

Subcommittee

 Luis Monge . . . . . . . . . . . . . . . . . 37

 Theresa Frakes . . . . . . . . . . . . . . . 41

 Sherry Sirkin. . . . . . . . . . . . . . . . 45

 Charlotte Uris . . . . . . . . . . . . . . . 50

 Goldie Caughlan. . . . . . . . . . . . . . . 59

 Charlotte Vallaeys . . . . . . . . . . . . . 69

 Allyson Kelly. . . . . . . . . . . . . . . . 88

 Troy Aykan . . . . . . . . . . . . . . . . . 92

 Zareb Herman . . . . . . . . . . . . . . . . 95

 Trace Tipton . . . . . . . . . . . . . . . . 98

 Lindsay Fernandez-Salvadore. . . . . . . . .101

Discussion and Vote . . . . . . . . . . . . .106

Compliance, Accreditation and Certification

Subcommittee: Presentation of Subcommittee

Proposals and Summarization of Written

Comments

 Joe Dickson, Chairperson . . . . . . . . . .169

Public Comments related to Compliance,

Accreditation and Certification Subcommittee

 Mary Mann. . . . . . . . . . . . . . . . . .192

Inerts Working Group Update

 Lisa Brines. . . . . . . . . . . . . . . . .205

Deferred Proposals/Final Votes

 Pet food amino acids . . . . . . . . . . . .218

 Polyoxin d zinc salt . . . . . . . . . . . .229

 Indole-3-butyric acid. . . . . . . . . . . .246

 Other ingredients. . . . . . . . . . . . . .251

 Tetracycline . . . . . . . . . . . . . . . .271
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S (Continued)

Subcommittee Workplans. . . . . . . . . . . .368

Other Business and Closing Remarks. . . . . .390

Adjournment . . . . . . . . . . . . . . . . .393
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1 P-R-O-C-E-E-D-I-N-G-S

2 8:02 a.m.

3 CHAIRMAN STONE: I'm going to call

4 the meeting back into session. Again,

5 everyone's quite familiar, we have a lot to

6 consider today, several topics that we've not

7 brought up yet. 

8 First, I'd like to start out, each

9 of us that are appointed by Secretary Vilsack

10 would like to give Francis a little something

11 that he can prove to his friends that he

12 actually is on this. 

13 So, Francis, if you'll come up

14 here?

15 (Whereupon, a presentation was

16 made to Member Thicke.)

17 MEMBER THICKE: Thank you very

18 much.

19 CHAIRMAN STONE: Thank you,

20 Francis. I guess now you realize the gravity

21 of your agreement to serve. 

22 So at this time I ask Jean to read
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1 from "The Unsettling of America," Wendell

2 Berry, this morning.

3 MEMBER RICHARDSON: "The concept

4 of country, homeland, dwelling place becomes

5 simplified as the environment; that is, what

6 surrounds us. Once we see our place, our part

7 in the world as surrounding us, we have

8 already made a profound division between it

9 and ourselves. We've given up the

10 understanding, dropping it out of our language

11 and so out of our thought, that we and our

12 country create one another, depend on one

13 another, are literally part of one another,

14 that our land passes in and out of our bodies

15 just as our bodies pass in and out of the

16 land. That is, we and our land are part of

17 one another so all who are living as neighbors

18 here, human and plant and animal, are part of

19 one another and so cannot possibly flourish

20 alone, that therefore our culture must be our

21 response to our place. Our culture and our

22 place are images of each other and inseparable
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1 from each other and so neither can be better

2 than the other."

3 CHAIRMAN STONE: Thank you, Jean. 

4 So anybody else, any tidbits or anything from

5 the Program to start?

6 Okay. Very good. Okay. We'll

7 jump right in. We're going to do Handling

8 Subcommittee first thing this morning before

9 a break. Then we'll have CACS before lunch. 

10 Then after lunch will be the voting session

11 for all the topics that we have pushed off

12 until today. 

13 So with no further ado, I'll turn

14 the program over to Mr. Foster.

15 MEMBER FOSTER: Thank you. We

16 have four substances and one document to be

17 voting on today. We have sulfuric acid,

18 barley beta fiber, sugar beet fiber, DBDMH and

19 the auxiliary or other ingredients document.

20 My hope is that we can, after we

21 hear public comment, vote on the four

22 materials, and my guess is that we'll hold off
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1 voting on the other ingredients document until

2 after lunch probably. But otherwise, I think

3 we're ready to go on sulfuric acid.

4 And Dr. Brines, if you'd be so

5 kind as to introduce it?

6 DR. BRINES: Thank you, John. The

7 first petition on the agenda is sulfuric acid. 

8 The substance was petitioned on July 29th,

9 2010 by a company called Marinova. The

10 petition requests the addition of sulfuric

11 acid to Section 205.605 of the National List

12 for use in organic handling. The substance

13 does not appear elsewhere on the National List

14 for handling.

15 In support of its review the

16 Handling Subcommittee requested the

17 development of a third party technical

18 evaluation report. That report was completed

19 in 2012 and both the report and the petition

20 were posted on the NOP Web site in advance of

21 the opening of the public comment period for

22 this meeting. Thank you.
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1 MEMBER FOSTER: Thank you very

2 much for that. As before, I'm going to ask

3 the folks who headed up the discussions on

4 each of the items to introduce them and carry

5 the discussion forward if necessary.

6 So, Joe Dickson, I think you're

7 up.

8 MEMBER DICKSON: Thank you, Mr.

9 Foster. The Handling Committee reviewed the

10 petition for sulfuric acid and the technical

11 evaluation report. We found that sulfuric

12 acid, which is used as a pH adjuster in the

13 extraction of seaweed extracts, did not meet

14 the review criteria for a number of reasons. 

15 First of all, the petition itself

16 had large swaths of confidential business

17 information redacted, which made it very

18 difficult to really understand the process by

19 which the extraction of the seaweed takes

20 place. It was impossible to determine whether

21 the resulting extract was a synthetic material

22 and it really just left a lot of details out. 
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1 The essentiality of the substance was not

2 demonstrated in the petition and the technical

3 report documented negative environmental

4 impact of the production of the substance very

5 clearly. 

6 We received several public

7 comments regarding this material. Marinova,

8 the petitioner, did provide some additional

9 information that did address some parts of

10 what had been redacted from the petition, but

11 did not fundamentally change the standing of

12 the substance with regard to the review

13 criteria. 

14 Richard Theur noted that if we are

15 going to ever have organic citric acid, this

16 material will need to be added to the List,

17 which may well be the case, but isn't germane

18 to this particular use. 

19 Beyond Pesticides, PCC, NOC, Wild

20 Farm Alliance all commented against this

21 material and we did not hear from any

22 potential downstream users of the ingredient
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1 in any product. 

2 Any questions? 

3 MEMBER FOSTER: Yes, if we could

4 kind of have clarifying questions now, that

5 would be great. And then I anticipate having

6 discussion after we hear public comment on the

7 subjects. But clarifying questions at the

8 moment?

9 All right. Thank you, Joe.

10 Moving onto barley beta fiber next

11 on the docket. And Dr. Brines, would you be

12 so kind?

13 DR. BRINES: Thank you, John. The

14 petition for barley beta fiber was submitted

15 by Cargill on September 17th, 2009. There was

16 one update to the petition on June 1st, 2011,

17 and that update was in response to additional

18 questions from the Handling Committee. The

19 petition requests the addition of barley beta

20 fiber to Section 205.606 of the National List

21 for use in organic handling and barley beta

22 fiber does not appear elsewhere on the
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1 National List.

2 In support of its review the

3 Handling Subcommittee requested the

4 development of a third party technical

5 evaluation report, and that report was

6 completed in 2012. Both the report and the

7 petition were available to the public on the

8 NOP Web site in advance of the opening of the

9 public comment period for this meeting. 

10 Thanks.

11 MR. FOSTER: Thank you. So this

12 material was petitioned to be put on 205.606

13 as an allowed non-organic ingredient. I won't

14 go through the whole summary, but it's intent

15 was as a nutritional supplement to add to

16 dietary fiber. The reported unique qualities

17 of this were a preferable balance between

18 soluble and insoluble fiber, and the variety

19 of barley from which this is derived is -- in

20 the petition was identified as a unique

21 variety not available in an organic form.

22 A review of what we could find in
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1 the commercial stream confirmed that. In

2 general, we identified that the evaluation

3 criteria -- impact on humans and environment,

4 we felt that that criteria was met. On

5 essentiality and availability, in part because

6 essentiality and availability are linked in a

7 single criteria, the answer is actually yes

8 and no. And then compatibility consistency,

9 we felt on the whole it did meet that

10 criteria. And again it seemed to meet the

11 commercial supply criteria.

12 We confirmed through the

13 classification motion unanimously that it was

14 agricultural as petitioned, and on the listing

15 motion the Handling Subcommittee voted seven

16 yes and one abstention to list it on the

17 National List.

18 Any clarifying questions at the

19 moment on that? 

20 Okay. Hearing none, I'd like to

21 move onto sugar beet fiber.

22 Dr. Brines, would you be so kind?
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1 DR. BRINES: Thank you, John. The

2 petition for sugar beet fiber was submitted by

3 Nordic Sugar on September 30th, 2009. The

4 petition was revised February 7th, 2011 in

5 response to additional questions from the

6 Handling Subcommittee. The petition requests

7 the addition of sugar beet fiber to Section

8 205.606 of the National List as an

9 agricultural product, and sugar beet fiber

10 does not appear elsewhere on the National

11 List.

12 In support of its review, the

13 Handling Subcommittee requested the

14 development of a third party technical

15 evaluation report, and that report was

16 completed in 2012. Both the report and the

17 petition were available on the NOP Web site in

18 advance of the opening of the public comment

19 period for this meeting. Thank you.

20 MEMBER FOSTER: Thank you. Like

21 the barley beta fiber, the intent was to add

22 this as a dietary supplement to increase the
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1 fiber content of materials. It's a byproduct

2 of the sugar manufacturing process. The

3 primary concerns that we discussed were the

4 manufacturing of sugar and its impact on the

5 environment. The majority of the discussion

6 focused around the likelihood of genetically

7 engineered sugar beets getting into the supply

8 chain in some way. We had a fair amount of

9 discussion on that again summarized in the

10 proposal. 

11 In general we felt the criteria

12 for evaluation criteria were met and we

13 confirmed through vote to classify this as

14 agricultural and the listing motion again on

15 205.606 were seven yes and one abstention.

16 Are there any clarifying questions

17 at the moment?

18 All right. Moving onto the last

19 of the substances up for vote this meeting,

20 DBDMH. I'll try once -- actually no, Dr.

21 Brines, would you be so kind to just pronounce

22 this correctly as you introduce the material?
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1 DR. BRINES: Sure. For the

2 record, the petitioned substance is 1,3-

3 Dibromo-5,5-Dimethylhydantoin, henceforth

4 known as DBDMH.

5 The petition was received on

6 February 9th, 2012 and was submitted by

7 Alvamaro Corporation and the petition requests

8 the addition of the substance to Section

9 205.605 of the National List as an anti10 microbial. It is not currently listed

11 elsewhere on the National List.

12 In support of its review the

13 Handling Subcommittee did request the

14 development of a third party technical

15 evaluation report. That report was completed

16 in 2012 and both the petition and the

17 technical report were posted on the NOP Web

18 site in advance of the opening of the public

19 comment period for this meeting. Thank you.

20 MEMBER FOSTER: Thank you. The

21 material DBDMH is widely used as a

22 disinfectant in the rest of the world, in
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1 drinking water, recreational water treatment,

2 bleaching agent in paper and pulp

3 manufacturing. It was petitioned here as an

4 antimicrobial treatment for beef carcasses and

5 beef parts. As Dr. Brine said, not recognized

6 by other programs.

7 The Committee on the whole felt

8 that none of the evaluation criteria were met. 

9 We classified this as synthetic seven yes and

10 one was absent. And on the listing motion to

11 add this to 205.605(b) the vote was seven no

12 and one absent. 

13 Are there any clarifying questions

14 at the moment?

15 All right. Thank you. That's the

16 last of the substances up for a vote. We have

17 one more item on our agenda, and that is the

18 auxiliary or other ingredients document. And

19 I would ask Zea who headed up the discussion,

20 the robust discussion on this to take it from

21 here.

22 MEMBER SONNABEND: Thank you,
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1 John. Well, Michelle is going to pull up or

2 slides on other ingredients, the PowerPoint

3 first and then the revised document.

4 Anyway, I will start with just a

5 bit of discussion. I guess we were asked by

6 the NOP originally about a year ago to take up

7 this issue. We decided at our pre-meeting

8 that we had on Monday afternoon no one likes

9 the term other ingredients, and so we decided

10 we're going to try out ancillary substances. 

11 And so all of these slides say ancillary

12 substances, but just in case you forget what

13 that means, they say other ingredients, too. 

14 (Laughter.)

15 MEMBER SONNABEND: And we did not

16 actually revise the original document to say

17 that. 

18 But anyway, we received 88

19 specific comments and then a whole bunch that

20 I didn't count that were generally no

21 synthetics in organics. Among the 88 specific

22 comments there were 5 certifiers and the ACA
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1 that represents certifiers, 9 companies; I

2 mean production companies in that, OTA, the

3 Trade Association and W,D,& A as the

4 consultants, 4 NGOs and 67 individuals.

5 Unlike some other presentations,

6 because each of these groups had pro and con

7 and suggestions for wording changes -- and so

8 I'm just going to give some general comments

9 from them without singling out who said what,

10 and then we're going to show a few revisions

11 that we made to the recommendation, the

12 proposed recommendations based on the people's

13 comments.

14 Okay. As I mentioned, we

15 developed the proposal in response to the NOP

16 request. Certifiers in general were in

17 support of this Program. The sense was that

18 it balances consumer expectations with the

19 paperwork burden and will allow more

20 consistent decisions among the ACAs. A few of

21 them had suggestions that we have addressed in

22 our revisions to the proposal.
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1 Okay. Several NGOs and

2 individuals want an option D where everything

3 is reviewed, and they claim this is required

4 in OFPA. Our attitude is that we're

5 responding to the NOP request and comments

6 regarding what is legal in OFPA is really not

7 our domain and that needs to be taken up by

8 the NOP lawyers and perhaps your lawyers. 

9 Our proposal clearly states that

10 we are prepared to review ancillary

11 substances. We're planning to do this to the

12 best of our ability according to the criteria

13 in OFPA. We are not proposing to put them

14 individually on the National List. We're

15 trying to balance the need for vigorous review

16 of all the materials with the budgetary

17 limitations of the NOP and being able to

18 achieve technical reviews, write rules and

19 implement sound and sensible procedures for

20 the NOSB, as well as themselves and ACAs.

21 The checklist we used is in

22 process of being revised to reflect this
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1 proposal. An example of one of the questions

2 on it, which comes from category 2, question

3 11, are there other ingredients associated

4 with the substance that have been reviewed as

5 part of the substance? Describe along with

6 proposed limitations. 

7 Other questions on the checklist

8 will parallel the same OFPA criteria that we

9 used for the main ingredients. Although some

10 commenters want us to publish checklist

11 questions for comment, we're not planning to

12 do this directly, but we still start using it,

13 this new checklist, for items on the next

14 agenda so you will be able to comment in that

15 context.

16 We acknowledge the concerns raised

17 by two commenters about considering

18 international norms in planning how to

19 implement this review and we realize the

20 details of the procedure will need some

21 refinement and clarification as we start to

22 use it. As they say, it seldom turns out the
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1 way it does in the song. 

2 This includes exactly what form

3 the allowance information for ancillary

4 substances will take, whether it will be an

5 annotated or whether it will be a combination

6 of annotation guidance or incorporated into a

7 permitted substance list for handling in the

8 future.

9 So we're going to now project our

10 revised version of the document that will deal

11 with some of the additional comments. 

12 Okay. Now one factor I want

13 everyone to be aware of is that the NOP is

14 having some challenges incorporating a lot of

15 annotations into the sunset process. They

16 have brought up the possibility to us of

17 starting the supplementary reviews on other

18 ingredients especially for the big categorical

19 things before the normal sunset because we do

20 anticipate that this process of reviewing the

21 other ingredients will add another six months

22 or so to every review while we go out to the
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1 community to find out what these other

2 ingredients are and have them come in so we

3 can review them all. And so we may consider

4 taking up the supplementary reviews before the

5 normal sunset so they can be spread out over

6 time.

7 I feel it also necessary to point

8 out to the Board and the public that this is

9 our best proposal from the Handling Committee. 

10 If this doesn't pass, we're going to go back

11 to the way things have been done in the past

12 with the NOSB doing haphazard reviews, the

13 ACAs making inconsistent interpretations of

14 those reviews, and the NOP eventually deciding

15 how this will be done in the future. 

16 So our first change is on the

17 baseline criteria, which is on page 5 of the

18 proposal. We were unclear in point 4. Now a

19 lot of people misinterpreted and thought that

20 the baseline criteria in some way were review

21 criteria, but the baseline criteria is just

22 the starting point, and that's basically
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1 everything. The starting point is everything

2 as long as its allowed in food and not

3 prohibited. So point 4 we've made the

4 clarification change. It's required by the

5 FDA to be on the ingredient label of the

6 product to which the substance is being added. 

7 Okay. Onto the policy. We have

8 tried to strengthen the language by taking out

9 a few terms like "if possible" in the last

10 sentence of the third paragraph, and "try to,"

11 because we're not going to do just if

12 possible. We're going to do it. We're going

13 to incorporate restrictions. And we are going

14 to distinguish between non-synthetic ones now

15 that we have the classification of materials

16 out. We had written this before that came

17 out. And so this clarifies that we're going

18 to do it according to the new classification

19 of materials.

20 Now the procedure. A lot of

21 commenters commented that this wasn't really

22 clear whether this was NOSB review criteria or
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1 was what ACAs and MROs, etcetera, had to

2 follow. So we added a paragraph to clarify

3 that point, that this procedure refers only to

4 NOSB review, but not ACA procedures. It is

5 anticipated that following adoption of this

6 proposal the NOP will issue guidance for ACAs,

7 MROs and handlers about their procedures in

8 this matter.

9 We took heed of your comments and

10 it was an unintentional leave-out that not

11 just -- we would engender the public or enable

12 the public and the industry to submit their

13 other ingredients and not just ask ACAs for

14 what other ingredients were, or petitioners. 

15 We do want this to be a level playing field so

16 that not one brand name is favored over

17 another, and so we plan to try and review the

18 broad range of other ingredients. To that end

19 we changed points 1 and 2 in the NOSB review

20 portion to accommodate public comment and the

21 industry on this.

22 Also, we took out some somewhat
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1 vague language on point 8 and we replaced the

2 clause "provided they are specifically

3 acknowledged by the NOSB during review,"

4 because that doesn't have a very clear

5 meaning, and we replaced it with "specific

6 restrictions or prohibitions will be

7 communicated in an annotation or an NOP

8 guidance."

9 Okay. Moving down to the

10 confidential business information section, we

11 had written this before the last version of

12 the CBI policy from the Materials

13 Subcommittee. And so our intention was to

14 refer to that, which was going to originally

15 be a proposal but got turned into a discussion

16 document rather late in the game. So we're

17 changing this language and we perhaps weren't

18 as clear as we could have been that our

19 intention is that ingredients can never be

20 kept confidential. All ingredients have to be

21 disclosed and have to be reviewed. So the

22 wording that we have now is "all other
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1 ingredients;" although we may change that to

2 "ancillary substances," "must be disclosed for

3 purposes of NOSB review." All other issues

4 around CBI will be covered by the NOSB

5 recommendation on this subject once it is

6 finalized. 

7 Lastly, the portion that we called

8 "Other Considerations," was not -- it was put

9 there for things that we have to be aware of

10 for the future, but not that we would vote as

11 part of this policy or procedure, and

12 therefore we just moved that whole section

13 down to an appendix. And we will take that

14 up, the whole -- about a separate section for

15 cleaners and sanitizers and the like -- that

16 will be taken up at some future date by this

17 Committee is by no means endorsed or voted on

18 as part of this recommendation.

19 So I think that summarizes our

20 changes.

21 MEMBER FOSTER: Thank you, Zea. 

22 There was a lot of hard work for a long period
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1 of time. Thank you very much for carrying

2 that load. 

3 Are there any clarifying questions

4 at the moment? Again I expect a broader

5 discussion after we hear public comment. 

6 Nick, go ahead.

7 MEMBER MARAVELL: Yes, Zea, thank

8 you for running us through that. I have been

9 hearing some concern that we may not be

10 reviewing all these other ingredients or

11 ancillary substances to the criteria that are

12 specified in the Organic Foods Production Act. 

13 And I'm just going to say our policy says the

14 NOSB intends to review other ingredients. We

15 might want to just clarify for the purposes of

16 the public that intends to review to OFPA

17 standards other ingredients. That would be

18 consistent with what we are saying here, is

19 that correct?

20 MEMBER SONNABEND: I did say that

21 and I plan to do my very best to take a look

22 at all the OFPA criteria as we look at these
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1 things, but it's up to each of us to do as

2 much as we can in that regard.

3 MEMBER MARAVELL: And then I had

4 another point of clarification where we refer

5 to going out to the public to solicit

6 additional information that maybe we're not

7 aware of with regard to ancillary substances,

8 or materials; I can't remember what they are,

9 in the sunset process. And this may seem like

10 a minor point, but if we get a petition, we

11 will, you know, obviously put the petition out

12 so the public has access to it, but we have

13 not explicitly stated here that we would

14 welcome -- and that's what I'm questioning for

15 clarification -- we would welcome input from

16 the public once a petition is received as to

17 any substances that are not mentioned in the

18 petition that they may be aware of that we

19 should consider. 

20 And the reason I'm raising this is

21 we are not going to have a lot of flexibility

22 with requesting technical reviews and if we
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1 find another substance out there that's not in

2 the petition substance but is a major issue,

3 we'd like to have that in time for the

4 technical review process. So I was wondering

5 if that's something that might be accommodated

6 within our procedures here.

7 MEMBER SONNABEND: We did say that

8 in procedure point 1, NOSB 1, and 2, that we

9 would talk to the industry and the public. 

10 What we didn't say is the exact mechanism for

11 doing that, because that is still being worked

12 out. What I anticipate though is when we get

13 a petition in, the first meeting notice after

14 the petition could call for other ingredients. 

15 That's something we're going to take up at the

16 following meeting in six months. This is why

17 I say it will probably add six months to most

18 petitions. And then we have that time, and

19 hopefully we'll have an open docket so people

20 have a little time to submit these. But then

21 it will be reviewed at the following meeting.

22 We'll probably leave some things behind in the
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1 first round, and we're going to have to have

2 a plan B to deal with that, but this is

3 starting somewhere and we're starting

4 somewhere.

5 MEMBER MARAVELL: And then with

6 regard to the NOSB may or may not stipulate in

7 a review that any agricultural other

8 ingredients must be organically produced, how

9 does that work with our commercial

10 availability general policy? Is that clear

11 from this document?

12 MEMBER SONNABEND: That doesn't

13 need to be clear from this proposal. That

14 will be worked out in the course of looking at

15 the ingredients compared to the commercial

16 availability clause.

17 MEMBER FOSTER: All right. Thank

18 you, Nick and Zea.

19 I think I saw Jay. Yes.

20 MEMBER FELDMAN: Thank you. Thank

21 you. So, John, we will have more in-depth

22 discussion on this later at some point?
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1 MEMBER FOSTER: That's my intent,

2 yes.

3 MEMBER FELDMAN: Okay. I just

4 want to ask a general question for internal

5 consistency purposes. When we're talking

6 about CBI, we're talking about getting access

7 to all ingredients so that we can review them

8 and we can ensure disclosure. So do you feel

9 like the document does the same thing for the

10 public that enables the public to have access

11 to what is reviewed and to have full

12 disclosure of what is reviewed?

13 MEMBER SONNABEND: Yes, because

14 they will be named on the checklist. 

15 Otherwise, ACAs are not going to be able to

16 enforce to this and they will be in the TRs.

17 MEMBER FELDMAN: Okay. But both

18 of those things you just mentioned are

19 internal processes to the NOSB. So through

20 the posting mechanism is how you see it being

21 disclosed to the public? Okay. Thank you.

22 MEMBER FOSTER: Okay. Any
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1 clarifying questions at the moment? Yes,

2 Miles, please.

3 MR. McEVOY: Yes, I just wanted to

4 clarify our thinking around the annotations in

5 sunset, kind of add a little bit to that. 

6 There have been a number of annotation changes

7 that have been recommended during the sunset

8 process and we have found that that has been

9 incredibly difficult to meet the deadlines,

10 the time frames of sunset, when we're making

11 annotation changes because it complicates the

12 rulemaking process. 

13 So what we're requesting is to

14 move forward with these reviews and making

15 recommendations about the annotation changes,

16 but to have any rulemaking that we conduct to

17 make annotation changes be separate some

18 sunset so that we don't run into these very

19 difficult deadline problems, and that the

20 annotation changes could be made through a

21 separate rulemaking process. 

22 So we still want these ancillary
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1 substances or other ingredients to be

2 reviewed, and it could be potentially done

3 during sunset, but the rulemaking we'd like to

4 do separate if there's any annotation changes.

5 MEMBER FOSTER: Thank you, Miles. 

6 Other clarifying questions? Nick?

7 MEMBER MARAVELL: Miles, would

8 that represent any change from what our

9 existing policy and practice is? Aren't we

10 already doing that in effect?

11 MR. McEVOY: Well, the sunset from

12 the last round you made two recommendations,

13 one for relisting as is and one for relisting

14 with an annotation change if there was an

15 annotation change. So you're asking if the

16 future sunset review process will be

17 different? 

18 MEMBER MARAVELL: Yes. Or will it

19 be a continuation of what we're doing?

20 MR. McEVOY: Your process will be

21 the same, yes.

22 MEMBER MARAVELL: Okay. 
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1 MEMBER FOSTER: Was that the end

2 of that clarification or -- I see people

3 looking around as if they want more

4 clarification.

5 MEMBER MARAVELL: I hope so. Does

6 anyone else need more clarification? What I

7 heard was that Miles said we're just going to

8 continue to do what we've been doing.

9 MEMBER FOSTER: Okay.

10 MEMBER MARAVELL: No change.

11 MEMBER FOSTER: Excellent. All

12 right. Then that I believe concludes the end

13 of the introduction of the materials.

14 CHAIRMAN STONE: Thanks, John. 

15 And I guess the idea is that we'll have more

16 debate, more conversations, excuse me, on each

17 of these after we hear public comment so that

18 we can include that as part of our

19 deliberations.

20 So with that, I've got several

21 signed up here to speak during the Handling

22 session. Luis Monge. And Luis, please
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1 correct me on that pronunciation of the last

2 name. Theresa Frakes is on deck. So, Luis,

3 come on up. 

4 And just to remind, if you weren't

5 here yesterday or you're just here today,

6 there's a little stop light system. The green

7 light is for three minutes. The yellow light

8 for one. And when it goes red and the beep,

9 we ask that you stop. And right now Terry

10 Shistar is in the lead to win the prize for

11 being the best on time public presenter.

12 MR. MONGE: Just for the record

13 I'm colorblind. 

14 (Laughter.)

15 MR. MONGE: That's true.

16 CHAIRMAN STONE: So when it 

17 goes --

18 MR. MONGE: So I'm going to assume

19 that somebody's going to say stop. Okay?

20 CHAIRMAN STONE: When the one on

21 your right gets brighter, then you can step

22 away from the microphone.
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1 MR. MONGE: Okay. Good morning. 

2 I bet most of you might be asking what is he

3 doing here if there's nothing on the agenda

4 related to bananas or pineapple? Well, that

5 is exactly the reason I'm here today --

6 (Laughter.) 

7 MR. MONGE: -- to remember that

8 there is a new petition on -- to list

9 gibberellic acid on 205.605 for post10 harvesting organic bananas. 

11 Two meetings ago the petition to

12 include the gibberellic acid on 605 fail

13 because we, the petitioners, could not prove

14 that gibberellic acid was essential to organic

15 bananas production.

16 Well, we submitted the new

17 petition making a special emphasis on how

18 essential gibberellic acid is to the

19 sustainability of organic banana production. 

20 Months later we receive a letter from the

21 Handling Committee asking for more information

22 and we submitted the requested information. 
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1 I'm here today to ask the Handling

2 Committee and the NOSB to include gibberellic

3 acid on the agenda for the fall NOSB meeting

4 in Kentucky. I just want to repeat one more

5 time that gibberellic acid, a natural

6 substance already allowed for crop use under

7 601, is a key tool that needs to be used by

8 the organic banana growers to reduce the

9 rejection of the fruit at the packing station

10 and at the market. Please, Handling Committee

11 and NOSB Members, include the gibberellic acid

12 on the fall NOSB meeting agenda.

13 The other reason of my presence

14 here today is to submit a brief report and

15 update on what the organic banana industry in

16 Latin America is doing in order to develop

17 alternatives to rotenone for red rust control. 

18 Remember last time in Rhode Island

19 you set the date of January 1st, 2016 to

20 include rotenone in 205.602 as prohibited

21 natural? Well, we organize as the industry. 

22 We have had two meetings already. The first
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1 meeting was held in Ecuador to set up the

2 coordination group, and the second meeting was

3 in fact a red rust summit held in Piura, Peru. 

4 We had the participation of NGOs, a

5 university, local and national authorities

6 from Ecuador and Peru, as well as growers,

7 researchers and private corporations. 

8 It was a three-day summit where

9 all the parties shared their research results

10 on banana red rust. We now have a group of

11 representative from all the stakeholders

12 working together towards a common goal; that

13 is, to find real alternatives to red rust

14 thrips control in organic bananas. We will

15 keep submitting update reports on the upcoming

16 NOSB meeting. 

17 So thank you and see you in

18 Kentucky.

19 CHAIRMAN STONE: Very good. Thank

20 you, Luis. Questions for Luis?

21 All right. Thank you for being

22 here. Oh, I'm sorry. Harold?
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1 MEMBER AUSTIN: Luis, thanks for

2 coming and giving us an update. Were you

3 around yesterday at all? I saw you earlier,

4 but I wasn't sure. Were you around for the

5 discussions with tetracycline at all during

6 the afternoon?

7 MR. MONGE: Not really, no.

8 MEMBER AUSTIN: Okay. And the

9 reason I'm asking, very similar to the tree

10 fruit growers, same type of a resolution, same

11 type of, you know, annotation was made in

12 Seattle in 2011 giving them the 2014

13 expiration date with the challenge to go out

14 and do the research. Very typical, very

15 similar to what the challenge has been given

16 to the banana growers regarding rotenone, to

17 go out, come back to us before that 2016

18 expiration date, showing us that you guys are

19 making progress. It's nice to see that you're

20 here and telling us that you're making

21 progress. Thank you.

22 MR. MONGE: Great. It is always a
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1 pleasure to see familiar faces.

2 MEMBER FELDMAN: Hey, Mac?

3 CHAIRMAN STONE: Yes? 

4 MEMBER FELDMAN: Luis, I just want

5 to let you know; it's good to see you again,

6 that on these complicated issues we like to go

7 on field trips, but we haven't got an

8 invitation from you yet.

9 (Laughter.)

10 MR. MONGE: You're always welcome.

11 CHAIRMAN STONE: Maybe when the

12 sequester is over we'll get down there.

13 (Laughter.)

14 CHAIRMAN STONE: All right. Thank

15 you, Luis.

16 MR. MONGE: You're welcome.

17 CHAIRMAN STONE: I have Theresa

18 Frakes. I didn't see any movement. Theresa? 

19 Very good. Sherry Sirkin is on deck.

20 MS. FRAKES: Hello, my name is

21 Theresa Frakes. I'm a member of the

22 Cornucopia Institute and I'm here today as a
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1 citizen lobbyist. 

2 Cornucopia agrees with the

3 Handling Committee's recommendation to reject

4 the petition for sulfuric acid. Sulfuric acid

5 is classified as a group 1 carcinogen and is

6 toxic to humans. It should not be added to

7 the National List. We disagree with an

8 industry consultant who commented that

9 sulfuric acid should be added to the National

10 List to allow the manufacturer of organic

11 citric acid. That is a classic example of

12 changing the regulations to change the

13 definition of organics and we believe that is

14 unacceptable. Sulfuric acid is a toxic

15 synthetic substance. It is not compatible

16 with organic principles. 

17 Cornucopia also agrees with the

18 Handling Subcommittee's recommendation to

19 reject DBDMH. DBDMH is an antimicrobial

20 chemical used in conventional slaughterhouses

21 to control pathogenic bacteria such as E.

22 coli. DBDMH fails every criterion for
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1 inclusion on section 205.605. The EPA even

2 considers DBDMH to be a pesticide. 

3 The petition withheld important

4 information from the NOSB, the technical

5 reviewer and the public. The withheld

6 confidential business information included an

7 entire section titled "Effects on Human

8 Health." 

9 Alternatives exist including those

10 discussed at length in the TR; peracetic acid,

11 hot water washing, chlorine and hydrogen

12 peroxide. The lack of publicly available

13 safety testing data combined with strong

14 indications that human health and

15 environmental concerns exist renders this

16 material a poster child of why U.S. consumers

17 are switching to the organic label which

18 mandates greater scrutiny of chemical inputs

19 in food production.

20 Some of the answers on the

21 decision tree should be corrected. We do not

22 agree that the answer to the question are
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1 there adverse effects on environment from

2 manufacture use and disposal is no. It

3 appears that DBDMH and its breakdown product

4 hypobromous acid are both toxic to aquatic

5 life. The only information regarding the

6 environmental impacts of DBDMH comes from the

7 petitioner. If anything, the environmental

8 impacts are unknown and we do not believe the

9 Handling Subcommittee has enough information

10 to confidently state that no negative

11 environmental effects exist.

12 The Handling Subcommittee also

13 answered no to the question is there any

14 harmful effect on human health. Multiple

15 animal studies on DBDMH and its breakdown

16 product hypobromous acid have shown effects on

17 the reproductive and endocrine function. 

18 Again, the fact that the Handling Subcommittee

19 does not know the answer to this question does

20 not justify the assumption that the material

21 is safe for human health. 

22 Serious concerns exist about this
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1 synthetic antimicrobial which is regulated as

2 a pesticide by the EPA. Animal studies

3 suggest its breakdown product may be an

4 endocrine disrupter. Operating under the

5 precautionary principle the NOSB should reject

6 the petition to add DBDMH to the National

7 List. 

8 Thank you for considering our

9 comments.

10 CHAIRMAN STONE: Thank you very

11 much. Are there any questions for Ms. Frakes?

12 Thank you very much for being

13 here. 

14 Sherry Sirkin to the podium. 

15 Sherry? Okay. Thank you. And Charlotte Uris

16 is on deck.

17 MS. SIRKIN: Morning. My name is

18 Sherry Sirkin. I'm a member of the Cornucopia

19 Institute and I'm here today as a citizen

20 lobbyist, although I'm also a small farmer

21 just 20 minutes east of here.

22 We urge you to reject the petition
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1 for sugar beet fiber. Read some of the 1,300

2 public comments submitted to you through

3 regulations.gov and it will confirm what

4 public interest groups like Cornucopia repeat

5 over and over to you. Organic integrity is

6 important. Organic consumers feel very

7 strongly that organic foods should contain

8 organic ingredients. I know that seems like

9 a no-brainer, yet the Handling Subcommittee

10 voted unanimously to allow conventional sugar

11 beet fiber in organic foods.

12 The petitioner, Nordic Sugar,

13 confirmed in a written comment that the

14 conventional sugar beet seed they use is

15 treated with a pesticide that belongs to the

16 neonicotinoid class, or neonics pesticides, 

17 are deadly to honeybees. In a front page

18 story from the New York Times just a few weeks

19 ago, March 29th, began as follows: "A

20 mysterious malady that has been killing

21 honeybees en masse for several years appears

22 to have expanded drastically in the last year,
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1 commercial beekeepers say, wiping out 40 or

2 even 50 percent of the hives needed to

3 pollinate many of the nation's fruits and

4 vegetables." 

5 The New York Times story goes on: 

6 "A conclusive explanation so far has escaped

7 scientists studying the ailment, Colony

8 Collapse Disorder, since it first surfaced

9 around 2005, but beekeepers and some

10 researchers say there is a growing evidence

11 that a powerful new class of pesticides known

12 as neonicotinoids incorporated into the plants

13 themselves could be an important factor." And

14 it seems to me every new day a study shows the

15 connection between neonicotinoids and Colony

16 Collapse Disorder.

17 And now they Handling Subcommittee

18 recommends we add conventional sugar beet

19 fiber to organic foods even with the full

20 knowledge that conventional sugar beet is

21 treated with a neonic pesticide. They're

22 ignoring their legal responsibilities to
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1 protect the environment under OFPA. For that

2 reason alone the petition asking to allow

3 conventional sugar beet fiber in organic foods

4 should be rejected, and we hope unanimously.

5 There are dozens more reasons to

6 reject the petition, and I'd like to speak

7 about just two others. The petitioner may be

8 in Europe where sugar beets are not currently

9 genetically engineered because they don't

10 allow it there, but if it is added to the

11 National List, it will open the door for

12 conventional sugar beet fiber sourced from

13 anywhere in the world, including the U.S. And

14 in the U.S., according to the USDA's own data,

15 95 percent of conventional sugar beets were

16 genetically engineered in the 2009-2010 crop

17 year. 

18 Finally, this material is not

19 essential to organic production. There is

20 currently plenty of fiber in certified organic

21 food and this is really just a gimmicky

22 nutraceutical that is being petitioned in
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1 order for multinational corporations to be

2 able to make certain health and marketing

3 claims on their label. Consumers who want

4 more fiber in their diet can eat whole organic

5 foods that are rich in fiber. Consumer survey

6 data from various sources; the PCC Natural

7 Market surveyed 1,500 organic shoppers, found

8 that organic consumers expect the added

9 nutrients in organic foods to be organic. 

10 And finally, I'd like to add that

11 I'm a grower of mostly vegetables here and I'm

12 actually not certified organic because I

13 direct sell every single vegetable that leaves

14 our farm. I know the people who eat it. But

15 when I go shopping as a consumer, I prefer to

16 buy organic because I don't want to be a

17 guinea pig and be part of the genetic

18 engineering test. And I oppose genetic

19 engineering strongly. And the one thing that

20 I feel confident is that if I eat organic

21 food, I'm not exposing myself to genetic

22 engineering. 
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1 So thank you for considering our

2 comments.

3 CHAIRMAN STONE: Thank you very

4 much. Any questions from the Board?

5 All right. Thank you for taking

6 time to be here. We appreciate it.

7 Charlotte Uris is to the podium

8 and Goldie Caughlan on deck.

9 MS. URIS: Hello, my name is

10 Charlotte Uris. A chemical exposure changed

11 my life. I now have multiple synthetic

12 chemical sensitivities and any additional

13 chemical exposures could be harmful to me. 

14 People like me with sensitivities to the

15 numerous synthetic chemicals that didn't exist

16 for thousands of years of human history and

17 life on earth are like the canary in the mine

18 warning of danger. We have the same bodies as

19 you do, as your children do, as your

20 grandchildren do. Keeping organic food truly

21 organic is necessary, marketable and moral.

22 I'm a member of the Cornucopia
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1 Institute here today as a citizen lobbyist. 

2 We urge you to reject the petition

3 to add barley beta fiber to the National List. 

4 Barley beta fiber appears to be petitioned to

5 serve as a marketing tool for organic

6 processors to increase fiber content and

7 justify an FDA-approved health claim on the

8 food or beverage packaging. A Michael Pollan

9 food rule is never buy a product that makes a

10 health claim. Eat real food, he says. 

11 Organic consumers want real and organic food. 

12 Adding conventional barley beta fiber

13 manufactured by Cargill to organic foods would

14 be a marketing disaster for the organic label

15 in general. 

16 Organic consumers expect organic

17 foods to contain only organic ingredients. 

18 There is some tolerance for synthetics that

19 are truly essential, carefully reviewed for

20 safety and for which no alternatives exist

21 like sodium bicarbonate, baking soda, to make

22 organic cookies. There's nothing essential or
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1 even healthy about conventional barley beta

2 fiber in organic foods. 

3 PCC Natural Market's 2011 survey

4 confirms that organic consumers do not want

5 added nutrients in their organic foods unless

6 they are derived from an organic source. 

7 Nearly two-thirds of respondents said they

8 would not knowingly purchase organic foods

9 with a conventional added nutrient. And one10 quarter said they would be less inclined to

11 purchase an organic product with a

12 conventional added nutrient. 

13 If you have any doubt whether

14 organic consumers feel strongly that the

15 organic products they buy should be

16 trustworthy, truly organic, containing only

17 organic ingredients, please read some of the

18 1,300 citizen comments submitted to you

19 through regulations.gov.

20 Organic consumers buy organic

21 foods to avoid GMOs, avoid pesticides and

22 protect the environment from the toxins used
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1 in conventional agriculture. Barley beta

2 fiber is made from conventional barley. Toxic

3 and environmentally damaging fumigants are

4 likely used in storage. Methyl bromide, an

5 ozone-depleting fumigant which is so

6 environmentally disastrous it's being phased

7 out, is still used to fumigate barley. 

8 Another fumigant, sulfuryl fluoride is a

9 greenhouse gas 4,000 times more efficient at

10 trapping heat than carbon dioxide. Ethanol is

11 used in the processing of barley beta fiber

12 and is likely derived from genetic engineering

13 corn. 

14 Cornucopia found that Cargill has

15 identified a specific enzyme used in barley

16 beta fiber production for which the patent

17 states that the bacteria have been genetically

18 engineered. Cargill is the sole manufacturer

19 of barley beta fiber in the U.S. Cargill

20 routinely uses genetic engineering. In fact,

21 the corporation contributed a quarter million

22 dollars to defeat proposition 37 in
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1 California. 

2 Barley beta fiber is entirely

3 incompatible with organic principles. Organic

4 consumers will lose confidence in the

5 integrity of the organic label if this is

6 allowed in organic foods endangering the

7 organic industry. Please reject the petition. 

8 Thank you for considering

9 Cornucopia and my comments.

10 CHAIRMAN STONE: Thank you very

11 much. Any questions from the Board? John?

12 MEMBER FOSTER: Excuse me, I have

13 a question over here.

14 MS. URIS: Okay.

15 MEMBER FOSTER: How is this

16 conventional ingredient different in any of

17 the aspects than any of the other conventional

18 ingredients on 205.606 currently?

19 MS. URIS: I don't understand all

20 the technicalities, but basically a

21 genetically modified enzyme is used to process

22 the beta fiber, which is a conventional beta
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1 fiber from conventional barley which should

2 not even be in the organic product.

3 MEMBER FOSTER: So if that's the

4 case; I don't know that that's the case, but

5 if that's case, would it not be prohibited

6 under other portions of the regulation?

7 MS. URIS: I didn't understand the

8 question or quite hear it.

9 MEMBER FOSTER: If it's a genetic10 engineered material, then it would be

11 prohibited for other reasons.

12 MS. URIS: Well, I would think so,

13 yes.

14 MEMBER FOSTER: I would hope so. 

15 I don't know that that's the case, but I think

16 that there's other prohibitions that would

17 keep that ingredient from being --

18 MS. URIS: This is based on the

19 research of Cornucopia where they are saying

20 that it's a patented genetic enzyme. I'll go

21 back to exactly the way they describe it: 

22 It's a specific enzyme used in barley beta
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1 fiber for which the patent states that the

2 bacteria have been genetically engineered.

3 MEMBER FOSTER: So if that's the

4 case, I'm thinking that that would be

5 prohibited for other reasons, right?

6 MS. URIS: And are these reasons

7 that you wouldn't be dealing with in this

8 Committee? Is that what you're saying?

9 MEMBER FOSTER: Well, there's

10 provisions in the regulation that prohibit the

11 inclusion of genetic-engineered material.

12 MS. URIS: I just see all of these

13 things as being relevant to the organic

14 standards and that's why all of these things

15 are being brought up in this particular

16 testimony and hearing.

17 MEMBER FOSTER: Yes. Right. Is

18 that the only distinction see as far as, you

19 know, this being different than other

20 materials on 606, or is that one of the unique

21 qualities?

22 MS. URIS: Every one of the things
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1 I've said are things that are of concern to me

2 as an organic consumer. As I explained in the

3 beginning, I'm very sensitive and I have

4 actually had organic products that have had a

5 significant negative impact on me, one,

6 because of processing or even because of the

7 storage. For example, organic apples. Some

8 of them are stored. They might be organic

9 apples, but if they're stored in the wrong

10 kind of boxes and packaging to keep them from

11 getting moldy or spoiling, they actually have

12 a negative impact on me. 

13 MEMBER FOSTER: I'm sorry to hear

14 that.

15 MS. URIS: So all of what I'm

16 saying is I really am like a canary in the

17 mine.

18 MEMBER FOSTER: Yes.

19 MS. URIS: And when other people

20 might just think, oh, this is a funny-tasting

21 apple, you know, think about -- I had a brief

22 moderate toxic load that totally changed my
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1 life. With all of these synthetic chemicals

2 that basically have come into our world since

3 around the time of World War II, which are

4 really new things, for most people it's more

5 of a slow loading of the system. Some of the

6 things can be cleared and some can't.

7 MEMBER FOSTER: Yes.

8 MS. URIS: I'm the canary in the

9 mine. That's what I'm saying.

10 MEMBER FOSTER: Thank you. Just

11 one more question. Are you aware of the 100

12 percent organic claim? Do you see that in the

13 marketplace?

14 MS. URIS: I am. I think it's

15 very complex to figure out what that really

16 means, because there are things that say

17 organic that you'd think by reading the label

18 is organic.

19 MEMBER FOSTER: Thanks.

20 MS. URIS: -- you know? And I'm

21 not just talking for myself. I'm concerned

22 for other people besides myself.
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1 MEMBER FOSTER: Thank you very --

2 MS. URIS: That's why I'm doing

3 this testimony, too.

4 MEMBER FOSTER: Thank you. I

5 appreciate it. 

6 CHAIRMAN STONE: Thank you very

7 much. Goldie Caughlan to the podium and

8 Charlotte Vallaeys on deck.

9 MS. CAUGHLAN: Thank you. Yes, my

10 name is Goldie Caughlan and I formerly served

11 on this Board as well in 2001 until '06. I'm

12 from Seattle, worked for nearly 30 years with

13 PCC Natural Markets.

14 Regarding other ingredients,

15 ancillary or otherwise, the Organic Foods

16 Production Act, the USDA Organic Regs and

17 previous USDA statements have all made it

18 indisputably clear that all ingredients in an

19 organic product must either be organically

20 produced or appear on the National List. 

21 There is no distinction existing between

22 ingredients and other ingredients. We urge
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1 the NOSB to use the organic law and the

2 regulations for setting policy regarding other

3 ingredients. 

4 OFPA states, unequivocally we

5 believe, that every synthetic and non-organic

6 ingredient must be listed for its specified

7 purpose. For example, if rennet cannot be

8 made without sodium benzoate, a currently

9 unapproved synthetic, then sodium benzoate

10 should be petitioned for the specific purpose

11 of use in rennet.

12 The current practice of allowing

13 ingredient suppliers to use any synthetic

14 preservative, stabilizer or other ingredient

15 and to justify this based on the fact that

16 these suppliers are not certified organic

17 handlers, is itself a violation of OFPA and

18 should end. The success and continued growth

19 of the organic industry absolutely depends in

20 large part on consumer trust in the organic

21 label. You've heard it frequently, not just

22 from Cornucopia. And in turn, the success
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1 would depend upon the NOSB, the USDA and the

2 industry's combined adherence to the organic

3 law and the regulations.

4 Without question, if organic

5 consumers know that the organic products that

6 they buy could contain unapproved ingredients

7 such as polysorbate 80 or sodium benzoate and

8 others and are processed with materials such

9 as hexane and propylene glycol, then they

10 would undoubtedly feel deceived, and

11 rightfully so, and we will all be the ones who

12 bear the results of that. 

13 You've heard about the data from

14 PCC. I don't need to say that again, but we

15 must remind you again apparently that over

16 1,500 of our shoppers found that organic

17 products containing an added nutrient with

18 unapproved ancillary ingredients would not be

19 purchased by an overwhelming majority of

20 organic shoppers.

21 Since these other ingredients are

22 not required, however, to be listed in the
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1 ingredient lists of a processed food, most

2 consumers likely don't realize -- in fact, I

3 know that they don't from talking with them,

4 which is what I spent a lot of time doing with

5 consumers over that period of three decades. 

6 They know. They believe they can believe, and

7 then there is the moment of surprise. They

8 don't know that if they buy a product with

9 algal oil, for example, that they're buying a

10 product with glucose syrup solids possibly

11 derived from genetically engineered corn,

12 synthetic stabilizers and additional

13 unapproved synthetic other ingredients. But

14 those other ingredients do have to be listed.

15 CHAIRMAN STONE: All right. Thank

16 you very much. Zea?

17 MEMBER SONNABEND: Thank you,

18 Goldie. When you were on the NOSB did you

19 bring up any of this testimony in reviewing

20 petitions or to the Department about these

21 other ingredients?

22 MS. CAUGHLAN: As you probably
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1 will remember, Zea, during the final phase of

2 the time that we spent on the Board just

3 during the last part of 2005, as a matter of

4 fact there was a great deal of discussion and

5 concern about these issues and it was a very

6 troubling time in many respects on the Board. 

7 And I don't need to go over that, but there

8 were certain situations that made it much more

9 so. I would say that we talked about these

10 things exhaustively long and it was very

11 confusing. And I think that we bear part of

12 the problem, because I think perhaps some of

13 the confusion started with that Board, our

14 Board's decision. 

15 I've spoken with some of the other

16 members of the people that were on the Board

17 at that time and we all, you know -- so the

18 fact of the matter is we don't need nor want,

19 and we certainly should not continue with the

20 mistakes that well-meaning people dealing with

21 the same kinds of very difficult issues that

22 all of you are dealing with, doing your
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1 darnedest to come up with decent answers. But

2 it doesn't excuse us from the fact that right

3 now we're faced with the fact that we will

4 only add to the problem if we don't attempt;

5 and I believe you are attempting, to make a

6 situation where this will not go forward. But

7 it's not a pleasant situation, as I'm sure you

8 would agree. Thank you for your work on this.

9 CHAIRMAN STONE: Jay?

10 MEMBER FELDMAN: Thank you,

11 Goldie, and thank you for all you have

12 contributed to the organic movement --

13 MS. CAUGHLAN: Thank you.

14 MEMBER FELDMAN: -- both on the

15 NOSB and at PCC. You know, we've been going

16 through a lot of these issues where the Board

17 is trying to grapple with consumer

18 expectations and trying to review inputs, the

19 inert ingredient issue, which I view as a

20 similar parallel sort of situation, which the

21 Board has committed itself to review those

22 ingredients which have here to date been
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1 inadequately reviewed, I would say. And so

2 now we have and have had for a long time a

3 similar situation with other ingredients. 

4 So obviously there's a workload

5 issue.

6 MS. CAUGHLAN: There is.

7 MEMBER FELDMAN: And there's a

8 question of resources. And, you know, you

9 heard the director of the Program earlier

10 talking about the difficulties of annotation

11 and, you know, which --

12 MS. CAUGHLAN: Right.

13 MEMBER FELDMAN: -- has been added

14 as a function of our sunset review, or that

15 authority, which I think is an important one.

16 What advice can you give to this

17 Board as we grapple with this proposal and at

18 the same time grapple with the OFPA standards

19 and requirements, as you indicated? What

20 advice can you give us in terms of creating a

21 system that meets those standards, does not

22 overwhelm the Board and the Program, ensures
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1 integrity from a consumer perspective as

2 organic continues to grow?

3 MS. CAUGHLAN: Thank you for

4 asking. I will answer from my own

5 perspective. A perspective that has been

6 shared, I believe, by others that I have

7 spoken with is that I think the Board is

8 always, and increasingly so, under incredible

9 pressure to respond and to do so at the behest

10 of industry which comes to us constantly

11 asking for more tools, understandably. And

12 it's, if I can put it that way, almost a sense

13 of imperative. We have to do this. We have

14 to hear this. And we heard it yesterday in

15 regard to several very serious issues, the

16 constant pressure that you must perform, that

17 you must give that which has been asked.

18 The reality is it is incumbent

19 upon each of us when we sit in those sometimes

20 very uncomfortable chairs for hours at a time

21 that the fact is much of the individual public

22 voice is not necessarily coming through with
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1 the drum beat that is heard from industry

2 itself. 

3 And so the work of people like

4 Cornucopia, which is not frequently viewed

5 with acceptance or concern when it's -- by

6 members of this Board I'm sure -- are looked

7 at, I'm sure, as nitpickers, but they're

8 attempting to bring to your attention to the

9 fact that consumers' voice is very, very, very

10 important. After all, if the consumers lose

11 their confidence in the product, what do you

12 have? What does industry then have? What do

13 any of us have? None of us got into this

14 originally with the intent to continuously

15 have acrimony. I think the fact of the matter

16 is the consumers are basically the end

17 choosers, and I think that that has to be

18 revisited frequently in our thoughts.

19 And I heard some rather

20 disparaging kinds of comments yesterday. I

21 don't think it was intentional, but in

22 exasperation I heard some Board Members and
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1 others feeling that consumers don't really

2 know what they're talking about or don't

3 really care, don't really understand. If they

4 don't understand, then somebody with all the

5 ability to market to those consumers better

6 take a look at it. Are we telling people just

7 enough or just what we think people want to

8 hear, or are we leveling with people? 

9 That's all. I'm sorry. I think

10 that it's extremely important to realize that

11 you have a very awesome task in front of you. 

12 You're not there just to serve industry,

13 however. It is a partnership between the

14 producer and the consumer and that consumer

15 has to have an opportunity to truly influence

16 or this is not going to work very long.

17 CHAIRMAN STONE: Thank you. It's

18 great to hear from the heart. We listen

19 closely when we hear that tone.

20 MS. CAUGHLAN: Thank you so much.

21 CHAIRMAN STONE: Thank you. Thank

22 you very much.
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1 CHAIRMAN STONE: Thank you. 

2 Charlotte Vallaeys to the podium and Allyson

3 Kelly on deck.

4 MS. VALLAEYS: Hi, my name is

5 Charlotte Vallaeys. I'm policy director at

6 the Cornucopia Institute. I have two master's

7 degrees, one in nutrition from Tufts and one

8 from Harvard in ethics.

9 I'd like to urge many of us, you,

10 to stop viewing and talking about organic

11 consumers as if they're a nuisance, as if

12 they're misinformed, irrational and therefore

13 irrelevant. We've heard a lot of that over

14 the last couple of days and hours. 

15 It sounds a lot like conventional

16 agribusiness. They don't think very highly of

17 their customers either. But organics grew

18 because consumers are interested, because they

19 do care, because they are informed, and most

20 importantly because they want clean, safe and

21 responsibly-produced food, the same reason

22 that people collectively spent $30 billion
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1 last year on organic food to avoid the

2 pesticides and the GMOs that the FDA and the

3 EPA tells us are perfectly safe. 

4 It's the same reason they're

5 asking you now to remove antibiotics from

6 organic production, to ensure sugar beet fiber

7 and barley beta fiber; conventionally produced

8 ingredients, don't make their way into organic

9 foods and that all ingredients, including

10 ingredients of ingredients, no matter how they

11 got into the finished product and regardless

12 of whether they're listed in the ingredients

13 list -- that they be either organic or on the

14 National List. 

15 Organics is a vehicle for positive

16 change. People who buy organic do so to

17 support a food production system that does the

18 right thing. This is very much about ethics. 

19 Nobody expects the organic apple industry to

20 solve the global problem of resistance to

21 critically important antibiotics, but

22 consumers expect organics to be part of the
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1 solution. They expect organic producers to do

2 the right thing. And they certainly don't

3 expect organics to be part of the problem,

4 which in the case of antibiotics it is. 

5 Consumers feel betrayed when they are informed

6 that the organic foods they were buying, that

7 the organic seal that they trusted is not what

8 they thought it was. 

9 And organic consumers expect all

10 ingredients to be either organic or on the

11 National List. This is backed by solid

12 consumer survey data. And no, OFPA does not

13 state that consumer expectations are one of

14 the criteria, but in this case the consumer

15 expectation does not come out of nowhere. It

16 comes from OFPA, which does not distinguish

17 between ingredients and other ingredients and

18 requires all ingredients to be either organic

19 or on the National List. 

20 So here's Cornucopia's

21 recommendation, and it's a simple one: Follow

22 the law. The organic industry needs to be
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1 honest. Consumers are told that unreviewed

2 synthetics do not end up in organic food, but

3 they do as ingredients of ingredients that are

4 because of faulty FDA labeling laws not listed

5 in the ingredients list. They look to you to

6 follow the law in this case. 

7 The NOSB needs to do everything in

8 its power to preserve consumer trust in the

9 organic label. The organic industry needs

10 consumer trust a lot more than a segment of

11 apple producers need antibiotics. And yes,

12 consumer trust is more important to all of us

13 than the unreviewed and unapproved potentially

14 harmful ingredients that end up in organic

15 foods as ingredients of ingredients. Thank

16 you.

17 CHAIRMAN STONE: Thank you,

18 Charlotte. Any questions from the Board? 

19 Jay?

20 MEMBER FELDMAN: Thank you,

21 Charlotte. I'm interested in the discussion

22 that John had earlier with; I'm sorry, I
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1 forget her name, the other witness on the

2 fiber issue. There's a patent, and I guess

3 the question that we would need to know is

4 whether that is unique to this particular

5 petition and the materials that are associated

6 with the petition and how you would view the

7 Board's responsibility in terms of evaluating

8 the genetically engineered component of that

9 as distinct from other inputs that might fall

10 under the petition that would not be affected

11 by a genetically engineered substrate or

12 ingredient to the process.

13 MS. VALLAEYS: Well, I think in

14 the case of barley beta fiber what our

15 volunteer Cornucopia member said organic

16 consumers said is it's about everything about

17 this barley beta fiber, the fact that it is

18 not essential. You can get fiber from whole

19 foods. And I think that it does come as a

20 shock to consumers when they find out that

21 non-essential, in this case, marketing tools

22 that are not organic, that are treated with
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1 fumigants, with pesticides, in this case with

2 GMO enzymes are added. And I mean we would,

3 you know, certainly hope that the certifiers

4 would look at the GMO enzymes, and if there

5 are GMO enzymes, would not allow them. But in

6 this case Cargill appears to be the only

7 producer of barley beta fiber. And so it's

8 one of the many components that contributes to

9 our concern about this particular petition.

10 MEMBER FELDMAN: Have we faced

11 this before? Have we faced this sort of

12 question before where a material that's being

13 petitioned appears to have an individual

14 component that's essential to the production

15 of that material or that substance known to be

16 genetically engineered and we sort of say,

17 well, we don't know? We're going to put on

18 the List and let somebody figure out? I mean

19 do you believe that to be the responsibility

20 of the Board or the petitioner to ensure that

21 we know whether there are other practices or

22 other inputs that could fit under this new
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1 listing that are not genetically engineered? 

2 I mean do we have that burden as a Board to

3 know that?

4 MS. VALLAEYS: Well, you know, it

5 comes back to the other ingredients

6 discussion, which is what is the

7 responsibility of the Board? And it fits very

8 nicely, because that's in part why for the

9 other ingredients issue we're saying it

10 actually should not be the responsibility of

11 the Board. It is the responsibility of the

12 Board to put very specific single materials on

13 the National List and then all the other

14 ingredients and all the -- you know, since --

15 well, and process aids, but in this case since

16 it's an excluded method, that the certifiers

17 will look very closely at that. And if it

18 does not fit the criteria and the law, that

19 those would not be allowed into organic foods.

20 And the reason we bring this up

21 here is because what we've discovered over the

22 past couple of years -- in looking very
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1 closely at some of the petition materials, we

2 discovered this was not happening. So that is

3 why we're bringing it up. It happened with

4 DHA algal oil. We saw the petition before the

5 Board and all of the other ingredients that

6 were in an organic baby food, which was

7 confirmed, were not in the petition, were not

8 reviewed and the certifiers were letting it

9 in. So that is why we're bringing up these

10 issues now. And it is relatively recent,

11 because it's something we discovered only a

12 couple of years ago.

13 MEMBER FELDMAN: So just to be

14 clear, in the absence of a policy like that,

15 this Board has historically taken action to

16 restrict some of the other ingredients. I

17 mean we did that on DHA. We happened to focus

18 in on one extractant, you know, hexane. But

19 we could have limited the other ingredients. 

20 I mean we have done that in a limited fashion. 

21 I guess the question I have, given that

22 there's a patent involved here and the
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1 petition is reliant on that patented process;

2 we know what that patented process is, do we

3 have a duty to address that in an annotation

4 or to address it when we're thinking about the

5 overall material? Not to say that there

6 aren't other issues that Board Members may

7 want to consider in voting this up or down. 

8 I'm just focused on the GMO issue right now.

9 CHAIRMAN STONE: All right. Nick?

10 MEMBER MARAVELL: Yes, Charlotte,

11 I'm referring now to our other ingredients

12 policy that's been proposed here to the Board. 

13 I know we don't have two or three hours to sit

14 and discuss it in detail, you and I right here

15 in this venue, but I mean if you could say

16 I've got two major concerns and this is what

17 I would do to fix it, what might those be? 

18 You know, just briefly what is it that you

19 feel would set the Board --

20 MS. VALLAEYS: Sure.

21 MEMBER MARAVELL: -- going in the

22 best possible direction?
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1 MS. VALLAEYS: Well, when the memo

2 from the USDA was received in 2011, November

3 2011, it was to develop a policy. And so we

4 don't think that putting more work on the

5 Board to review all the other ingredients is

6 necessarily the solution. It could be as easy

7 as a policy that you as the Board are saying

8 to the organic community, to certifiers, to

9 industry, saying every ingredient, including

10 ingredients of ingredients, including those

11 that the consumer doesn't see, but that are on

12 the spec sheets that certifiers see; that is,

13 the certifier who makes sure that all those

14 other ingredients are either organic or on the

15 National List. 

16 And that seems to be a very simple

17 solution that would be very lawful, you know,

18 following the law that would be simple for you

19 as well. So you would be reviewing individual

20 single substances. And then if manufacturers

21 need other ingredients, that those be reviewed

22 by the certifier. And obviously if we had it
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1 our way, yes, the FDA labeling laws would

2 change and the consumer would also be able to

3 see those. But since that's not the case, we

4 believe it is the job of the certifiers to

5 make sure that everything that ends up in an

6 organic food is organic or on the National

7 List.

8 So the second thing; because you

9 asked for two, is if a manufacturer of another

10 ingredient says I absolutely need material X

11 to make this ingredient, then they could

12 petition that for the specific use in the

13 ingredient that they need it for. And then

14 again, it would be a very transparent process. 

15 Consumers would know, the public would know

16 what's going into which foods, and then it

17 would be reviewed according to OFPA's criteria

18 again. So if they say I need material X, but

19 it turns out that's harmful to human health,

20 then it is up to the NOSB to review it and

21 ensure the public that indeed what they are

22 buying as organic, that everything in it has
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1 been carefully reviewed and meets the legal

2 criteria for being in organic food.

3 MEMBER MARAVELL: Let me just

4 clarify. So you're saying in certain

5 instances an additional petition -- that would

6 represent something different than what is

7 currently going on, that an additional

8 petition would be required? Is that what

9 you're saying? I'm not quite following. 

10 You're saying that an additional petition for

11 something that we're calling an other

12 ingredient may be called for?

13 MS. VALLAEYS: Right. So if there

14 is a preservative that a manufacturer says

15 they need for rennet or any of the other

16 ingredients already on the National List, that

17 they petition that, that they say I need this

18 to make my rennet which is on the National

19 List. And then they petition that. And then

20 that material could be on the National List. 

21 And OFPA states that the National List should

22 list materials for their specific use or
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1 application. So then it could say for the

2 specific use of rennet, but nothing else. And

3 then it's up to you to decide.

4 MEMBER MARAVELL: And is it

5 possible that the Board could have already

6 decided broad classes of materials that are

7 either prohibited or permitted with regard to

8 rennet, and so that petition might not be

9 necessary? Do you see that as a possibility?

10 MS. VALLAEYS: Are you saying that

11 you review all the ingredients and put it in

12 an annotation, for example?

13 MEMBER MARAVELL: Well, we might

14 review classes of ingredients that we would

15 say would meet OFPA standards unless there was

16 some reason not to. Yes, I mean in other

17 words do you perceive that that could occur,

18 that the Board could review rennet and comment

19 on major categories?

20 MS. VALLAEYS: So like synthetic

21 preservatives you can --

22 MEMBER MARAVELL: Yes, we could
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1 say for example no synthetic preservatives. 

2 I'm just making that up. Do you see that as

3 a possibility?

4 MS. VALLAEYS: Well, there's a

5 concern there when you start putting in the

6 annotations, first of all, the concerns we've

7 heard from the USDA, but our concern would be

8 if there are prohibitions in an annotation,

9 the danger there is that a petitioner tells

10 the Board the ingredients, the other

11 ingredients they're using. You review those

12 and those get prohibited, which would open the

13 door to a competitor which maybe uses

14 something else. Since that has not been

15 reviewed and they're not prohibited, those

16 would then -- and it would not be a level

17 playing field. It would put the petitioner at

18 a competitive disadvantage and I'm sure that's

19 the last anybody here wants to do.

20 MEMBER MARAVELL: No, that's

21 another issue which is prohibited versus

22 permitted. But, yes. Okay. I was just
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1 exploring this with you. Thank you. 

2 CHAIRMAN STONE: All right. 

3 Harold, if you'll wrap this up?

4 MEMBER AUSTIN: Hi, Charlotte.

5 MS. VALLAEYS: Hi.

6 MEMBER AUSTIN: In your comments

7 you mentioned a little bit tetracycline; go

8 figure, and the consumers. The consumers are

9 definitely an intricate part of the organic

10 community, and I think we all respect that. 

11 And I think we all know that those that are

12 growers/producers, they can produce their

13 little hearts out. And if there's not a

14 consumer out there to eat the products of

15 their labor, the fruits of their labor, it's

16 all for naught. 

17 But we're talking about an issue

18 that is very passionate, very emotional on all

19 sides of the equation where we have a group of

20 stakeholders that are using a material that is

21 actually on the National List. They've

22 developed their livelihoods. They've
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1 developed their farms, their practices as part

2 of their process, not necessarily a basic

3 fundamental, but as a tool that they can use

4 to get from one point to another.

5 How do we move forward as an

6 organic community to find a point of

7 commonality to where we can support the

8 various components of the organic industry and

9 the stakeholders and I mean -- and that's from

10 growers to retailers to the consumers

11 ultimately themselves, to where we can not

12 make the accusations and not make he said, she

13 said, they said, we said, but a point of

14 commonality to where we can agree to agree for

15 the benefit of all and for most importantly

16 for the organics to move forward? On an issue

17 like this how do we move forward? 

18 This is one of those ones where in

19 2011 there was a resolution, there was an

20 expiration date, there was a challenge put

21 forth to a group of stakeholders to go out and

22 redefine their processes, to come back, show
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1 that they're making progress to move away from

2 that material. And I think there are strives

3 to get there and I think all of the tree fruit

4 growers anywhere that you talk to are going to

5 be striving and are striving to get to that

6 point so that the consumers can have full

7 confidence that an antibiotic like

8 tetracycline is not being used. 

9 But in the interim how do we work

10 together as a group of organic stakeholders on

11 all spectrums to achieve that? What are your

12 thoughts there?

13 MS. VALLAEYS: Well, I think for

14 the antibiotics issue there's a lot of emotion

15 definitely, but what bothers me sometimes is

16 when the consumer groups are the ones that are

17 accused of being emotional, of not being

18 scientific, when we are basing our concerns on

19 Dr. Morris, on the physicians, on the World

20 Health Organization saying we need this

21 particular antibiotic, and every time it is

22 used in an agricultural setting we are risking
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1 losing that. That's what we're basing our

2 emotions on.

3 And then we have to -- the

4 consumer groups, the Cornucopia -- have to

5 listen to the producers who get up here and

6 are also very emotional, are saying I'm going

7 to watch all my trees die. How is that not

8 emotional? So we're saying we are not

9 irrational. Cornucopia is not -- we are

10 science-based as much as -- well, we base

11 everything that we say on sound science. And

12 there can be different -- within science there

13 are different viewpoints and different

14 conclusions and there's absolutely no doubt

15 about that.

16 But what we're going to base it on

17 is the -- and this has happened before, on the

18 independent scientists or on the scientists

19 who have concerns to consumers. And so as a

20 farmer group, because most of our members --

21 we have 8,000 members. Most of them are

22 farmers. We do represent our members. And
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1 when we did the survey and discovered that in

2 fact there were lots of apple growers who were

3 saying I don't use antibiotics. And we'll

4 have a volunteer read some of those comments

5 later today who are saying I am organic and I

6 don't want organic to be part of this problem. 

7 I want organic consumers to be able to trust

8 organics. And that is important. 

9 And I think that that's more

10 important than anything else. You cannot

11 gamble with your customers, with your

12 consumers because they are the ones spending

13 $30 billion because they trust it. If you

14 lose that, you lose everything. And I think

15 that's serious and that's not something to be

16 taken lightly. And that was my concern in my

17 testimony, is that I feel it is kind of

18 ridiculed. Consumers are important and we

19 can't lose sight of that. 

20 CHAIRMAN STONE: Thank you,

21 Charlotte. Allyson Kelly to the podium and 

22 Troy Aykan on deck.
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1 MS. KELLY: Hello, my name is

2 Allyson Kelly. I'm the organic program

3 manager for the Hain Celestial Group. 

4 We wish to offer our support for

5 the Handling Committee's proposal on other

6 ingredients. We also support the excellent

7 comments made on this topic by Gwendolyn Wyard

8 of the Organic Trade Association.

9 As organic program manager, it is

10 my responsibility to make sure that we

11 maintain all of the documentation required for

12 over 1,000 organic products and the thousands

13 of ingredients that we use. We have a whole

14 team of people who spend virtually all of

15 their time obtaining documents from ingredient

16 suppliers and new documents have to be

17 obtained every 12 to 18 months, even if

18 nothing has changed. 

19 To add to that, at inspection time

20 the inspectors want to see hard copies of all

21 of this documentation, which I spend hours and

22 days and weeks compiling and sending out to
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1 more than two dozen of our certified

2 facilities a year. We've killed more trees

3 than Mount Saint Helens when it exploded and

4 the ingredient suppliers are sick of filling

5 out all of these documents. We welcome the

6 recommendations by Mr. McEvoy encouraging

7 sound and sensible practices that will

8 hopefully lighten these paperwork

9 requirements.

10 We use many ingredients that are

11 on Section 605 and 606 of the National List. 

12 The companies that make these ingredients do

13 about 99 percent of their business with

14 conventional food companies. Because our

15 order quantities are relatively small, one of

16 our greatest challenges is sourcing

17 ingredients that meet this National List

18 criteria, such as non-GMO, no radiation, no

19 sewage sludge and additional requirements

20 described in the annotations.

21 The Handling Committee proposal

22 describes the possible stipulation that
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1 agricultural other ingredients be organically

2 produced. We strongly urge the Board to not

3 require that these incidental additives be

4 organic. They are using extremely small

5 quantities, therefore their use will not

6 increase or organic production.

7 More importantly, many suppliers

8 will not add inventories of organic

9 ingredients that are used in such small

10 quantities and they will create entirely

11 separate products for the comparatively tiny

12 organic trade. While we understand and

13 support the desire to promote the use of

14 organic ingredients, the majority of

15 ingredients suppliers will not do it and this

16 will make it even more difficult to source the

17 ingredients that we need.

18 We would also like to make a

19 comment on the Committee proposal that

20 describes special questions to assess the

21 role, essentiality and viability of

22 alternatives to the other ingredients in a
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1 substance. Before the Board makes any

2 decisions regarding the role or essentiality

3 of other ingredients or viable alternatives,

4 we strongly request that during the review

5 process, the Board should get input from all

6 stakeholders, especially ingredient

7 manufacturers. On the ingredient suppliers

8 have the in-depth knowledge of their own

9 manufacturing processes and the needs of their

10 customers to do this assessment. 

11 The comments I'm making do not

12 require structural changes to the Committee

13 proposal. They pertain to how the Board

14 implements the policy. We strongly support

15 the Committee proposal. The proposal is

16 sound, thorough and practical and it provides

17 for input from all stakeholders. Thank you.

18 CHAIRMAN STONE: Thank you,

19 Allyson. Questions for Allyson? Thank you

20 very much. 

21 MS. KELLY: Thank you.

22 CHAIRMAN STONE: Troy Aykan to the
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1 podium and Zareb Herman on deck.

2 MR. AYKAN: Okay. Good morning. 

3 My name is Troy Aykan. I'm a food scientist

4 and a lawyer. I am legal counsel for the

5 intellectual group for the regulatory and on

6 my spare time I teach food laws and

7 regulations at Cal Poly Pomona and Chapman

8 University since 2002. I will also be

9 teaching the same class at Chapman University

10 School of Law later this year.

11 I will be addressing the Board on

12 the topic of other ingredients. OFPA requires

13 that other ingredients be evaluated as a part

14 of the consideration of substances for

15 inclusion on the National List. The law

16 expressly states that the NOSB shall work with

17 manufacturers of substances considered for

18 inclusion on the proposed National List to

19 obtain a complete list of ingredients and

20 submit to NOP, along with the proposed

21 National List listing or any proposed

22 amendments to such list, the results of the
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1 Board's evaluation and the evaluation of the

2 Technical Advisory Panel of all substances

3 considered for inclusion on the National List.

4 There is no mention of the word

5 ingredient or single ingredient in the law

6 governing National List or the NOSB. The OFPA

7 does not require other ingredients to be

8 separately listed on the National List. There

9 is no requirement or restriction against use

10 of other ingredients other than following the

11 law which prescribes technical review,

12 evaluations, public comments, voting and power

13 to amend. Therefore, there's no requirement

14 that other ingredients be petitioned

15 separately in the law or regulations.

16 The other ingredients occur at

17 insignificant levels in finished products and

18 may be considered as incidental additives. 

19 Historically, other ingredients have been

20 reviewed as a part of the technical reports

21 and by the NOSB, and they are subject to

22 public comments and NOSB vote. 
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1 We strongly support the current

2 Handling Committee proposal. It's quite

3 rigorous and it fully complies with the

4 requirements of the OFPA and the regulations. 

5 Other ingredients will be reviewed as part of

6 new petitions and they will be reviewed during

7 the sunset review of all substances currently

8 on the National List. This process is

9 transparent and allows for input from all

10 stakeholders. Therefore, petitions are

11 totally unnecessary as well as totally

12 impractical. It would be impossible to

13 process petitions for every possible other

14 ingredient. We urge the Board to approve the

15 Handling Committee proposal. Thank you. Any

16 questions, please?

17 CHAIRMAN STONE: Thank you. 

18 Questions? Thank you very much.

19 MR. AYKAN: Thank you.

20 CHAIRMAN STONE: Zareb to the

21 podium and Trace Tipton on deck.

22 MR. HERMAN: Good morning. My
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1 name is Zareb Herman. I am a nutritionist and

2 food scientist with the Hain Celestial Group. 

3 I am here to support the Handling Committee

4 proposal on other ingredients. 

5 In the early 1970s my family grew

6 organic apricots in Southern California. Back

7 then, we didn't call crops organic, but we

8 wanted to grow fruit the natural way without

9 chemical pesticides. I've been involved in

10 natural and organic foods for most of my life,

11 managing a natural food store, doing research

12 on citrus trees and for the last 21 years I've

13 been doing R&D and regulatory for an organic

14 food manufacturer.

15 Last month I was speaking with two

16 former NOSB members at the Natural Products

17 Expo in Anaheim, California. We were

18 lamenting that until a few years ago NOSB

19 meetings which much less polarized and more

20 reasonable. People had differences of

21 opinion, but we could generally compromise and

22 work things out so the organic industry could
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1 keep growing. It may be unrealistic in this

2 age of politics, but I hope that we can return

3 to this former approach, because after all we

4 should all share the goal of increasing the

5 use of organic foods and growing the industry.

6 This brings me to the Committee

7 proposal on other ingredients. The proposal

8 provides for a thorough review of other

9 ingredients during the petition process and

10 during each sunset review. If anyone objects

11 to any ingredient, they can submit written and

12 oral comments to their heart's desire. 

13 This brings me to the suggestion

14 by some that every single ancillary substance

15 must go through the petition process. Do we

16 really want to go through the petition process

17 for every incidental additive? This process

18 would take so long, we will all be dead or

19 wish we were dead before it could happen.

20 And as stated by others, we do not

21 have the resources to do it and it is

22 unnecessary because the current proposal more
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1 than allows for public comment and debate. 

2 Let's look at the consequences of

3 requiring petitions. Over 50 percent of

4 organic sales are for processed organic foods. 

5 Almost all of these products require

6 substances from the National List for their

7 production and many of these substances

8 require other ingredients. The petition

9 process would get so bogged down that these

10 other ingredients would never get approved and

11 without them there will be no flavors, colors,

12 enzymes, microorganisms, yeast, vitamins,

13 minerals and many other substances. Without

14 these substances, companies will not be able

15 to manufacture most processed organic foods. 

16 The entire organic industry will be devastated

17 and thousands of organic farms will likely

18 revert to conventional agriculture resulting

19 in increased use of chemical pesticides,

20 herbicides and fertilizers. 

21 For these reasons I strongly urge

22 you to support the Committee proposal. Thank
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1 you.

2 CHAIRMAN STONE: Thank you. 

3 Questions? All right. Thank you very much. 

4 Trace Tipton to the podium and, it will sound

5 different when she says it because I say it

6 slow, Lindsay Fernandez-Salvadore on deck.

7 MR. TIPTON: Good morning. My

8 name is Trace Tipton. I do regulatory affairs

9 for Suterra just over the hill here in Bend,

10 Oregon. My comments are actually related to

11 the review of other ingredients for crop

12 inputs, not necessarily with the handling

13 section of it, but I appreciate you giving me

14 a couple minutes to present this. I have

15 submitted written comments to the NOSB Board

16 and NOP throughout the years and I've never

17 had the chance to speak to you at this type of

18 venue, but I thank you for coming to Oregon.

19 I'll be brief today. My comments

20 are just about the replacement of the 7 CFR

21 205.601 exemptions for inerts that are

22 currently based on the old U.S. EPA List 4,
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1 and in the case of passive pheromone products,

2 List 3 ingredients. The mechanics of the NOP

3 exemptions are surely in need of an update as

4 the U.S. EPA lists have not been updated for

5 several years now. 

6 To start I'd like to thank past

7 and present NOSB and NOP decision makers for

8 their level-headed treatment of pheromone9 based products. From the earlier days with

10 the use of pheromones just in insect/pest

11 traps and monitoring lures and the integration

12 of these with temperature records, degree13 days, pest control models to today the use of

14 pheromones in actual pest control products we

15 have seen that the benefit has been

16 tremendous. Anybody familiar with the pome

17 fruit industry can attest to the benefits of

18 disrupting the normal mating cycle of that

19 proverbial worm in the apple, the codling

20 moth.

21 These pest products have been

22 available to organic growers for many years
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1 based on the old EPA lists. In some cases the

2 substances in question are things that are

3 sitting all over the room here. Cellulose

4 paper for your coffee cup, polyethylene

5 materials for dispensers. Folks are drinking

6 their morning coffee in cups and lids that are

7 made out of these same materials. These

8 materials do not contaminate organic crops,

9 they do not leave harmful residues and they

10 are completely compatible with organic farming

11 practices. They're necessary for the

12 economical application of pheromones in the

13 field. 

14 And during your upcoming

15 deliberations about them, I'd only ask that

16 you please keep in mind that many of them are

17 ubiquitous in the world around us, have

18 already undergone extensive EPA review in

19 order to be placed on EPA's List 4 initially. 

20 And in the case of the List 3s for passive

21 pheromone hand-applied products only, they

22 simply do not come into significant contact
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1 with organic materials when used according to

2 their labeling.

3 The benefits of continued use of

4 these other ingredients clearly outweigh any

5 hazard or risk and the continued exemptions

6 for them will allow organic growers to

7 continue to benefit from the use of pheromone

8 active ingredients in the field. Thank you.

9 CHAIRMAN STONE: Thank you for

10 taking time to be here and submitting written

11 comments and tracking our work so we can get

12 your input. We appreciate that.

13 Question?

14 Very good. Thank you very much

15 for taking time to be here.

16 So, Lindsay, if you'll state your

17 name so they hear the non-Kentucky version,

18 and we'll go from there.

19 MS. FERNANDEZ-SALVADORE: And

20 accent, too. Good morning. My name is

21 Lindsay Fernandez-Salvadore with OMRI.

22 (Laughter.)
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1 MS. FERNANDEZ-SALVADORE: And I am

2 the program director at OMRI. I really think

3 today that my comments will be quick and

4 painless in comparison to what you were

5 hearing yesterday. I'm commenting on the

6 proposal on ancillary substances, or formerly

7 known as other ingredients. We are pleased

8 with the changes made to the recommendation

9 that Zea presented. For the most part they

10 clarify the confusions that we had about the

11 intent of the document.

12 We understand now that if the

13 proposal is adopted by the full NOSB today

14 that we should wait for further guidance from

15 the NOP on how OMRI as a material review

16 organization should proceed when reviewing

17 processing ingredients that may contain

18 ancillary substances. In the meantime, we

19 will continue with our current procedure that

20 we have established and published for the

21 review of such ancillary substances.

22 Overall we find the recommendation
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1 to be clear and the revised procedures will

2 lead the NOSB through this complex subject in

3 a structured, transparent manner. We will be

4 happy to provide comments on ancillary

5 substances as each 205.605 and 606 material

6 comes onto the docket. And we will also look

7 forward to bidding for the supplementary

8 technical reviews. Yay.

9 And so thank you for your hard

10 work on this proposal. See, painless?

11 CHAIRMAN STONE: Good. Great. 

12 Thanks. Question?

13 Great. Thank you very much. 

14 Thanks for all your -- 

15 MR. FELDMAN: I have a question. 

16 Sorry.

17 CHAIRMAN STONE: Oh, I'm sorry,

18 Jay. 

19 MEMBER FELDMAN: Thank you. Thank

20 you, Lindsay. I'm trying to reconcile the

21 role of the MROs with the role of the NOSB on

22 this. I mean it was suggested earlier by
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1 Charlotte that the certifiers play maybe more

2 of role. I mean you're waiting for guidance

3 from NOP, but how does that square with the

4 Board's responsibility to ensure that the

5 materials that are in certified organic

6 products are in compliance with OFPA and are

7 reviewed by the Board and put on the National

8 List, or at least held to the National List

9 criteria?

10 MS. FERNANDEZ-SALVADORE: It

11 doesn't. I would say that there's two

12 separate processes. So whatever you decide on

13 today is one procedure, and I'm sure that will

14 guide the NOP on their further guidance.

15 MEMBER FELDMAN: And what about

16 Charlotte's point that if we create a negative

17 annotation as opposed to an annotation that

18 specifies allowed ingredients, if we were to

19 go that route, that we're creating competitive

20 disadvantage for the original petitioner so

21 that new petitioners can come in with

22 replacement ingredients that are not
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1 prohibited by the annotation and fill that

2 part of the market?

3 MS. FERNANDEZ-SALVADORE: I really

4 can't comment on Charlotte's comments. I just

5 can't answer that question. I'm sorry.

6 MEMBER FELDMAN: Well, what if I

7 were to propose that we have a negative

8 annotation? Could manufacturers come in and

9 use that approved listing with other

10 ingredients? Would you as an MRO allow other

11 ingredients that were not specifically

12 prohibited?

13 MS. FERNANDEZ-SALVADORE: If that

14 was the guidance from the NOP, yes. But

15 again, the NOP hasn't provided that guidance

16 and I understand that this is not what we as

17 an MRO are supposed to do with this proposal,

18 that the NOP will provide that guidance.

19 MEMBER FELDMAN: Thank you.

20 MS. FERNANDEZ-SALVADORE: Thanks.

21 CHAIRMAN STONE: Thanks, Lindsay. 

22 Thanks for all your support for the organic
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1 industry.

2 That concludes the public comment

3 for the Handling Committee. We're just about

4 10 minutes behind. Not bad. We have a lot to

5 do before lunch so that we have plenty of time

6 for robust discussion after lunch, so be in

7 your seats, Board Members and audience, please

8 promptly at five after 10:00.

9 (Whereupon, the above-entitled

10 matter went off the record at 9:55 a.m. and

11 resumed at 10:09 a.m.)

12 CHAIRMAN STONE: Board's going to

13 go back in session. So I think the Handling

14 Committee is prepared to work through a

15 discussion and vote on four materials, I

16 believe, John?

17 MEMBER FOSTER: Yes.

18 CHAIRMAN STONE: And we plan to

19 put ancillary substances to the after lunch

20 session. So the motion or recommendation is

21 on the table if anyone will -- John will get

22 it up and I think Joe may be leading the first
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1 one. And Michelle can put sulfuric acid up on

2 the screen, please. So I'll turn to over to

3 John.

4 MEMBER FOSTER: All right. Well,

5 I guess it's my turn to figure out how to

6 delay just a moment until Joe gets back.

7 All right. So we have the

8 proposal up on the screen. We made no changes

9 to it in the interim, but I do want to make

10 sure we follow through on opportunities to

11 have discussion beyond clarification on the

12 material. 

13 So you all heard the summary of

14 proposed action on sulfuric acid. 

15 MEMBER DICKSON: Was a motion

16 made?

17 MEMBER FOSTER: A motion has not

18 yet been made. I was hoping you might be able

19 to do that.

20 MEMBER DICKSON: I would like to

21 move to accept the Committee -- or, I'm sorry,

22 we're classifying first. I move to classify
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1 sulfuric acid as a synthetic substance.

2 MEMBER FOSTER: Is there a second?

3 MEMBER AUSTIN: I'll second that.

4 MEMBER FOSTER: Thank you, Harold. 

5 Before I ask for further discussion, I want to

6 ask on materials what we want to do with

7 declaration of interests. Anyone have a

8 declaration of interest they'd like to make at

9 the present time? Zea?

10 MEMBER SONNABEND: I do work for a

11 certifier who may or may not in the future

12 allow products with any materials that we vote

13 onto the National List.

14 MEMBER FOSTER: Mac?

15 CHAIRMAN STONE: And just to be

16 clear this is for each of these four

17 materials, not just sulfuric acid. We'll get

18 that on the table.

19 MEMBER SONNABEND: Not to mention

20 other ingredients maybe in some of the

21 certified products. 

22 MEMBER FOSTER: Thank you for
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1 mentioning that. Are there any other

2 declarations that need to be made here?

3 I'll go ahead and say our

4 company's farming operation doesn't use it,

5 but I imagine at least one the suppliers we

6 work with, it's likely someone would intend on

7 using it.

8 Okay. That's it for declarations. 

9 So now do we have further discussion on the

10 classification motion for sulfuric acid?

11 All right. Hearing none, then I

12 think we can proceed to a vote. 

13 CHAIRMAN STONE: Okay. The voting

14 will begin with Carmella.

15 MEMBER BECK: Yes.

16 MEMBER SONNABEND: No.

17 MEMBER FELDMAN: This is the

18 synthetic.

19 MEMBER SONNABEND: Oh, the

20 synthetic? Sorry. Yes, synthetic.

21 MEMBER FELDMAN: Yes.

22 MEMBER RICHARDSON: Yes.
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1 MEMBER DICKSON: Yes.

2 MEMBER FOSTER: Yes.

3 MEMBER WALKER: Yes.

4 MEMBER FULWIDER: Yes.

5 MEMBER AUSTIN: Yes.

6 MEMBER TAYLOR: Yes.

7 MEMBER MARAVELL: Yes.

8 MEMBER THICKE: Yes.

9 MEMBER BONDERA: Yes.

10 MEMBER FAVRE: Yes.

11 CHAIRMAN STONE: Chair votes yes.

12 MEMBER FOSTER: Thank you. Do we

13 have a motion for listing of sulfuric acid?

14 MEMBER DICKSON: I move to accept

15 the Committee's recommendation to add sulfuric

16 acid to 205.605(b).

17 MEMBER FOSTER: Do we have a

18 second?

19 MEMBER RICHARDSON: Second.

20 MEMBER FOSTER: Thank you, Jean. 

21 Further discussion?

22 CHAIRMAN STONE: Just to clarify,
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1 Francis, remind you that the motions are

2 always made in the positive.

3 MEMBER FOSTER: All right. Back

4 to further discussion.

5 All right. Hearing none, then we

6 proceed to vote.

7 CHAIRMAN STONE: Okay. The voting

8 will begin with Zea.

9 MEMBER SONNABEND: No.

10 MEMBER FELDMAN: No.

11 MEMBER RICHARDSON: No.

12 MEMBER DICKSON: No.

13 MEMBER FOSTER: No.

14 MEMBER WALKER: No.

15 MEMBER FULWIDER: No.

16 MEMBER AUSTIN: No.

17 MEMBER TAYLOR: No.

18 MEMBER MARAVELL: No.

19 MEMBER THICKE: No. 

20 MEMBER BONDERA: No.

21 MEMBER FAVRE: No.

22 MEMBER BECK: No.
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1 CHAIRMAN STONE: No.

2 MEMBER FOSTER: How did we come

3 out?

4 CHAIRMAN STONE: Vote was

5 unanimous.

6 MEMBER WALKER: Yes.

7 MEMBER FOSTER: All right. Next

8 item up is barley beta fiber. Michelle, could

9 we have the proposal up? 

10 All right. I will make a motion

11 to classify barley beta fiber as petitioned as

12 agricultural. Is there a second? 

13 MEMBER RICHARDSON: Second.

14 MEMBER FOSTER: Thank you, Jean. 

15 Further discussion on barley beta fiber? Zea?

16 MEMBER SONNABEND: Okay. I'll

17 start the discussion. I originally abstained

18 on this coming out of Committee because I

19 wanted to hear from the public comments that

20 came in from manufacturers who felt that this

21 was actually needed in organic products

22 because I don't feel like I personally can
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1 judge whether something is needed or not in an

2 organic product. And so I have trouble with

3 most of the 606 items.

4 The fact that we heard no

5 companies submit testimony that they needed

6 this in their organic product has made we

7 decide to vote no on this material. Aside

8 from other questions that I do have about its

9 appropriateness and availability of other

10 alternatives, it seems clear that there are

11 other alternatives since nobody really

12 requested it. 

13 MEMBER FOSTER: Thank you, Zea. 

14 More discussion?

15 All right. Then I think we can

16 proceed to vote then on the listing motion. 

17 I'm sorry, yes, on classification.

18 CHAIRMAN STONE: Voting will begin

19 with Jay.

20 MEMBER FELDMAN: Yes.

21 MEMBER RICHARDSON: Yes.

22 MEMBER DICKSON: Yes.
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1 MEMBER FOSTER: Yes.

2 MEMBER WALKER: Yes.

3 MEMBER FULWIDER: Yes.

4 MEMBER AUSTIN: Yes.

5 MEMBER TAYLOR: Yes.

6 MEMBER MARAVELL: Yes.

7 MEMBER THICKE: Yes.

8 MEMBER BONDERA: Yes.

9 MEMBER FAVRE: Yes.

10 MEMBER BECK: Yes.

11 MEMBER SONNABEND: Yes. 

12 CHAIRMAN STONE: Chair votes yes. 

13 Vote was 15-0, unanimous.

14 MEMBER FOSTER: Moving on to a

15 listing motion, I would move to list barley

16 beta fiber as petitioned at 205.606. Is 

17 there --

18 MEMBER RICHARDSON: I second that.

19 MEMBER FOSTER: Oh, thank you,

20 Jean. Further discussion on the listing

21 motion?

22 Okay. Surprisingly, I guess to
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1 me, no discussion. We'll proceed to vote

2 then.

3 CHAIRMAN STONE: The voting to --

4 I'll just try to get a little more thorough in

5 my delivery here.

6 MEMBER FOSTER: This is to list

7 barley beta fiber as petitioned at 205.606.

8 CHAIRMAN STONE: Good. Voting

9 will begin with Jean.

10 MEMBER RICHARDSON: No.

11 MEMBER DICKSON: No.

12 MEMBER FOSTER: Yes.

13 MEMBER WALKER: No.

14 MEMBER FULWIDER: No.

15 MEMBER AUSTIN: Yes.

16 MEMBER TAYLOR: No. 

17 MEMBER MARAVELL: No.

18 MEMBER THICKE: No.

19 MEMBER BONDERA: No. 

20 MEMBER FAVRE: No.

21 MEMBER BECK: Yes.

22 MEMBER SONNABEND: No.
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1 MEMBER FELDMAN: No.

2 CHAIRMAN STONE: No. Three yes,

3 twelve no. Motion fails.

4 MEMBER FOSTER: All right. Moving

5 onto sugar beet fiber. Thank you, Michelle. 

6 First we'll do classification motion. I would

7 move to classify sugar beet fiber as

8 petitioned as agricultural.

9 MEMBER BONDERA: I'll second that.

10 CHAIRMAN STONE: Thank you,

11 Colehour. Any discussion on the

12 classification motion?

13 Seeing none, we can proceed to

14 vote.

15 CHAIRMAN STONE: The voting will

16 begin with Joe.

17 MEMBER DICKSON: Yes.

18 MEMBER FOSTER: Yes.

19 MEMBER WALKER: Yes.

20 MEMBER FULWIDER: Yes.

21 MEMBER AUSTIN: Yes.

22 MEMBER TAYLOR: Yes. 
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1 MEMBER MARAVELL: Yes.

2 MEMBER THICKE: Yes.

3 MEMBER BONDERA: Yes. 

4 MEMBER FAVRE: Yes.

5 MEMBER BECK: Yes.

6 MEMBER SONNABEND: Yes.

7 MEMBER FELDMAN: Yes.

8 MEMBER RICHARDSON: Yes.

9 CHAIRMAN STONE: Yes. Fifteen

10 yes, no nos.

11 MEMBER FOSTER: All right. We'll

12 move onto the listing motion for sugar beet

13 fiber. I would move to list sugar beet fiber

14 as petitioned on 205.606. Is there a second?

15 MEMBER FAVRE: Second.

16 MEMBER FOSTER: Thank you. 

17 Further discussion on the listing motion? 

18 Zea?

19 MEMBER SONNABEND: The exact same

20 comment I said for the barley beta fiber

21 applies to this. I was curious to see if

22 anyone really wanted this in their organic
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1 products and so I abstained, but the comments

2 came in that made it clear that there does not

3 seem to be a demand for it. And there are

4 some troubling issues that arise from approval

5 of this, and so I have decided to vote no.

6 MEMBER FOSTER: More discussion on

7 this item?

8 I would just ask could you get in

9 what are the troubling issues, you know, that

10 you just mentioned?

11 MEMBER SONNABEND: Yes. The fact

12 that in order to assure that there's no GMOs

13 it pretty much confines us to product only

14 from Sweden, and I think that puts a real

15 hardship on certifiers. You know, there's

16 just no way that any domestic sugar beet fiber

17 would not be potentially GMO, and so it's sort

18 of favoring this one manufacturer. And there

19 seem to be plenty of alternatives, or we would

20 have heard from people about why this was the

21 only type of fiber that they would possibly

22 need. 
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1 So those are the two main factors,

2 although considering, you know, if they find

3 a way to grow sugar beets organically, then

4 maybe it would be appropriate I guess, but

5 otherwise no.

6 MEMBER FOSTER: Okay. Thank you. 

7 More discussion? Oh, Colehour?

8 MEMBER BONDERA: Thank you. You

9 know, I don't serve on the Handling Committee,

10 but in my review and reflection on the

11 essentiality and the compatibility, I can't

12 comfortably -- besides this whole relatively

13 large GMO question in my mind, sorry, I have

14 a difficult time supporting it even before or

15 independent of the testimony. 

16 MEMBER FOSTER: Thanks. All

17 right. I just want to reiterate I do have

18 faith in the certification system to make sure

19 that if genetic engineering is involved it's

20 going to be excluded. So I just want to get

21 that out there. It sounds like there's some

22 either confusion or doubt about that. I just
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1 want to say I don't doubt that, so I have

2 confidence in that system. 

3 Also, perhaps this isn't the best

4 example of it, but part of the discussion we

5 had was around the use of agricultural

6 byproducts, and I want to say that in this --

7 like I said, this may not be the best example

8 of it, but in general I want to recognize that

9 I think most of us, if not all of us in the

10 Subcommittee, were wanting to at least

11 recognize the value of trying to find uses for

12 agricultural food and ag byproducts, and this

13 is one. It may not be the best example, but

14 in general we supported that and look for

15 ways, you know, to find opportunities to use

16 that. 

17 So that was kind of the last item

18 in the discussions that we had in the

19 Subcommittee that I wanted to get out in this

20 record.

21 All right. Any last tidbits?

22 Then we'll proceed to vote.
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1 CHAIRMAN STONE: The voting begins

2 with John.

3 MEMBER FOSTER: No.

4 MEMBER WALKER: No.

5 MEMBER FULWIDER: No.

6 MEMBER AUSTIN: No.

7 MEMBER TAYLOR: No. 

8 MEMBER MARAVELL: No.

9 MEMBER THICKE: No.

10 MEMBER BONDERA: No. 

11 MEMBER FAVRE: No.

12 MEMBER BECK: No.

13 MEMBER SONNABEND: No.

14 MEMBER FELDMAN: No.

15 MEMBER RICHARDSON: No.

16 MEMBER DICKSON: No.

17 CHAIRMAN STONE: And no. So all

18 nos and zero yeses.

19 MEMBER FOSTER: All right. Last

20 of the materials in front of us today on the

21 Handling Committee is DBDMH. I'll go ahead

22 with a classification motion. Move to
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1 classify 1,3-Dibromo-5,5-Dimethylhydantoin as

2 petitioned as synthetic.

3 MEMBER AUSTIN: Second that.

4 MEMBER FOSTER: Thank you, Harold. 

5 Any discussion on the classification motion?

6 Seeing none, then we can proceed

7 to vote.

8 CHAIRMAN STONE: Voting begin with

9 Calvin. 

10 MEMBER WALKER: Yes.

11 MEMBER FULWIDER: Yes.

12 MEMBER AUSTIN: Yes.

13 MEMBER TAYLOR: Yes. 

14 MEMBER MARAVELL: Yes.

15 MEMBER THICKE: Yes.

16 MEMBER BONDERA: Yes. 

17 MEMBER FAVRE: Yes.

18 MEMBER BECK: Yes.

19 MEMBER SONNABEND: Yes.

20 MEMBER FELDMAN: Yes.

21 MEMBER RICHARDSON: Yes.

22 MEMBER DICKSON: Yes.
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1 MEMBER FOSTER: Yes.

2 CHAIRMAN STONE: Yes. Unanimous

3 yes.

4 MEMBER FOSTER: We'll move on to

5 listing motion. I move to list 1,3-Dibromo6 5,5-Dimethylhydantoin as petitioned on Section

7 205.605(b) of the National List. Is there a

8 second?

9 MEMBER RICHARDSON: Second.

10 MEMBER FOSTER: Thank you, Jean. 

11 Further discussion on this?

12 All right. Then we can proceed to

13 vote.

14 CHAIRMAN STONE: Voting begins

15 with Wendy.

16 MEMBER FULWIDER: No.

17 MEMBER AUSTIN: No.

18 MEMBER TAYLOR: No. 

19 MEMBER MARAVELL: No.

20 MEMBER THICKE: No.

21 MEMBER BONDERA: No. 

22 MEMBER FAVRE: No.
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1 MEMBER BECK: No.

2 MEMBER SONNABEND: No.

3 MEMBER FELDMAN: No.

4 MEMBER RICHARDSON: No.

5 MEMBER DICKSON: No.

6 MEMBER FOSTER: No.

7 MEMBER WALKER: No.

8 CHAIRMAN STONE: And no. 

9 Unanimous, 15 nos. Motion fails.

10 MEMBER FOSTER: Moving onto last

11 item on our Subcommittee agenda for this

12 morning then is the ancillary substances-other

13 ingredients proposal. Do we have a motion? 

14 Ah, my mistake. I think we were thinking

15 about pushing off the voting to that in the

16 afternoon.

17 MEMBER SONNABEND: Okay. I hadn't

18 necessarily heard that. Why? 

19 MEMBER FOSTER: My expectation

20 based on the comments was that we would want

21 further discussion. There's room on the

22 agenda to first deliberate that. If we don't
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1 need it, that's okay.

2 MEMBER SONNABEND: Don't you think

3 we should discuss it now and then if things

4 come up that we have to revise then push the

5 vote back to this afternoon? Because if we

6 don't discuss it now, we're going to be

7 really, you know, starting over.

8 MEMBER FOSTER: Let's discuss it.

9 CHAIRMAN STONE: And right now

10 we're about 30 minutes ahead of where we

11 thought we might be, so I think we can spend

12 a little time discussing.

13 MEMBER SONNABEND: And so to that

14 end, John, I don't know if you want to put a

15 motion on the floor before we start discussing

16 it or not, but it's up to you.

17 MEMBER FOSTER: I think if we can

18 do it, let's just do it in discussion. It

19 could get muddier faster if we have a motion

20 on the floor.

21 CHAIRMAN STONE: The Chair

22 respects that.
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1 MEMBER FOSTER: Excellent. So if

2 you want to start the discussion, that would

3 be great. 

4 Would any of the other Board

5 Members like to discuss the proposal in front

6 of us? Nick?

7 MEMBER MARAVELL: Yes, I want to

8 say that I think this is a very important

9 issue and they've made a considerable amount

10 of progress in addressing I'm going to just

11 say other ingredients because I get too

12 confused with what I'm reading and what we're

13 saying, but I would like to suggest some

14 clarifications and perhaps some shortening to

15 our policy that I don't think is at all

16 substantive and would make it easier for

17 future boards to understand. 

18 So in that light, and I'm going to

19 ask Zea if she considers these quote/unquote

20 "friendly." I would definitely like to add

21 the words "reviewed to OFPA standards" just so

22 that we don't have to answer that question
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1 anymore. In the very beginning where it says

2 "It will be our policy to review all other

3 ingredients," I would -- I don't even know if

4 I'm looking at the most recent version of it

5 in my book, but the very first -- now I got to

6 find it. Yes, right under the heading it says

7 "Policy." The NOSB --

8 MEMBER SONNABEND: Okay. Could I

9 just ask -- Michelle has it up and could 

10 you --

11 MEMBER MARAVELL: Sure.

12 MEMBER SONNABEND: -- point and --

13 MEMBER MARAVELL: On page 199 in

14 my book at the very bottom there's the

15 heading, subheading called "Policy." The very

16 first sentence at the top of the screen, it

17 says, "The NOSB intends to review," and I

18 would add the words "to OFPA standards," "OFPA

19 criteria." I would take anything that the

20 Committee or the Board wants to put in there. 

21 "Other ingredients found, et cetera, et

22 cetera." But I'm tired of answering the
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1 question and I think that future Boards can

2 see our intent very clearly there.

3 I'm going to make another --

4 MEMBER SONNABEND: Can --

5 MEMBER MARAVELL: Yes?

6 MEMBER SONNABEND: Can I just make

7 sure Michelle has that change, because

8 Michelle is going to have to keep the firm

9 version of the document.

10 MEMBER MARAVELL: Okay. And then

11 perhaps I should just ask, does anyone have a

12 particular word they want to see there? OFPA

13 standards? OFPA criteria? Do you want to

14 cite the statute? I want it to be crystal

15 clear. Does anyone have any thoughts on that?

16 CHAIRMAN STONE: Jay?

17 MEMBER FELDMAN: I would say "in

18 accordance with OFPA criteria."

19 MEMBER MARAVELL: Okay. I'm fine

20 with that. I just want to make it clear. 

21 MEMBER SONNABEND: Okay. 

22 Michelle, adding "in accordance with OFPA
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1 criteria" to the first sentence under "Policy"

2 at the end, does that work for you?

3 MEMBER MARAVELL: Then a second

4 concern that I have is -- just to shorten this

5 a little bit would be to take the section that

6 lists the categories we know are going to have

7 a lot of other ingredients in it. And we're

8 not really giving policy on that. We're just

9 saying, hey, guys, we got to look at these. 

10 I would be willing to put that in an appendix

11 just so we can sort of shorten our policy.

12 MEMBER SONNABEND: I'm not sure

13 I'm following you, Nick. Can you tell us what

14 page and where you want to add or take out

15 language?

16 MEMBER MARAVELL: Okay. I'm

17 sorry. Yes, I'm sorry. Okay. Page 201 in

18 your book. "The following listings in 205.605

19 are classes of substances that are known to

20 require the use of other ingredients." That's

21 sort of a factual statement. "These are

22 recommended for careful review during the
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1 sunset period." We're going to do that. 

2 We're highlighting this for ourselves, future

3 boards and to the Program, but I don't feel

4 that we need to have that in our policy

5 section. It could be in our appendix or move

6 out of the policy. And I'm doing that in the

7 interest -- I'm trying to have us focus on the

8 most essential portions of the policy when we

9 vote. I don't feel that this is a policy

10 statement so much as it is just flagging

11 things that we're going to be doing anyway. 

12 So, but I'd love to hear from the

13 rest of the Board on that.

14 CHAIRMAN STONE: Harold?

15 MEMBER AUSTIN: I'm going to take

16 the other side of the equation on that one,

17 Nick, and throw something at me if you totally

18 disagree, but I think looking at the

19 complexity of what we do and the processes

20 that we all try to get engaged with, that I

21 think something like this is stuck in there

22 for the boards and the members that follow
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1 behind us. Actually, I think it's a good

2 component to have there just because it's

3 there. I mean, as they read through this

4 document, it's black and white. It's very

5 visible to where they're not going to have to

6 look some place else in the regs or the rules

7 to find these. It puts it right there in

8 plain sight. Just my thought.

9 MEMBER MARAVELL: Right. I don't

10 feel strongly about this. I'm just saying

11 it's not what I would consider to be high

12 policy and if want to, you know -- and that it

13 would still remain in this document. I'm not

14 suggesting that it leave the document. That's

15 all. It's a minor point. I'm trying to boil

16 this down to if I have to explain this policy

17 to stakeholders that I don't have to go

18 through that list as part of the explanation. 

19 That's all. But, you know, so a minor point,

20 but I'd love to hear yet additional comment if

21 there is any.

22 CHAIRMAN STONE: To me it's under
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1 the procedure, not policy. So there is a

2 separate subheading there. Jean?

3 MEMBER RICHARDSON: Yes, I think I

4 would leave it just where it is. It really

5 illustrates what's being discussed in the

6 policy and it is in the procedural section. 

7 And there's always a tendency for items that

8 go into the appendices to be lost in the

9 discussion, so I'd leave it where it is.

10 CHAIRMAN STONE: Zea?

11 MEMBER SONNABEND: Well, I just

12 would like to ask Miles or the Department; I

13 saw you mumbling over there between each 

14 other --

15 (Laughter.)

16 MEMBER SONNABEND: -- if you have

17 a reaction to this.

18 MR. McEVOY: Yes, we were just

19 discussing whether or not it was appropriate

20 to be amending the proposal without a motion

21 on the floor. So the proposal that was

22 submitted by the Subcommittee for
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1 consideration -- well, first there was the

2 published proposal and then you amended that

3 when you presented the proposal. Was that

4 this morning? Boy, it all blends together

5 after awhile. 

6 (Laughter.)

7 MR. McEVOY: And so, we just want

8 to be clear what you're doing here. And it

9 sounds like you're discussing some changes. 

10 And if you're going to make those change to

11 what you proposed this morning, then you have

12 to clarify that when you finally get to the

13 motion. 

14 MEMBER SONNABEND: Well, the

15 motion would be for the amended proposal, but

16 I am no parliamentarian, so whoever wants to

17 decide that, it's fine.

18 CHAIRMAN STONE: Yes, the fear

19 here is we get into amending amendments and

20 that type of thing, so I would like to modify

21 the document and then approve as modified. 

22 But if we need to have a motion and second and
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1 then we agree on one amendment, I think that

2 would be the cleanest for the record.

3 MEMBER SONNABEND: Well, Nick's

4 first amendment to add OFPA criteria, there

5 was agreement. But this one I'm hearing some

6 disagreement, so that would have to be a

7 formal amendment then.

8 MEMBER MARAVELL: I don't consider

9 any of these amendments. I'm just considering

10 this discussion points for us to consider

11 right now and sort of a forewarning that this

12 could lead to an amendment of the document. 

13 And I agree totally with what Miles said, we

14 are not amending this right now. We're

15 showing the public what our deliberation

16 process is. Is that okay?

17 MR. McEVOY: That's fine.

18 MEMBER MARAVELL: I would just

19 like though to clarify then, are we seeing the

20 policy section different in terms of its

21 impact from the procedure section in terms of

22 our recommendation? That's just a
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1 clarification question. In other words, do

2 they both carry the same weight? Because if

3 they don't, then I've got other suggestions,

4 because I think they both need to carry the

5 same weight.

6 MEMBER FELDMAN: Yes, I agree they

7 need to carry the same weight. I mean you're

8 talking about transparency, right? 

9 MEMBER MARAVELL: Absolutely.

10 MEMBER FELDMAN: So that when

11 someone reads this policy, it's not in the

12 background discussion. It is the policy. 

13 MEMBER MARAVELL: Zea, how do you

14 see it?

15 MEMBER SONNABEND: I don't

16 understand. It's a recommendation. It

17 carries the same impact, both parts of it. I

18 guess I don't understand.

19 MEMBER MARAVELL: Okay. Well,

20 it's just semantics then. I thought I heard

21 something saying, well, it's not in the policy

22 section, it's in the procedure section, and I
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1 don't know if that made any difference that

2 we're only adopting the policy and we're not

3 adopting a procedures. But if it's all 

4 equal --

5 MEMBER SONNABEND: That wasn't me.

6 MEMBER MARAVELL: Yes, yes. If

7 it's all equal, then, yes, that's fine. 

8 That's fine.

9 CHAIRMAN STONE: Is there other

10 discussion, other clarifications that Board

11 Members might have? Jay?

12 MEMBER FELDMAN: I'm trying to

13 figure out the definition of other

14 ingredients. Not being a part of the

15 Committee makes it a little difficult, and as

16 you know from our pre-meeting, I've been

17 through this document several times. But you

18 know, there's some reference to incidental

19 ingredients as defined by FDA in the document. 

20 There's reference to processing aids. There 

21 are referenced ingredients within ingredients. 

22 There are references to single ingredients and
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1 multiple ingredients. And at this point my

2 head is a little spinning around. But is

3 there a clear definition section that

4 identifies exactly what we're talking about? 

5 Is everybody clear on that? 

6 Because we have the section of

7 base criteria and we have a section of other

8 criteria, but do we need to start with base

9 criteria that's defined under another statute,

10 or do we need to start with all other

11 ancillary ingredients that are used in the

12 production of materials that are being

13 petitioned? Why isn't it that simple? And

14 when we talk about ancillary ingredients, why

15 isn't it as simple as processing aids and

16 other ingredients that are used for purposes

17 of formulation for whatever reason? 

18 I get a little worried when we

19 start referencing FDA and GRAS and incidental

20 ingredients because as you all know, as we've

21 talked about in the past, the standards that

22 govern those statutes or other statutes we
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1 typically reference are -- not that we can't

2 use them and incorporate them, but unless it's

3 really clear that we independent of those

4 statutes are defining the universe of

5 ingredients, I feel may we may leave some out

6 and then we have further problems down the

7 road. 

8 So am I missing something here? I

9 have a few other questions.

10 CHAIRMAN STONE: John?

11 MEMBER FOSTER: I know in the past

12 NOSB has been I believe directed by NOP to

13 consider ingredient. I think it's pulled from

14 the FDA definition of ingredient; any

15 substance used in the preparation of an

16 agricultural product that is still present in

17 the final commercial product as consumed. And

18 I kind of recall and I've been informed that's

19 an accurate recollection is that there was

20 some direction to do that. And that's

21 consistent with the heading of 605.606 I

22 think. 
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1 MEMBER FELDMAN: Could I ask you a

2 question at this point?

3 MEMBER FOSTER: Sure.

4 MEMBER FELDMAN: I don't want to

5 interrupt, but just is there anything in OFPA

6 that talks about functional or technical

7 effect as is referenced in FDA, FFDCA? And

8 along the same lines is there anything in OFPA

9 that talks about insignificant as is

10 referenced in FFDCA? I mean the reason OFPA

11 exists is because those other statutes were

12 different. 

13 I mean I don't want to denigrate

14 those other statutes; they have valuable

15 purpose, but the OFPA standard was intended to

16 be somewhat different and create a market that

17 differentiated itself from the conventional

18 market. And if we fall back on conventional

19 definitions of insignificant and functional

20 technical effect, then how are we different? 

21 How is this organic label differentiated? and

22 over time, you know, to me that becomes
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1 problematic. 

2 So you're citing FDA. And when

3 you do that, please help me by explaining how

4 that aligns with OFPA. That's what I was --

5 MS. FERNANDEZ-SALVADORE: Miles?

6 MR. McEVOY: Yes, I just wanted to

7 clarify why we used the term "other

8 ingredients." We purposely used that

9 terminology of "other ingredients" because we

10 didn't want to presume that the term

11 "incidental additives" would be all inclusive. 

12 So what the intent of the memo from 2011 was

13 that we want the Board to look at all of these

14 ingredients within ingredients that are on we

15 specifically said 605 so that they're all

16 reviewed as part of the review process for any

17 substance that's being considered to be on

18 605. So that's why we used that term "other

19 ingredients." Because some of the things are

20 not ingredients, right? They're other

21 ingredients and processing aids, and

22 processing aids are not ingredients. So we
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1 want to be inclusive, not restrictive.

2 And then the other point is that

3 if it's not included in the review and it's

4 not on the National List, then the substance

5 can't be allowed. So that's the purpose, is

6 to drill down deeper into these sub7 ingredients or ingredients within ingredients

8 to have a clear policy, clear recommendations

9 from the Board on those ancillary substances

10 and this universe of things.

11 CHAIRMAN STONE: So does this

12 definition do that? Does this cover that

13 world or sphere of --

14 MR. McEVOY: So the question is

15 whether the baseline criteria covers all those

16 different permutations? Was that the --

17 CHAIRMAN STONE: And item 1

18 through 4. Yes, that's the question.

19 MR. McEVOY: Well, I'd say we're

20 not exactly sure because we haven't analyzed

21 that in great detail, but it would be a

22 starting place of the universe of things that
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1 are allowed in foods, because they have to

2 meet these baseline criteria to be allowed in

3 foods in the first place.

4 CHAIRMAN STONE: So this is a

5 recommendation and you hear our intent

6 associated with the recommendation. So at

7 this point when we -- be sure we're covered

8 here, Jay, that it's their job if it's lacking

9 in some way. They have the responsibility to

10 let us know that. Zea?

11 MEMBER SONNABEND: In my

12 perception the definition of ancillary

13 substances is the baseline criteria as a

14 starting place and then the five bullet points

15 where it says "Other ingredients have the

16 following characteristics," because just the

17 baseline criteria by themselves is everything

18 allowed in food whether it's a main ingredient

19 or not an ingredient. But to distinguish

20 between those things which we're calling

21 ancillary and those things which are main

22 ingredients are the bullet points, and all of
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1 the bullet points characterize what

2 constitutes something being called ancillary.

3 MEMBER FELDMAN: Does that include

4 processing aids?

5 MEMBER SONNABEND: Yes.

6 MEMBER FELDMAN: That do not have

7 a functional or technical effect?

8 MEMBER SONNABEND: Yes. Well, it

9 includes ancillary substances within a

10 processing aid that's on the National List. 

11 It doesn't include processing aids that were

12 used to produce the other ingredients, because

13 you can't even find that out.

14 CHAIRMAN STONE: Because they're

15 no longer in the product.

16 MEMBER SONNABEND: They're no

17 longer in the product and they're not on the

18 label as an ingredient of the other

19 ingredient.

20 (Laughter.)

21 MEMBER FELDMAN: I got that one, I

22 think.
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1 (Laughter.)

2 CHAIRMAN STONE: Jay?

3 MEMBER FELDMAN: Just another

4 question is are we distinguishing here between

5 who actually is doing the processing? So if

6 I'm a certified handler and I'm doing the

7 processing, am I held to a different standard

8 than a non-certified handler who is doing the

9 processing?

10 MEMBER SONNABEND: Of what?

11 MEMBER FELDMAN: Of the other

12 ingredient, or of the ingredient that is

13 utilizing other ingredients in formulating its

14 end product. There's no distinction here

15 between certified handlers and non-certified

16 handlers, processors, that there was a

17 reference here to certified handlers.

18 MEMBER SONNABEND: I still don't

19 get it. 

20 MEMBER FOSTER: No, I'm with Zea

21 on this one. It's not clear to me.

22 MEMBER FELDMAN: Is there such a
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1 thing as certified handlers?

2 MEMBER FOSTER: Yes.

3 MEMBER FELDMAN: Processors?

4 MEMBER FOSTER: Yes.

5 MEMBER FELDMAN: Is there such a

6 thing as non-certified handlers?

7 MEMBER FOSTER: Yes.

8 MEMBER FELDMAN: Okay. Do

9 products from both those sources end up in

10 organic food?

11 MEMBER FOSTER: Sometimes.

12 MEMBER FELDMAN: Yes. Yes? 

13 MEMBER FOSTER: Sometimes yes.

14 MEMBER FELDMAN: Yes or no? 

15 Sometimes yes? Okay. Under this proposal are

16 the materials that end up in organic food,

17 certified food held to a different standard of

18 review when it comes to other ingredients if

19 it goes through the channel of certified

20 handler or if it goes through the channel of

21 non-certified handler? 

22 MEMBER SONNABEND: Okay.
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1 MEMBER FELDMAN: That's the

2 question. Sorry, I -- this is out of my

3 world.

4 MR. McEVOY: This is --

5 MEMBER SONNABEND: Okay.

6 MR. McEVOY: Can I answer that?

7 MEMBER SONNABEND: Miles, yes. 

8 MR. McEVOY: So any certified

9 organic handler goes through the same process

10 of verification that the final product meets

11 the requirements. And so if it's an organic

12 product --

13 MEMBER FELDMAN: Right.

14 MR. McEVOY: -- all the

15 agricultural ingredients have to be organic

16 and verified that they are certified under the

17 requirements, unless it's a 606 material, and

18 then they could potentially use a non-organic

19 606 material if they have evidence that it's

20 not commercially available in organic form. 

21 If it's a 605 material, then they

22 can use that in their formulation. It has to
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1 be verified that it meets the requirements. 

2 You know, those 605 materials are by

3 definition non-agricultural and so they would

4 not be coming from a certified organic source

5 because they're not an agricultural input. So

6 they're not coming from a certified organic

7 handler. They're just coming from some

8 supplier. 

9 And the certifier needs to verify

10 that those 605 materials meet the

11 requirements. Just like on a farm any inputs

12 that are used in farm production, they need to

13 be reviewed and determined that they meet the

14 requirements, that they're either non15 synthetic or that they're a synthetic that's

16 on 601. So it's sort of the same review

17 process. So we don't have certified organic

18 fertilizer manufacturers, just like we don't

19 have certified organic suppliers of 605

20 materials. But there's still a verification

21 process to verify that all those inputs meet

22 the requirements.
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1 MEMBER FELDMAN: And so under this

2 policy those inputs -- presumably some could

3 be other ingredients, right, would be reviewed

4 or held to the OFPA standards?

5 MR. McEVOY: All inputs are

6 reviewed. All ingredients are reviewed. So

7 whatever the requirements are that are under

8 605, including any annotations, the certifier

9 has to verify that those requirements are

10 being met.

11 MEMBER FELDMAN: Including the

12 other ingredients?

13 MR. McEVOY: If there are

14 annotations that reference other ingredients,

15 then yes.

16 MEMBER FELDMAN: Annotations in

17 the rule?

18 MR. McEVOY: Right.

19 MEMBER FELDMAN: On the National

20 List?

21 MR. McEVOY: Right, so there are

22 some 605 materials that have annotations and
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1 that is part of the process that the certifier

2 goes to to verify that those substances --

3 MEMBER FELDMAN: So you're talking

4 about current policy?

5 MR. McEVOY: Correct.

6 MEMBER FELDMAN: If it's not in

7 the annotation, it would not be reviewed by

8 the certifier currently?

9 MR. McEVOY: Okay. 

10 (Laughter.)

11 MEMBER SONNABEND: It's haphazard.

12 MR. McEVOY: Yes, it's haphazard. 

13 That's why we're asking for this policy from

14 the Board.

15 MEMBER FELDMAN: Right, but I'm

16 just trying to get the current situation.

17 MR. McEVOY: Right.

18 MEMBER FELDMAN: So then to make

19 sure we fix that, this policy is intended to

20 fix the haphazardness of that problem?

21 MR. McEVOY: Exactly.

22 MEMBER FELDMAN: Okay. Okay. 
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1 Thank you.

2 CHAIRMAN STONE: You good? 

3 MEMBER FELDMAN: I'm going to take

4 a break.

5 (Laughter.)

6 CHAIRMAN STONE: All right. 

7 Anybody else? Nick?

8 MEMBER MARAVELL: Yes, it looks

9 like we're the only fools here. 

10 Okay. I need to seek some

11 clarification here in terms of -- we have a

12 section in this paper called "Recommendation." 

13 We have another section called "Discussion." 

14 Under "Discussion" we define other ingredients

15 and we define baseline criteria. Am I to

16 understand that the discussion portion carries

17 the same weight as the recommendation portion? 

18 If that's correct, I am definitely going to

19 make a proposal that we change "discussion" to

20 -- start "recommendation" further up. I think

21 it needs to be very, very clear what we are

22 recommending here. 
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1 And then, so I'll entertain any

2 discussion on that and then I want to go back

3 to the five points. 

4 CHAIRMAN STONE: So it's my

5 thought that the -- and I'll ask the Program

6 in a second, but this whole document is our

7 recommendation, not just the paragraphs under

8 the title "Recommendation." Certainly we

9 could move the term "recommendation" back up

10 the document to be inclusive if it's

11 necessary. I would think not, but I'll defer

12 to the Program.

13 MR. McEVOY: Yes, if you pass a

14 final recommendation, the whole document

15 becomes part of your final recommendation. So

16 in your final recommendations you usually have

17 a section that you call the recommendation,

18 but it's in the context of the full final

19 recommendation. So it's all part of the

20 record that we would then utilize to implement

21 any kind of either rulemaking or guidance that

22 would need to happen. So the whole thing is
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1 the recommendation. 

2 CHAIRMAN STONE: And I would add

3 that certifiers, when they look back at

4 recommendations and TRs and petitions, the

5 whole document is a reference document, not

6 just that section. 

7 Did you have something else, Nick?

8 MEMBER MARAVELL: Yes, and this

9 follows on Jay's previous discussion. Hello,

10 Jay. Wake up. One of the five bullet points

11 is they are not added directly by the

12 certified handler. So I think Zea can explain

13 why that's an important provision to have

14 there, but it's somewhat of a confusing issue,

15 unless I'm the only one confused. Does anyone

16 else want that one explained?

17 CHAIRMAN STONE: It's my

18 understanding that if it's added directly,

19 then it goes on the ingredient panel, and this

20 is to address those that are not on the

21 ingredient panel.

22 MEMBER MARAVELL: And does the
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1 words "by the certified handler" make a

2 difference? Why do we have to say by a

3 certified handler?

4 CHAIRMAN STONE: Because they're

5 the ones that verify that these other

6 ingredients have been reviewed at some point

7 in the process already, and that's partly what

8 we're cleaning up. But we have authority --

9 the certified handler has a requirement under

10 the regulation to do that, whereas to Jay's

11 point I think was if it's not a certified

12 handler, then they're outside of our purview. 

13 And this gets into our purview. That's the

14 purpose of that.

15 MEMBER MARAVELL: Well, I'm going

16 back to Jay's point under 605; I assume not

17 under 606, but it could be, that there could

18 be materials, other ingredients coming from

19 non-certified handlers. Does that make a

20 difference and is there any way in which that

21 could cloud our transparency in reviewing all

22 of the materials and perhaps not recognize a
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1 material that we would otherwise not want to

2 see in a final product?

3 CHAIRMAN STONE: If I understand

4 your question right, that's what we're trying

5 to do here. And this says that.

6 MEMBER MARAVELL: Well, that's

7 what I'm questioning, whether that says that. 

8 You know, it may. And I'm showing my

9 ignorance here, but I'm, you know --

10 CHAIRMAN STONE: Well, you can

11 stop any time, if you want?

12 MEMBER MARAVELL: Well, yes.

13 (Laughter.)

14 MEMBER MARAVELL: Thank you, Mr.

15 Chair.

16 MEMBER BONDERA: No, I think I had

17 that question too of whether or not the word

18 "certified" needed to be struck. Modify that

19 or not.

20 MEMBER SONNABEND: Why would a

21 non-certified handler go through all this

22 trouble to sourcing stuff with -- look at
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1 other ingredients? Certified handlers are the

2 end users of the results of this

3 recommendation, and so they're the ones who

4 are making their recipes and what they add for

5 -- you know, what is added directly by them is

6 a thing like an enzyme or a vitamin or a dairy

7 culture, and that's what they're adding

8 directly. Those are ingredients. But they

9 don't know in all cases that they're also

10 adding growth media, preservatives, whatever. 

11 Those are the things we're going to review. 

12 CHAIRMAN STONE: Yes, Jay?

13 MEMBER FELDMAN: Just for the

14 laypeople, the confusion comes in that we know

15 that we're accepting other ingredients into

16 food, processed food that we label organic,

17 and the organic consumer expects that there's

18 been some degree of review. So if we know

19 that's going on, we have to have some type of

20 methodology to assess whether the non21 certified handler whose product we end up

22 buying and utilizing in the processing of a
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1 certified product -- that that non-certified

2 handler, whether he wants to be in the organic

3 stream of commerce or not, regardless of what

4 the intent is, his product or her product is

5 ending up in the final certified organic

6 product. And our consumers want to know that

7 that has been subject to some review.

8 So if this does that, that's fine. 

9 But if it doesn't, then we need to -- just

10 even a parentheses, you know, that -- and in

11 a case where applicable, a non-certified --

12 you know, I mean --

13 CHAIRMAN STONE: John?

14 MEMBER FOSTER: So in the main

15 those ingredients have had that scrutiny. 

16 That's it. I can't even tell you the

17 thousands of hours I spent reviewing

18 ingredients that certified operators were

19 putting into formulated products. Thousands

20 and thousands of hours. In the main that's

21 been happening in accordance with the

22 regulations.
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1 What I think we're talking about

2 here is refining that, drilling down more. 

3 But I don't want it to go out there that that

4 hasn't been done. That has been, the vast

5 majority. It's been a little inconsistent. 

6 Like any new regulation there's going to be

7 inconsistencies. I think we're just trying

8 to, you know, refine that a little bit more.

9 But don't anyone mistake the fact that in the

10 main since 2002 this has been happening. 

11 We're just getting better at it with this. 

12 CHAIRMAN STONE: So like Flavor

13 says, without synthetic solvents some of these

14 have some clarifying annotations and some

15 don't. And that's what we're driving for. 

16 But certifiers look at the regulations. They

17 look at recommendations. They look at TRs and

18 see what was in the TR. We defined it with

19 DHA and ARA. And in others it wasn't because

20 we don't do brand names. So this is a

21 refinement to do exactly what you're concerned

22 about. And the language I think says that.
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1 MEMBER FELDMAN: And I realize

2 that and I appreciate the work that you guys

3 have done on this. This is an incredibly

4 important area and I think the consumers will

5 appreciate this. What I think may be helpful

6 as we move this forward is to identify in the

7 document where we think more work is needed,

8 where we think more Board work is needed. I'm

9 very uncomfortable handing over authority to,

10 you know, parties outside this Board without

11 adequate, you know, assurance that there's

12 compliance with the underlying OFPA standards

13 and the process. 

14 And I said it earlier and we

15 didn't have a chance to discuss it, but just

16 the use of the word "insignificant" is

17 extremely troubling to me having worked in

18 chemical regulation for 30 years and having

19 seen us go through classical toxicological

20 reviews to inverse dose response curves with

21 exposure to endocrine disrupters where we

22 didn't conceive of this years ago where dose
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1 no longer makes a poison but timing can affect

2 the life of an organism from its fetal stage

3 through the rest of its life. And we organic

4 are on the cutting edge of that. 

5 So to throw in terms like

6 "insignificant" is very troubling to me. And

7 we've discussed this before as a Board. We

8 discussed this in Seattle in 2011. If that

9 term is going to be used in a document like

10 this, we really have to acknowledge as a Board

11 that we need to work on defining it.

12 CHAIRMAN STONE: I can appreciate

13 that. The way I read these bullets under

14 other ingredients, we're specifically stating

15 that items that are present in food at an

16 insignificant level have no technical function

17 of food are on the list of things to be

18 considered as other ingredients, not excluded

19 from. Zea?

20 MEMBER SONNABEND: This is the

21 definition simply of what we're going to

22 review. Then when we review them you can
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1 decide if it's significant or functional or

2 not. But this is just the definition of what

3 constitutes another ingredient. And it has to

4 be all of these things together, not just any

5 one of them to constitute the definition. And

6 then we're going to, you know, look at how

7 much is -- you know or the relative

8 proportions or whatever. And then you can

9 decide as a Board Member if it's insignificant

10 or not.

11 CHAIRMAN STONE: Nick?

12 MEMBER MARAVELL: So, Zea, if we

13 said "other ingredients must have the

14 following characteristics," would that still

15 be a correct statement? Do we want them to

16 have all those characteristics? They have to

17 meet every -- 

18 MEMBER SONNABEND: That's

19 regulatory language, not definition language. 

20 I mean we're defining. They have the

21 following characteristic.

22 MEMBER MARAVELL: Well definitions
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1 need to be somewhat precise if I'm going to

2 vote to recommend them. I mean I need to know

3 -- well, just let me know, would that be an

4 inappropriate thing to say, they must have the

5 following characteristics? They must have all

6 of the following characteristics? I mean I'm

7 literally trying to understand, Zea. I'm not

8 trying to be critical here.

9 CHAIRMAN STONE: I don't see that

10 that changes anything, but --

11 MEMBER SONNABEND: I don't see it

12 as being a worthwhile change, no.

13 MEMBER MARAVELL: I don't see that

14 as an answer to my question either.

15 CHAIRMAN STONE: Miles?

16 MR. McEVOY: Yes, if you change it

17 to "must have the following characteristics,"

18 you're going to limit what you're going to be

19 able to review. You don't want to limit what

20 you want to include in this category, I don't

21 think. I don't think that's what I've heard

22 from the Subcommittee. 
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1 MEMBER FELDMAN: But you could

2 always use language like "must have but is not

3 limited to." 

4 MR. McEVOY: You could do that.

5 CHAIRMAN STONE: If that helps,

6 I'm certainly -- be able -- Jean?

7 MEMBER RICHARDSON: To my way of

8 looking at it, the way it's phrased right now

9 is the correct way. It remains broad enough

10 to allow all the other ingredients to be

11 included in the pot. And that if we start

12 fiddling around with the language, we're just

13 going to make it more complicated than it need

14 to be. So I think we should just leave it the

15 way it is. "Other ingredients have the

16 following characteristics."

17 CHAIRMAN STONE: Tracy?

18 MEMBER FAVRE: Nick, explain to me

19 your concerns about it just saying "have the

20 following ingredients?"

21 MEMBER MARAVELL: It's not so much

22 that I have a concern. I'm trying to
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1 understand it. And if you bear with me, I

2 used to draft regulations for a living, so

3 these things do make a difference. As Miles

4 has pointed out, he doesn't want to be limited

5 and we don't want to send the wrong message. 

6 I'm just trying to understand. And as I said,

7 I'm going to show my ignorance here. I am

8 trying to understand.

9 CHAIRMAN STONE: Any other? 

10 Colehour, did you have your hand up?

11 MEMBER BONDERA: Yes, I don't

12 know. I mean I could say in this discussion

13 that when Zea was commenting on it and she did

14 say it must have these following

15 characteristics that are on that list, I was

16 like, whoa, okay, it didn't say that when I

17 had first read it. And so it made me do a

18 double take to understand it. So I think that

19 -- from my perspective it would add clarity,

20 because that was a presumption. And then I

21 think it would just make it more defined. 

22 CHAIRMAN STONE: Jay?
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1 MEMBER FELDMAN: Miles, I need to

2 go back to something you said, and I wrote it

3 down here. And this may be under the current

4 policy. Maybe this is what we're trying to

5 address. "If it's not included in the review

6 and it's not on the National List, then it's

7 not allowed." Aren't we trying to get around

8 that somehow possibly with this policy, that

9 we're trying to figure out another mechanism

10 to ensure its review, ensure the public that

11 it has been subject to review of OFPA

12 standards, but not necessarily put it on the

13 List? That's my sense of what I'm hearing

14 about the end result of this policy.

15 CHAIRMAN STONE: Miles?

16 MR. McEVOY: Okay. So everything

17 that's an input or ingredient has to be in

18 compliance with the regulations, and there's

19 various criteria for that depending upon what

20 part of the agricultural system you're looking

21 at. Crops and livestock is different than

22 handling. We spelled that out in the memo on
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1 this topic back in 2011. 

2 For crops and livestock,

3 especially for crops, it's very clear on what

4 ingredients and ingredients within ingredients

5 are allowed and not allowed. For livestock

6 it's very good, not quite as good as crops,

7 but it's very clear on the ingredients and

8 ingredients within ingredients. The

9 excipients is very clear. And we tried to

10 clarify that in our final guidance on

11 livestock feed supplements just recently. 

12 For handling, as we mentioned in

13 2011, it hasn't been systematically looked at

14 by the Board. It's been various levels of

15 review for the various substances on 605. 

16 There is some guidance that the Board does

17 provide in their review and the technical

18 reports, and certifiers use that. And

19 certifiers ensure that everything that is in

20 a processed organic product is compliant with

21 the regulations. What we're looking for is

22 drilling down a little deeper into that area
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1 to provide consistency on those ancillary

2 substances-other ingredients in 605 and now

3 606 materials. 

4 So from the way that we see this

5 proposal, it's trying to then provide that

6 structure and policy of how the Board would

7 approach this larger issue of these other

8 ingredients.

9 MEMBER FELDMAN: But are you

10 saying that at the end of the day when all of

11 this is done and reviewed to -- in a perfect

12 world, I mean do we need to put these

13 materials that have been reviewed on the

14 National List, or can there be some other

15 mechanism that meets the standard?

16 MR. McEVOY: Right, any input in a

17 processed organic product has to be either an

18 organic agricultural ingredient or it has to

19 be on the National List. Right. So there's

20 various ways that that can happen. So you can

21 have individual ingredients, individual

22 materials on the National List or you can have
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1 categories. So it all depends on how the

2 Board approaches this in the future. For

3 instance, for crops you have List 3 and List

4 4 inerts.

5 MEMBER FELDMAN: Right.

6 MR. McEVOY: So you don't have

7 individual ingredients. You have groups of

8 substances.

9 MEMBER FELDMAN: Right.

10 MR. McEVOY: For livestock you

11 have excipients. That's a group of

12 substances. And some of the other materials

13 are enzymes. That's a group of substances. 

14 It's not an individual enzyme-by-enzyme-type

15 of thing. I would think that that would be

16 the way that the Board would continue to look

17 at listing substances as by categories. The

18 inerts project, you're looking at categories

19 of groups of substances. 

20 MEMBER FELDMAN: Okay.

21 MR. McEVOY: So they're still on

22 the National List. There's still that
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1 regulatory basis for allowing it, but it might

2 not be as individual as an individual CAS

3 number.

4 CHAIRMAN STONE: Okay. So I'm

5 going to bit of a time check here. I think we

6 can have -- over lunch we can have more

7 discussion, get more comfort, Nick, with those

8 of you, the crafters of the recommendation. 

9 Before I just stop, are there other sections,

10 pages, paragraphs that someone -- or is this

11 sort of the last of our discussion that we

12 need to refine, or are there aspects of this

13 that are still hanging out there? Just kind

14 of gauging time later. 

15 Okay. Great. Oh, Nick? Sorry.

16 MEMBER MARAVELL: Unfortunately

17 there are other aspects, but, you know, I'm

18 not sure that they can be productively

19 discussed here. So I'll try to do it at

20 lunch, et cetera, and see. It gets pretty

21 detailed.

22 CHAIRMAN STONE: Well, so, yes, if
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1 you can work with Zea and John and those that

2 worked on this in Committee, then -- it does

3 get hairy, so we do have to figure out how to

4 work it in in time.

5 Okay. Well, thanks. So I've got

6 11:15. We'll move to the CACS Subcommittee

7 and I'll turn the program over to Joe.

8 MEMBER DICKSON: Thank you, Mac. 

9 The CACC or the CACS has only one item on the

10 agenda for this meeting, our proposal on

11 calculating the percentage of organic

12 ingredients in multi-ingredient products. Dr.

13 Jean Richardson has led our work on that

14 recommendation and I would ask her to give us

15 an overview and some recommended changes that

16 the Committee has come up with.

17 MEMBER RICHARDSON: Thank you,

18 Joe. The purpose of the document that we

19 circulated and put out for public comment is

20 on determination of percentage of organic

21 ingredients in multi-ingredient products. And

22 we put this out in order to be able to provide
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1 some assistance to the NOP in the development

2 of guidance for handlers and certifiers.

3 Consumers expect that labels on

4 multi-ingredient products that are sold as 100

5 percent organic or made with organic reflect

6 an accurate determination of percentage of

7 organic ingredients and all certifiers have

8 uniformly calculated such percentages. 

9 And we had a discussion. 

10 Documenters, you recall from last meeting,

11 sent out suggested changes and we got back

12 excellent comments from 14 different

13 organizations. We got responses from OTA,

14 MOSA, Cornucopia, Smucker Natural Foods, Wolf

15 DiMatteo, ACA, Beyond Pesticides, CCOF,

16 OneCert, OTCO, NOC, PCO, CROP and White Wave

17 Foods. There was a considerable consistency

18 amongst all of the people sending in

19 recommendations. Some suggested edits. 

20 Others supported other organizations such as

21 supporting the OTA statements. 

22 I'll fold my comments -- from the
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1 people that sent in comments, I'll fold those

2 into the recommendations as I go through them. 

3 And because we're asking for changes, this

4 guidance needs -- basically I have to sort of

5 read the recommendations into the record so

6 that it is clear where we're coming from.

7 So the first recommendation that

8 we had is to make a proposed regulatory

9 change. We propose to change the regulation

10 at 205.302(a), which in essence it says --

11 well, I'll just read it. 

12 It says, "Calculating percentage

13 of organic of organically produced

14 ingredients. The percentage of all

15 organically produced ingredients in an

16 agricultural product sold, labeled, or

17 represented as "100 percent organic,"

18 "organic," or "made with organic (specified

19 ingredients or food group(s))," or that

20 include organic ingredients, must be

21 calculated by: (1) Dividing the total net

22 weight (excluding water and salt) of combined
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1 organic ingredients at formulation by the

2 total weight (excluding water and salt) of the

3 finished product."

4 But we have made a change where it

5 will simply say "excluding water and salt of

6 all ingredients" instead of "the finished

7 product." So we'll be deleting the words "the

8 finished product" and inserting the phrase "of

9 all ingredients." And that's on the screen

10 now, yes.

11 Similarly, at No. 2, it says,

12 "Dividing the fluid volume of all organic

13 ingredients, excluding water and salt, by the

14 fluid volume of the finished" -- and we would

15 insert "all ingredients" and delete "the

16 finished product" -- "(excluding water and

17 salt) if the product and ingredients are

18 liquid. If the liquid product is identified

19 on the principal display panel or information

20 is being reconstituted from concentrates, the

21 calculation should be made on the basis of

22 single-strength concentration of" -- add the
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1 word "all" -- "the ingredients." Delete "and

2 finished product."

3 At (3): "For products containing

4 organically produced ingredients in both solid

5 and liquid form, dividing the combined weight

6 of the solid ingredients and the weight of the

7 liquid ingredients, excluding water and salt

8 by the total weight, excluding water and salt

9 of" -- insert the word "all ingredients,"

10 delete the phrase "the finished product."

11 And (3)(b): "The percentage of

12 all organically produced ingredients in an

13 agricultural product must be rounded down to

14 the nearest whole number." No changes there.

15 It should be understood by those

16 of you that are not familiar with processing,

17 the language we're proposing here is in

18 essence what everybody's been doing for the

19 last 10 years. So it is reflecting the

20 reality of the situation and it also meets the

21 OFPA requirements.

22 Our second recommendation relates
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1 to self-calculating forms. Section 205.302

2 states, "The percentage must be determined by

3 the handler who affixes the label on the

4 consumer package and verified by the

5 certifying agent of the handler. The handle

6 may use information provided by the certified

7 operation in determining the percentage." 

8 What the Subcommittee proposes is

9 that handlers utilize a self-calculating form

10 of their own or utilize a form provided by

11 their certifier so that a more uniform method

12 of calculation is established. We're not

13 looking for absolute similarity, but for

14 uniformity. And based on the input that we

15 received from public comment, we add in the

16 sentence which is underlined in red. We add

17 back in the language "one standard NOP18 generated form is not required." 

19 That language is also in the

20 discussion section of the document that was

21 circulated and published and it's simply being

22 repeated here in order that the NOP gets the
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1 clear message that neither the NOSB nor the

2 community at large wants the NOP to generate

3 a form which everyone should require, but that

4 the form should reflect the type of certifying

5 organization that is providing the

6 certification to the handler/processor. And

7 that seems like a very reasonable suggestion

8 to me.

9 The salt-excluded, No. 3,

10 recommendation is that the CACS proposes that

11 the only salt excluded from the calculation is

12 sodium chloride. Potassium chloride listed on

13 205.605 and any item on the National List such

14 as magnesium chloride or magnesium sulfate

15 used as an ingredient shall be counted in the

16 organic calculation. 

17 And those writing in to suggest

18 changes again recommended that we be sure to

19 add back into our recommendation to the NOP

20 language, which is in the discussion section,

21 which is on the screen right now and

22 underlined in red, which says, "Standard
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1 practice is to require any additives such as

2 anti-caking agents added to the salt to be on

3 the National List at 205.605 or 205.606. If

4 salt containing an additive on the National

5 List is added to a certified product, the

6 additive cannot be excluded. Therefore, the

7 product may not be labeled as 100 percent

8 organic."

9 This language is the same as in

10 the discussion section, as I said, and is

11 added in in order that it is clear to the NOP

12 what the intent is of the NOSB and the

13 certifying community at large. And I

14 recommend that change.

15 Under recommendation No. 4, Water

16 Excluded. Water is excluded from the

17 percentage calculations, as you heard in my

18 first reading of the rule, and that CACS

19 proposes extensive detailed and clear NOP

20 guidance to drive consistency among handlers

21 and certifiers to determine how much water

22 should be excluded from certain multi-
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1 ingredient formulations that include such

2 ingredients as chicken soup, soy milk, almond

3 milk, fruit juice, vegetable juice or ready4 to-drink teas. 

5 There was some additional comments

6 from, let's see, OTCO, which I was going to

7 look at here. Yes, OTCO had some specific

8 recommendations with regards to clarification

9 here to the NOP. "When clarification and

10 detailed guidance is provided by the NOP, we

11 would like to see formal calculations being

12 based on strong science and current industry

13 practices. Calculations should be developed

14 from items like extracts, hydrosols and

15 flavors. If we can agree on a sensible

16 extract calculation, we can use this

17 calculation for a wide variety of ingredient

18 calculations which can then provide the buyer

19 of an ingredient with an accurate verification

20 of organic content. 

21 "Additionally, standard

22 calculations for soy and almond milk-type
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1 products would provide industry

2 standardization. We would also like to see

3 that strong science is able to be used

4 alongside the FDA standards of identity and

5 not just leave the exclusion of water to

6 outdated FDA regulations."

7 And in doing the research for this

8 we all recognize that the water excluded

9 sounds simple, but in actual fact it's

10 extremely complicated. And so we would

11 recommend to the NOP really detailed guidance

12 together with specific examples in detail on

13 their Web site that everyone can then access,

14 because at the present time there is a lack of

15 consistency among certifiers as to their

16 understanding of how this should be dealt

17 with.

18 Recommendation No. 5, Processed

19 Single Ingredients. Handlers or certifiers

20 may request specification sheets from

21 manufacturers of processed single ingredients

22 if they desire more verification that the
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1 ingredient was not processed in a way there

2 would be remaining non-organic components in

3 the single ingredient product. And example of

4 such ingredients include oil, flour, sugar and

5 syrup.

6 I think this was broadly accepted

7 by everybody as being an important

8 recommendation. And again to urge

9 specification sheets, that was one of the

10 things that many of those who commented would

11 like to encourage more manufacturers to have,

12 which would make it much easier to do

13 calculations.

14 Under recommendation No. 6, the

15 single sentence that was put out for general

16 distribution is recommended to be deleted and

17 replaced by a longer explanation because it

18 was felt that the recommendation was too

19 abbreviated. And so we would delete the

20 sentence that says, "For multi-ingredient

21 ingredients such as chocolate chips where as

22 much as 5 percent of the ingredients may be
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1 non-organic, the certifier must provide

2 documentation of claims that the organic

3 content is beyond 95 percent if requested by

4 another handler or certifier." 

5 We would delete that and replace

6 it with something that is more explanatory. 

7 And it would state as follows, as you could

8 see on the screen in red and underlined: 

9 "Formulated multi-ingredient NOP-certified

10 products contain organic ingredients that are

11 either single ingredients or multi-ingredient

12 ingredients. For multi-ingredient products

13 added to the formula of another product such

14 as chocolate chips where as much as 5 percent

15 of the ingredients may be non-organic, the

16 actual organic content must be obtained if the

17 contributing content is above 70 percent

18 organic or 95 percent organic;" that obviously

19 is depending on the category, "otherwise the

20 ingredients should be calculated at either 95

21 percent organic or 70 percent organic,

22 depending on how the product is classified on
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1 the certificate. 

2 "And further, handlers must

3 provide certifiers with supporting

4 documentation that substantiates the organic

5 content claim of a multi-ingredient product

6 used in a production formulation submitted for

7 approval." 

8 And this of course is all really

9 in essence part of the discussion that comes

10 before these recommendations, but I hope that

11 that clarifies for those that several of the

12 commenters including OTA, OneCert, OTCO and

13 Smucker Natural Foods, everyone was supportive

14 of putting in this type of expansion into the

15 recommendation to be sure that it is clearly

16 received by the NOP for the guidance that they

17 would then develop.

18 Recommendation 7, Organic Label

19 Versus Organic Content. As specified in

20 205.302, the organic content or the percentage

21 of a product is based on a percentage of

22 organic ingredients. Sanitizers and
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1 processing aids are not ingredients, therefore

2 they should not impact the organic percentage

3 of a product. The use of a non-organic

4 processing aid prevents the single- ingredient

5 product from being labeled as 100 percent

6 organic, but when the product continues to

7 contain 100 percent organic ingredients and

8 can be calculated as such when it is

9 calculated into a multi-ingredient organic

10 product. There was universal agreement that

11 was appropriate.

12 Recommendation 8. Raw

13 agricultural and single-ingredient ingredients

14 can be assumed by handlers, manufacturers and

15 certifiers to contribute 100 percent organic

16 content in a multi-ingredient formulation even

17 if they are listed as quote/unquote "organic"

18 on a certificate except where it is clear that

19 the ingredient is significantly different from

20 the raw condition. 

21 And No. 9, NOP Guidance. That is

22 obviously extremely important. The NOSB
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1 recommends that the NOP establish and maintain

2 an easily accessible Web site with examples of

3 how to calculate percentage of organic

4 ingredients in multi-ingredient products and

5 related topics such how to determine when a

6 processing aid becomes an ingredient in

7 calculation and of course how to determine

8 excluded water. And again OTCO strongly urged

9 a good Web site where this kind of information

10 could be readily available.

11 This motion -- let's see, we

12 didn't actually approve the amendments, did

13 we? No? Okay. 

14 The document which was circulated

15 to the public without these changes in red

16 that you're seeing today had been approved by

17 our Subcommittee seven yes, zero no, one

18 absent. 

19 That concludes my presentation.

20 MEMBER DICKSON: At this point are

21 there any clarifying questions on the

22 presentation or the proposal from the Board? 
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1 Jay?

2 MEMBER FELDMAN: Yes, I'm trying

3 to understand the connection between the

4 calculation of ingredients and the labeling of

5 ingredients. And so do you expect that as a

6 result of this there will be more products in

7 the marketplace that can be labeled 100

8 percent organic?

9 MEMBER RICHARDSON: No, I don't

10 think that it will make any difference to the

11 use of the 100 percent organic category. 

12 There's almost no formulated products that are

13 on the market in the 100 percent category. 

14 And so I don't think this will make any

15 increase in that based on my experience as an

16 inspector and also from the research that I've

17 done, and from input from the certifiers.

18 MEMBER FELDMAN: Okay. And

19 everybody sort of concurs with that? Because

20 conceptually if there's no analysis of

21 certification of actual 100 percent

22 ingredients -- so in other words if you've got
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1 a calculation in which the individual

2 ingredients are deemed 100 percent now under

3 this new calculation and you add them into a

4 multi-ingredient product, each individually

5 100 percent, does that multi-ingredient

6 product become 100 percent for labeling? Just

7 as a follow up, because that's my dilemma. I

8 don't quite get that part of it.

9 MEMBER RICHARDSON: That's where

10 the distinct difference has to be sort of

11 understood in the difference between labeling

12 as opposed to organic ingredient content of

13 the product. So while it may have 100 percent

14 organic ingredients for purposes of

15 calculation, the label will not make 100

16 percent organic claim. It will only be making

17 the organic claim.

18 MEMBER FELDMAN: And if you could

19 just finish that thought. Because?

20 MEMBER RICHARDSON: Because that's

21 how it's set up under OFPA.

22 MEMBER FELDMAN: Okay. 
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1 MEMBER FOSTER: The simplest way

2 to finish that is because there is a

3 difference in the regulation between

4 composition and labeling. And that's what we

5 were talking about on Monday.

6 MEMBER FELDMAN: Okay.

7 MEMBER FOSTER: Yes.

8 MEMBER FELDMAN: Thank you.

9 CHAIRMAN STONE: And this doesn't

10 change any of that. This just helps clarify

11 in that process of calculating, uniformity of

12 the calculation. This doesn't change any of

13 how it's already operating.

14 MEMBER DICKSON: Miles?

15 MR. McEVOY: Yes, I appreciate the

16 work on this topic. It's very important to

17 have clear guidance on how to calculate

18 organic ingredients. And I note that in the

19 water-excluded part on passing it back to the

20 NOP to determine these out-of-date standard of

21 identities in the water part, that's very

22 complicated, as you mentioned. From our
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1 perspective it would be nice if the Board

2 continued to work on that particular topic,

3 rather than just leave it up to the Program to

4 make that determination. 

5 Then the other comment is on I

6 think it's 6, Multi-Ingredient Ingredients. 

7 I understand there's basically agreement on

8 that, the changes to the document and the

9 calculations there. I would just point out

10 that maybe is not completely in alignment with

11 the concept of sound and sensible. It's

12 pretty complicated. Well, it's more

13 complicated than a different approach. And

14 those kinds of things put additional burdens

15 on the smaller businesses that don't

16 necessarily have the same kind of resources to

17 get that information because they don't have

18 the leverage to get the information from their

19 ingredient suppliers. So just to point that

20 out that it can be more difficult for a

21 smaller bakery, for instance, to get that kind

22 of information about the percentage of the
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1 ingredients for an organic or made-with2 organic product.

3 MEMBER DICKSON: Jean?

4 MEMBER RICHARDSON: Yes, while I

5 respectfully agree with you -- I mean, or --

6 no, yes, sort of, I think that it does put

7 somewhat of a burden on the processors. On

8 the other hand, I think it's important that

9 the NOP sends out a clear message to the

10 manufacturers of the multi-ingredient

11 ingredients that the processor has to buy that

12 they need to make -- they need to know that we

13 need to know all the things that are in the

14 multi-ingredient ingredients. I mean it goes

15 back to the other ingredients discussions and

16 Jay's concerns, is that it should be

17 relatively easy for the manufacturer of the

18 chocolate chips to provide the processor,

19 whether large or small, with that information

20 on a specification sheet. 

21 The present situation is when you

22 go out and do inspections is that the
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1 processor says, you know, I called the

2 manufacturer and he says I don't have time to

3 give you those specification sheets. So if

4 the NOP sends out a message we expect those

5 specification sheets and information to be

6 available, then that will help reduce the

7 paperwork from both small and large processors

8 over the next few years.

9 MEMBER DICKSON: Understood.

10 MR. McEVOY: And just to make --

11 MEMBER DICKSON: Go ahead, Miles. 

12 Sorry. I just had a clarifying question that

13 I just want to make sure I understand No. 6

14 correctly. It's only requiring additional

15 documentation in a case where the manufacturer

16 wants to take credit for more than 95 percent. 

17 Without that documentation 95 percent is still

18 assumed. 

19 MEMBER RICHARDSON: Yes, 95

20 percent would still be the default.

21 MEMBER DICKSON: Thank you.

22 MR. McEVOY: Yes, I understand
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1 your point. It's a point well taken. Thanks.

2 MEMBER DICKSON: And, Miles, on

3 your earlier comment on the water exclusion,

4 do I hear you suggesting that we sort of hold

5 onto that piece of the recommendation and

6 perhaps your market for future committee work?

7 MR. McEVOY: Yes, exactly, that

8 the proposal is great and that particular

9 piece is complicated. And this is a great

10 forum to work out those difficulties rather

11 than just leave it to the Program to determine

12 what is the appropriate percentage of water

13 that you include or don't include in these

14 reconstituted products, because there's a lot

15 of opinions about it. There's a lot of

16 different products out there and this would be

17 a good forum to have that discussion and work

18 out what is the appropriate way to calculate

19 those types of ingredients. 

20 MEMBER DICKSON: Thank you. Any

21 other questions from the Board?

22 So a quick comment to those of you
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1 out there in the audience from all the

2 certifying agencies that have sent us in so

3 many other comments. Obviously as soon as

4 you'd like to start sending us stuff on water,

5 feel free to do so.

6 MEMBER DICKSON: Thanks. Mac,

7 that concludes our presentation of this

8 recommendation.

9 CHAIRMAN STONE: Thanks, Joe and

10 Jean. 

11 We have three people that signed

12 up for public comment specifically to this

13 session and several others that Michelle very

14 graciously worked with to work them into the

15 agenda. They couldn't be here other days. 

16 But several of these had not signed in when we

17 came back after the break. So I believe Mary

18 Mann. I believe Mary is here. 

19 As you make your way to the

20 podium, let me call out these other names

21 right quick. Gautami Makam. If you're here,

22 raise your hand and John will help watch. 
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1 Aurelie Lawrence, Donald Stroub, Raymond

2 Brown, Carol Ann Merchant, Sherry Lingerfelt,

3 Stephen Bennett, and Mary Essex.

4 Okay. So we have Ms. Mary Mann. 

5 And if you weren't here, just to be sure you

6 understand, there's the little stop light

7 mechanism there. The green light will be on

8 for three minutes, the yellow for one, and the

9 red you will stop when it goes off. Thank

10 you.

11 MS. MANN: Good morning. My name

12 is Mary Mann. I'm an Oregon resident. I'm a

13 mother, hopefully a future grandmother and I'm

14 deeply concerned about the health of my

15 family. We just welcomed 5 new babies into

16 the family in the last 18 months. I'm an

17 elected official. I'm a business owner. I'm

18 a consumer. I'm in total denial I'm a senior

19 citizen. 

20 (Laughter.)

21 MS. MANN: I'm a member of the

22 Cornucopia Institute and here today as a
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1 citizen lobbyist and I have volunteered to

2 help present testimony which I am concerned

3 about the use of antibiotics in organic

4 apples. I am a consumer and I was totally

5 stunned, even as informed as I thought I was,

6 that antibiotics were even used in sprays. 

7 And these are critical in human medicine and

8 are used in organic agriculture. I'd like to

9 see organics be part of the solution and not

10 part of the problem. Consumer union polling

11 data shows that I am not the only one who

12 believes this, who believes apples or pears

13 treated with antibiotics should not be sold as

14 organic.

15 Cornucopia conducted a survey to

16 find out if it was possible to grow apples

17 with antibiotics. I'd like to read some of

18 the comments from apple growers. They could

19 not be at this meeting, but their voice is

20 just as important as the apple growers who are

21 here to give testimony. So here are a few

22 verbatim comments to the words who returned
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1 this survey.

2 From an apple grower in New York

3 State: "I do not get it. Antibiotics are not

4 natural, so why should they be used in the

5 allowance of organic production? If you

6 cannot grow organic apples with antibiotics,

7 you should not be growing organic apples. I

8 love how the rules get bent when they are not

9 convenient."

10 From an apple grower in Eastern

11 Washington: "If antibiotics are prohibited,

12 I think I would be affected positively as

13 antibiotics are detrimental to the explanation

14 of organic."

15 From an apple grower in Western

16 Washington: "These antibiotic should be

17 banned now and not later."

18 From an apple grower in

19 California: "We would be very delighted if

20 antibiotics were prohibited for use in organic

21 apples and pears. This will mean safer

22 cleaner food for our customers, not to mention
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1 healthier."

2 And finally from Barry Flamm. This

3 is not part of the survey. He was a former

4 NOSB chair, an organic fruit grower in

5 Montana. "Materials that pose human health

6 and environmental risk must not be used in

7 organic production. Tetracycline is such a

8 material and its use in organic crop

9 production should not be allowed to continue. 

10 For many years I believe it has been clear

11 that the National Organic Standard Board's

12 intent to remove antibiotics from the National

13 List for fire blight control in apples and

14 pears."

15 And as that last note about the

16 five new babies in the family, their parents

17 are busy, busy people and I will share with

18 you their very literal -- it's all they can do

19 now to think about making sure that their

20 babies are safe. And prior to that they

21 probably ate convenience foods and all of a

22 sudden they're highly aware of what's going
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1 on. And when something says organic baby food

2 that's putting in their baby, they want to

3 know that 100 percent of that pear juice or

4 that pear puree is organic. Thank you very

5 much.

6 CHAIRMAN STONE: Thank you. Any

7 questions?

8 Okay. Thank you. Joe, before I

9 clarify for the vote; sort of make an

10 executive decision here, but we have two

11 categories and two winners of the public

12 speaking timing. So I have Ms. Goldie

13 Caughlan, who stopped the second that the red

14 light came on. 

15 So you get your choice between the

16 cup or the water bottle. 

17 (Laughter.)

18 (Applause.)

19 CHAIRMAN STONE: And Terry

20 Shistar, you get the one that Goldie doesn't

21 take for stopping. The timing was perfect

22 when you stopped already. So thank you both
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1 for respecting the time of your -- so thank

2 you.

3 (Applause.)

4 CHAIRMAN STONE: So, Joe, are we

5 ready? 

6 MEMBER DICKSON: Yes, I believe

7 we're ready to proceed with voting, if anyone

8 has a motion to make.

9 MEMBER RICHARDSON: Do you want me

10 to read the entire thing again? No? I make

11 a motion that we accept the recommendations as

12 written together with the amendments that were

13 put forward this morning at this meeting.

14 MEMBER DICKSON: Is there a

15 second?

16 MEMBER FAVRE: Second.

17 MEMBER WALKER: Second.

18 MEMBER DICKSON: I think Tracy won

19 that. Is there discussion on the motion? 

20 Jay?

21 MEMBER FELDMAN: Does anybody feel

22 like I do, that it would be helpful to put
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1 into the document a clause that said 100

2 percent organic only for the purpose of

3 calculating the organic percentage of multi4 ingredient so that there is no confusion over

5 how this gets used for purposes of labeling?

6 MEMBER DICKSON: Jean?

7 MEMBER RICHARDSON: I did propose

8 that very language change, Jay, when were

9 discussing it on the conference call and I

10 believe it was Emily that said that such an

11 addition was not necessary because it was

12 fully covered under OFPA.

13 MEMBER DICKSON: And, Michelle,

14 would you scroll back up to No. 7 on there

15 just so we all can see it? 

16 I mean my reading of the language

17 in No. 7 also underscores that this doesn't

18 impact the labeling claim around 100 percent

19 organic.

20 MEMBER FELDMAN: Because, you

21 know, I would propose as a friendly amendment

22 if it was acceptable to folks, if it
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1 reinforces existing law and is not at odds

2 with or contradictory to -- I don't -- you

3 know, but I'm not going to pursue it unless

4 there's support for that.

5 MEMBER DICKSON: I feel like

6 because it was the earlier advice of the

7 Program not to make that redundant language,

8 I'd like to ask the Program if they have an

9 opinion on that question today.

10 MR. McEVOY: Yes, it looks like

11 it's covered very clearly in 7, that it says

12 specifically, "The product continues to

13 contain 100 percent organic ingredients and

14 can be calculated as such when it is

15 calculated into a multi-ingredient ingredient

16 product. But before that the use of a non17 organic processing aid prevents the single18 ingredient product from being labeled as 100

19 percent organic." 

20 MEMBER FELDMAN: But the multi --

21 MR. McEVOY: So that seems to be

22 saying the same thing that you're saying, Jay.
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1 MEMBER FELDMAN: Is it? Does that

2 refer to multi-ingredients as well?

3 MR. McEVOY: Does that what?

4 MEMBER FELDMAN: Refer to multi5 ingredient products, with that clause you just

6 read.

7 MR. McEVOY: Well, that is

8 specifically about single ingredients. A

9 multi-ingredient product could also not be

10 labeled as 100 percent organic until it

11 contained 100 percent organic-labeled

12 ingredients as all the labeled ingredients.

13 MEMBER FELDMAN: I think so. I

14 hope so. Thank you.

15 MEMBER DICKSON: Harold?

16 MEMBER AUSTIN: I guess a people

17 of question, too, regarding No. 4, since the

18 Program would actually like us to take that

19 back and continue to work on that, would we

20 want to pass it with the verbiage that we

21 currently have in it now, or would we want to

22 modify that?
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1 MEMBER RICHARDSON: No, I would

2 like NOP to give us some extensive guidance on

3 it, personally.

4 (Laughter.)

5 MEMBER DICKSON: I mean I imagine

6 that if we left that language as it is, the

7 Program would perhaps ask us in the

8 communication for elaboration on that point,

9 or does it matter?

10 MR. McEVOY: Yes, it's possible. 

11 It's kind of up to your Subcommittee whether

12 or not you want to work on this in terms of

13 your workplan, that particular part of the

14 calculation. We will certainly work on this

15 if it's passed to provide further instruction

16 to certifiers about how to do the

17 calculations.

18 MEMBER DICKSON: But you wouldn't

19 see an issue if we left No. 4 in and then did

20 some more work on it?

21 MR. McEVOY: That would not be an

22 issue, no.
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1 MEMBER DICKSON: Okay. Thank you. 

2 Other questions or comments from

3 the Board?

4 (No audible response.)

5 MEMBER DICKSON: Well, shall we

6 vote?

7 CHAIRMAN STONE: Voting begins

8 with Harold.

9 MEMBER AUSTIN: Yes.

10 MEMBER TAYLOR: Yes. 

11 MEMBER MARAVELL: Yes.

12 MEMBER THICKE: Yes.

13 MEMBER BONDERA: Yes. 

14 MEMBER FAVRE: Yes.

15 MEMBER BECK: Yes.

16 MEMBER SONNABEND: Yes.

17 MEMBER FELDMAN: Yes.

18 MEMBER RICHARDSON: Yes.

19 MEMBER DICKSON: Yes.

20 MEMBER FOSTER: Yes.

21 MEMBER WALKER: Yes.

22 MEMBER FULWIDER: Yes.
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1 CHAIRMAN STONE: Yes. Vote was

2 unanimous and approval of the recommendation.

3 We have just a few minutes before

4 12:00. Did a lot of great work this morning. 

5 We have one, two, three, four, five, six

6 topics to work on after lunch and a brief

7 update on the Inerts Working Group, I believe. 

8 So it's been hard to get in and out, so we'll

9 still take the hour and 15 minutes and come

10 back at 1:15, which is a little more than an

11 hour and 15 minutes. Thank you.

12 (Whereupon, the hearing was

13 recessed at 11:53 a.m. to reconvene at 1:15

14 p.m.)

15

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 1:17 p.m.

3 CHAIRMAN STONE: I'm going to call

4 the meeting back in session.

5 (Whereupon, the bugle call "First

6 Call" was played.)

7 (Laughter.)

8 CHAIRMAN STONE: All right.

9 (Applause.)

10 CHAIRMAN STONE: You're making me

11 homesick, Francis. That's good. And you just

12 carry that everywhere you go, I guess, huh? 

13 Very good.

14 Okay. I think we're going to work

15 back through. We have five materials, no four

16 materials and two recommendations, if I got

17 that right. No, four and one. So no

18 particular order, but just sort of the way

19 they are on the sheet here.

20 I'm going to turn it over to Tracy

21 and I think we'll work through the pet food

22 amino acids, unless Michelle's telling me
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1 something different.

2 MS. ARSENAULT: You want to do

3 that first?

4 CHAIRMAN STONE: Oh, yes, let's do

5 the Inerts Working Group. Thank you,

6 Michelle. Yes, let's do the Inerts Working

7 Group just so we can get back in the flow

8 here. Thanks, Lisa.

9 DR. BRINES: All right. Thank

10 you. And Michelle's got me on a timer, so

11 let's see how I do.

12 (Laughter.)

13 DR. BRINES: So the purpose of

14 this brief update is to inform the Board and

15 the public here at the meeting on progress

16 since the last time on this work that the

17 Board and the Program and the EPA is doing,

18 collaborating on updating our approach to

19 inert ingredients. 

20 Okay. So we have two NOSB members

21 in this working group who are both absent from

22 the table right now. I'd like to recognize
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1 Jay and Zea as part of the working group. 

2 From the Program it's myself and Emily Brown3 Rosen and two members from EPA that are

4 assisting with this work, Chris Pfeifer in the

5 Biopesticides and the Pollution Prevention

6 Division and Kerry Leifer, who works

7 specifically on inerts issues with the EPA.

8 So as brief background, the

9 Organic Foods Production Act indicates that

10 the National List may provide for the use of

11 inerts in pesticides that are not classified

12 by EPA as inerts of toxicological concern. We

13 do have definitions for inert ingredients in

14 the NOP regulations, which are essentially

15 adopted from EPA's definition in FIFRA. 

16 So terminology can be confusing. 

17 Inert doesn't necessarily mean chemically or

18 biologically inert in the same way that

19 nitrogen is an inert gas, but we're working

20 with regulatory definitions from EPA.

21 Okay. So the rule on inerts

22 currently. Inerts are listed in several
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1 sections of the National List. So List 4

2 inert ingredients were previously considered

3 by EPA as inerts of minimal concern. This

4 includes synthetic inert ingredients that were

5 previously classified by EPA as either List 4A

6 or List 4B. These inerts are currently

7 allowed in pesticide products used by organic

8 crop producers and organic livestock

9 producers. So they appear twice on the

10 National List at Section 205.601 for crop

11 production and also at 205.603 for livestock

12 production. In addition to the allowances for

13 List 4 inerts there's also a limited use of

14 List 3 inerts, and those inerts are allowed

15 only in passive pheromone dispensers. And the

16 citation is on the slide.

17 Okay. So what is the issue? So

18 as we heard in public testimony earlier today,

19 is that this list of inerts is no longer

20 maintained by EPA. The last update to the

21 List as published is actually 2004. So in

22 2006, EPA completed their reassessment of
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1 these inert ingredients. 

2 So instead of using this

3 Classification List 1 through 4, which is sort

4 of grouping them according to toxicology and

5 their use pattern pesticides is that they have

6 moved the allowances for those inerts into

7 their actual EPA regulation. So if you go to

8 4 C.F.R., Part 180, which is the EPA

9 regulations, they've either established

10 tolerances or tolerance exemptions for these

11 inert ingredients that are currently allowed

12 for use.

13 So we here at the NOP are still

14 operating under that obsolete list of inerts

15 because of the way our regulations are citing

16 that old EPA list. And so in the interim,

17 since that last update was done, we received

18 a number of petitions for inerts that are not

19 on that old EPA list but that might be allowed

20 by EPA in products as exempt from a tolerance,

21 or that are just allowed and may be better

22 than some of the things that are on our list.
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1 So at the last meeting in

2 Providence the NOSB issued a recommendation on

3 policies and procedures for review of inert

4 ingredients and pesticide formulations. So

5 this recommendation took into consideration

6 ongoing work from the Inerts Working Group and

7 feedback. In February we responded to all the

8 recommendations from the fall meeting, so I'll

9 just go briefly through the highlights for

10 that.

11 So in the fall what this Board had

12 recommended was a series of steps to use for

13 preparing inerts review, some screening

14 guidelines, and a tentative list of proposed

15 groups, including a time line for review. The

16 Board also had requested that the Program

17 identify a mechanism to notify manufacturers

18 and the public regarding this inert review

19 process, and specifically that that mechanism

20 should include a list of which inerts are

21 under review and also how to inform the

22 working group of those inerts that are in use
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1 but might not be on our radar, or on known

2 list.

3 So a couple of issues in

4 determining which inerts are going to be

5 subject to this review. EPA governs pesticide

6 labeling in the U.S. and they do not require

7 that inert ingredients be included, disclosed

8 on pesticide labels. So they do require the

9 active ingredient, but you'll generally see a

10 listing under that active ingredient that says

11 either inert ingredients or other ingredients. 

12 So you have to indicate the percentage of

13 those inert ingredients, but not necessarily

14 identify them.

15 In previous work the working group

16 had identified and grouped a number of inert

17 ingredients. That was based on some feedback

18 from two material evaluation programs. So we

19 think we have at least a starting point for

20 what this list of inerts will look like. List

21 4, if you look at it, there's a lot of inerts

22 on that list, but what we know is that what's
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1 currently in use is really a small subset of

2 that list. 

3 We have not yet published that

4 full list of inerts. Again we did publish a

5 list of the tentative groups as part of the

6 last Board recommendation, but our intention

7 is to publish that list and the groupings for

8 public comment before proceeding further.

9 So in response to the Board's

10 recommendation for a notification step, our

11 intent is to notify the public of the inert

12 ingredients that we know to be in use in

13 organic production, and again, the basis for

14 that knowledge is the information supplied by

15 material review organizations; to also notify

16 the public of the Board's review plan

17 including how those inerts are currently

18 grouped to get feedback on that, as well as

19 how the Board intends to conduct this review.

20 That notice will include a request

21 for public comments regarding again the inerts

22 that are currently in use and that may not
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1 appear on that list yet. And we have drafted

2 a Federal Register notice which will include

3 that official request for public comment. 

4 That notice is under legal review and I don't

5 have an estimate on when that will be

6 published just yet.

7 One additional, I guess, point for

8 that Federal Register notice: It's not really

9 our intent at this point in the process to be

10 asking for feedback from the public on which

11 inerts should be allowed in organic production

12 and should not be allowed in organic

13 production. Really the intent of this notice

14 is to gather information, what's currently in

15 use and will need to be reviewed by the Board

16 in order to implement the update to the

17 regulations. 

18 Okay. So after that notice is

19 published, the working group will use the

20 comments to finalize the groups of inerts and

21 initiate technical reports. So we've

22 previously told the Board that based on our
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1 current estimates there is about 126 inerts

2 that we're aware of that may be in use in

3 products that are marketed for organic

4 production or for organic use. So we'll use

5 the comments received to finalize those lists. 

6 And for efficiency, our intent is

7 to initiate the development of one technical

8 report per group of inerts. So we understand

9 that these will be longer technical reports

10 typically than probably for single ingredient

11 substances. But the intent is to not have one

12 technical report per each individual inert

13 ingredient that might be considered by the

14 Board. And again, the Board, following the

15 recommendation, will review these inerts by

16 group rather than making individual

17 recommendations for those substances.

18 So additional progress. Since

19 last fall we've worked with EPA closely to

20 refine those groups. We think we've got a

21 good handle on, for the existing ones that

22 we're aware of, how those will be grouped. So
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1 that will be included in the Federal Register

2 notice. Again, we've gone through the

3 technical report template that is used for

4 materials used in crop and livestock

5 production. We've identified a couple of

6 areas that we might update for these group

7 reports, taking into consideration what was in

8 the recommendation from the Board in the fall,

9 as well as some of the issues that might need

10 to be highlighted when things are reviewed as

11 a group, rather than as individual substances. 

12 So, you know, there will be probably a

13 learning curve as we do the first couple of

14 these, but we'll see how it goes.

15 And we've also taken one of these

16 identified groups and sort of done a test run

17 using the NOSB checklist that you're familiar

18 with in evaluating substances for crop

19 production. So we don't have the technical

20 report yet, so it is really a trial, but just

21 to see how that would work and how things

22 might work by running that through as a group
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1 rather than one single individual substance.

2 Okay. So just briefly, timelines. 

3 So what was in the fall recommendation, the

4 intent was to review four to six of these

5 inerts groupings per year during the four-year

6 period beginning in 2013 in order for the

7 Board to complete most of its reviews by

8 spring of 2015. So that timeline that was

9 included in the Board recommendation was

10 intended to allow time for the Program to

11 complete any rulemaking needed to update the

12 listing for inerts by the sunset date for List

13 4. So that's October 2017 for both the List

14 4 listing for crop production and for

15 livestock.

16 Within that recommendation, the

17 Board acknowledged that an implementation

18 period will be needed. So that will depend on

19 the public comment we receive. If there's

20 additional time, that might be needed to

21 complete the reviews and also time for

22 reformulation and compliance, if needed. So
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1 at this point we don't really know what the

2 outcome of these reviews will be, so it's hard

3 to gauge how many products may need to be

4 reformulated or whether products will comply

5 with whatever this outcome is, but we

6 understand that if reformulation is necessary,

7 we'll need to allow adequate time for that to

8 take place. 

9 So I guess the last step in terms

10 of timeline is that the Board did agree in the

11 fall recommendation to assess the viability of

12 this proposed timeline after it completes its

13 recommendation on the first few groups of

14 inerts. So as the work continues, as the

15 technical reports are developed, we'll see how

16 the process goes, but we do have, I guess, an

17 excuse to go and look back and reassess if we

18 need to, if there are some tweaks that we need

19 to make to the process. 

20 And that's it. Thank you.

21 CHAIRMAN STONE: Questions for

22 Lisa, or for Jay or Zea that's on the
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1 Committee?

2 MEMBER FELDMAN: I just want to

3 thank the Program for all the work that's

4 going into this and has gone into this. This

5 is an incredibly important area of review and

6 strengthens organic tremendously in the

7 market. Thank you.

8 CHAIRMAN STONE: Francis?

9 MEMBER THICKE: Is this going to

10 be available for us? Lisa, could we have

11 these PowerPoints in Dropbox or something?

12 DR. BRINES: Yes, the presentation

13 will be posted for the Board and the public on

14 our web site in the next few days. Thanks.

15 CHAIRMAN STONE: Okay. 

16 DR. BRINES: All right. Thank

17 you.

18 CHAIRMAN STONE: Thank you very

19 much. Appreciate all y'all's due diligence on

20 that one. Okay. I think that I'll turn it to

21 Tracy, and we'll have Lisa read the proposal. 

22 And we'll check for declarations, just as a
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1 reminder.

2 MEMBER FAVRE: Thank you for that

3 reminder after lunch. That's always welcome. 

4 It's my understanding we are going

5 to have a revised recommendation for the

6 proposal for the pet food amino acids.

7 Lisa, do you want to go ahead and

8 -- do we have to do that again, or no? Yes. 

9 No? She says no.

10 CHAIRMAN STONE: And Michelle will

11 bring it up while Lisa --

12 MEMBER FAVRE: She shakes her head

13 no.

14 DR. BRINES: Yes, we've already

15 done the introduction for the petition, so I

16 think Subcommittee can take over from here. 

17 MEMBER FAVRE: Thanks. Okay. Mac,

18 you took the lead on this. While Michelle's

19 bringing it up, you want to walk through the

20 rationale and the discussion?

21 CHAIRMAN STONE: Okay. Thanks,

22 Tracy. Yes, so based on written comment and
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1 public testimony day before yesterday I guess

2 -- yesterday morning -- seems like a long time

3 ago -- we heard and the Committee felt

4 compelled, I'll say it that way, to include or

5 add taurine, synthetic taurine to be available

6 in organic dog foods, not just cat food. And

7 actually the amended motion is pet food. And

8 that's a little bit the vernacular that's used

9 in the rulemaking that will come out -- what

10 date did I say? I think that was October

11 11th, Melissa, that I said on that one. So

12 when the standards come out, you know, that's

13 in line with what we think that language is

14 going to look like versus saying dogs and cats

15 or canine and feline, or whatever. 

16 So I'll be glad to go back through

17 any other discussion if Board Members have any

18 clarifications or questions about that.

19 MEMBER FAVRE: Seeing no

20 discussion, do we have any declaration of

21 interest for this from the Board?

22 (No audible response.)
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1 MEMBER FAVRE: Well, in the

2 interest of full disclosure, I should say that

3 I am a breeder of dogs and I do use pet foods

4 with taurine in it. 

5 CHAIRMAN STONE: Great. Jay?

6 MEMBER FAVRE: Okay. So are we

7 prepared to vote on this again?

8 MEMBER FELDMAN: I'm sorry, I

9 should have said yes when you asked if there

10 were any questions.

11 MEMBER FAVRE: Go ahead, Jay.

12 MEMBER FELDMAN: The question I

13 had yesterday I'm still not clear on. I came

14 across one manufacturer, I think I mentioned,

15 Natural Logic or something, that claims that

16 because of the protein-based diet that they

17 have, I assume it's meat-based, that they meet

18 all of the whatever-the-trade-group-is

19 standards for taurine and other amino acids

20 and so forth. Is that true, or have you

21 looked into that?

22 CHAIRMAN STONE: Yes. Sorry, Jay,
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1 I should have followed up because I know you

2 specifically asked about that. The Committee

3 did a survey of -- it's a countable number,

4 but there's a countless number of pet foods,

5 and some manufacturers were producing dog

6 foods that were called "complete and balanced"

7 without any synthetic amino acids. There are

8 several. Just glancing at the list here

9 there's 8 or 10 or 12 that had no added

10 taurine. Some had carnitine and lysine, but

11 not added taurine. 

12 But the issue I think that we felt

13 -- because the large breed dogs specifically,

14 and I think, Joe, you said cocker spaniels or

15 something were sort of called out

16 specifically, that because of manufacturer

17 distribution and what not that there's -- the

18 manufacturers and the Pet Food Institute felt

19 like that to have the reach and not get

20 tripped up, someone would be feeding their dog

21 an inferior product if they met some of that,

22 that the Committee was comfortable adding
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1 taurine to dog food. It's still a degradation

2 and processing sort of issue specifically to

3 taurine.

4 MEMBER FELDMAN: But it is true

5 then, the manufacturer's claim you believe to

6 be true, that without added taurine that their

7 ingredients provide adequate nutrition?

8 CHAIRMAN STONE: Yes, from looking

9 at this label survey that we did, there are

10 several that claim they can do it without

11 taurine.

12 MEMBER FAVRE: Jay, I might add

13 that it looked as though from the public

14 comments yesterday that some of this research

15 about heart disease and blindness is

16 relatively new as it relates to taurine and

17 giant breeds.

18 Any other questions?

19 (No audible response.)

20 MEMBER FAVRE: Okay. So we have a

21 listing motion. Motion to list amino acids

22 arginine, methionine, cystine, lysine,
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1 tryptophan, threonine, histidine, isoleucine,

2 leucine, phenylalanine, tyrosine and valine --

3 and I get extra brownie points for doing that

4 after lunch -- on Section 205.605 for use in

5 organic pet food. Do I have --

6 CHAIRMAN STONE: Technically we

7 need to do a classification motion first.

8 MEMBER FAVRE: Oh, I'm sorry. Did

9 I do the listing? And you know what, you told

10 me not to do that.

11 (Laughter.)

12 MEMBER FAVRE: I was looking at

13 the wrong page. Classification motion to --

14 I'm not reading them again unless it's

15 absolutely required; somebody give me a nod --

16 as synthetic. Do I need to do it again?

17 CHAIRMAN STONE: I think just read

18 them again, just for clarity. 

19 MEMBER FAVRE: Oh.

20 CHAIRMAN STONE: You've practiced

21 already.

22 MEMBER FAVRE: All right. 
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1 Classification motion. Motion to classify

2 amino acids arginine, methionine, cystine,

3 lysine, taurine, tryptophan, threonine,

4 histidine, isoleucine, leucine, phenylalanine,

5 tyrosine and valine as synthetic. Do I have

6 a motion?

7 CHAIRMAN STONE: I'll make that

8 motion.

9 MEMBER FELDMAN: I'll second that.

10 MEMBER FAVRE: I have a motion and

11 a second. Any further discussion?

12 (No audible response.)

13 CHAIRMAN STONE: The vote begins

14 with Jennifer. And I would remind everyone if

15 you'll go just a little bit slower so Wendy

16 and Calvin can be sure to -- and Michelle over

17 there can get an accurate tally.

18 MEMBER TAYLOR: Yes. 

19 MEMBER MARAVELL: Yes.

20 MEMBER THICKE: Yes.

21 MEMBER BONDERA: Yes. 

22 MEMBER FAVRE: Yes.
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1 MEMBER BECK: Yes.

2 MEMBER SONNABEND: Yes.

3 MEMBER FELDMAN: Yes.

4 MEMBER RICHARDSON: Yes.

5 MEMBER DICKSON: Yes.

6 MEMBER WALKER: Yes.

7 MEMBER FULWIDER: Yes.

8 MEMBER AUSTIN: Yes.

9 MEMBER FOSTER: Yes.

10 CHAIRMAN STONE: Yes. So that was

11 15 yes, zero nos.

12 Miss Tracy?

13 MEMBER FAVRE: Now we had a little

14 bit of procedural confusion on this because

15 these were listed as -- or petitioned as a

16 group, but given the fact that we've come up

17 with a recommendation for only taurine to be

18 included, we have two listing motions. The

19 first one is: motion to list amino acids

20 arginine, methionine, cystine, lysine,

21 tryptophan, threonine, histidine, isoleucine,

22 leucine, phenylalanine, tyrosine and valine on
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1 Section 205.603 for use in organic pet food. 

2 Do I have a motion?

3 MEMBER BONDERA: I so move.

4 MEMBER FAVRE: Okay.

5 MEMBER RICHARDSON: Second.

6 MEMBER FAVRE: Okay. I have a

7 motion and a second. Is there any

8 conversation/discussion?

9 (No audible response.)

10 MEMBER FAVRE: Okay. Hearing

11 none, we're prepared to vote.

12 CHAIRMAN STONE: Okay. The vote

13 will begin with Nick.

14 MEMBER MARAVELL: No.

15 MEMBER THICKE: No.

16 MEMBER BONDERA: No. 

17 MEMBER FAVRE: No.

18 MEMBER BECK: No.

19 MEMBER SONNABEND: No.

20 MEMBER FELDMAN: No.

21 MEMBER RICHARDSON: No.

22 MEMBER DICKSON: No.
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1 MEMBER FOSTER: No.

2 MEMBER WALKER: No.

3 MEMBER FULWIDER: No.

4 MEMBER AUSTIN: No.

5 MEMBER TAYLOR: No.

6 CHAIRMAN STONE: Chair votes no. 

7 That's 15 nos. Motion fails.

8 Miss Tracy?

9 MEMBER FAVRE: Our second listing

10 motion is: motion to list taurine, CAS No.

11 107-35-7 at 205.603(d) as a feed additive for

12 use in pet foods. Do I have a motion?

13 CHAIRMAN STONE: I'll make that

14 motion.

15 MEMBER FAVRE: Okay. Do I have a

16 second?

17 MEMBER FULWIDER: Second.

18 MEMBER FAVRE: Any discussion?

19 (No audible response.)

20 MEMBER FAVRE: Hearing none, we're

21 prepared to vote.

22 CHAIRMAN STONE: Thanks, Tracy. 
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1 The vote will begin with Francis.

2 MEMBER THICKE: Yes.

3 MEMBER BONDERA: Yes.

4 MEMBER FAVRE: Yes.

5 MEMBER BECK: Yes.

6 MEMBER SONNABEND: Abstain. 

7 MEMBER FELDMAN: No.

8 MEMBER RICHARDSON: Yes. 

9 MEMBER DICKSON: Yes.

10 MEMBER FOSTER: Yes. 

11 MEMBER WALKER: Yes.

12 MEMBER FULWIDER: Yes. 

13 MEMBER AUSTIN: Yes.

14 MEMBER TAYLOR: No.

15 MEMBER MARAVELL: Yes.

16 CHAIRMAN STONE: Chair votes yes. 

17 Thirteen -- no, twelve yeses, two nos and one

18 abstention. Motion is approved. Thank you,

19 Tracy.

20 Jay, if you're ready, I'm thinking

21 in terms if we do like polyoxin and IBA, sort

22 of move those on through. Then we'll have the
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1 balance of our day on other ingredients and

2 tetracycline. Is that workable?

3 MEMBER FELDMAN: Thank you. If,

4 Harold, you're ready, I think we could do

5 polyoxin D zinc. Thanks.

6 MEMBER AUSTIN: Okay. We had, you

7 know, some testimony yesterday. We kind of

8 rushed this one a little bit during the

9 Committee process, but I think we had some

10 good testimony. 

11 One of the concerns that we'd had

12 with this material is its broad base as a

13 fungicide. I think, you know, we had some

14 descriptive explanations of its activity on

15 soil beneficials. We had concerns over one

16 test of how this material was controlled, its

17 effect on a roach study that was done, and I

18 think some of the concerns were dispelled on

19 that by the process of the study. There were

20 some environmental concerns with earthworms. 

21 The petitioner did provide us with some

22 additional studies during the course of the
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1 last week. I think all of the Subcommittee

2 had received that. 

3 So we've got a motion to classify

4 as polyoxin D zinc salt as petitioned as a

5 synthetic. That came out of the Subcommittee. 

6 And we'll move that to a vote, I guess, Jay,

7 unless, you know, we want to go ahead and move

8 the motion or open it up for some discussion

9 at this point.

10 MEMBER FELDMAN: I'd ask if there

11 are any questions on this.

12 MEMBER AUSTIN: Okay. Any

13 questions from the Board at this time?

14 MEMBER FELDMAN: And this would be

15 questions on the overall issue including the

16 classification and the listing motion?

17 MEMBER AUSTIN: Correct.

18 CHAIRMAN STONE: I have one.

19 MEMBER AUSTIN: Mac?

20 CHAIRMAN STONE: If the source of

21 the zinc were more well known or defined as a

22 mined product, would that have affected some
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1 of your all's votes, or perception of the

2 material, I should say?

3 MEMBER AUSTIN: I think in some of

4 the discussion that we had, the source of the

5 zinc was a definite component of why the

6 material ended up being classified as a

7 synthetic. The petitioner themselves get the

8 zinc, the product from multiple sources, so

9 they couldn't define if it a natural mined

10 material or if it was a product of sub11 manufacturing. So that basis was really the

12 main key basis why we went ahead and moved

13 this forward as a synthetic, or at least that

14 was our motion from the Subcommittee.

15 Any other concerns with that or

16 questions regarding that issue? Jay?

17 MEMBER FELDMAN: Well, you know,

18 there's been some lack of clarity around this

19 whole thing, you know, this whole discussion

20 regarding the broad spectrum or non-specific

21 effect of the material. And we've been mostly

22 concerned about the chitin-inhibiting effects
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1 of the material. 

2 You know, I was looking at the

3 label on this; I was trying to pull this up as

4 we were talking, but the label on this is

5 pretty clear that it has these, fungistatic

6 they're called, effects, which at least as it

7 appears on the label, are generalized to the

8 population of soil fungi. 

9 So I guess my question from, you

10 know, a soil standpoint is whether we should

11 be allowing or listing a material that seems

12 to work contrary to the statutory and

13 regulatory standard to maintain or improve

14 soil and environment. And I guess that is the

15 general -- this chitin inhibition and the --

16 even, I think there was an acknowledgment

17 yesterday by the professor that while it was

18 generalized, he seemed to be less concerned

19 because of the fact that fungi might bounce

20 back or would bounce back afterwards.

21 I think, you know, if we're

22 talking about all the stressors that farmers
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1 experience with developing soil fertility,

2 this just seems to run contrary to those

3 practices. So it would be interesting to see

4 if organic farmers as opposed to IPM farmers

5 that have more leeway in terms of introducing

6 other soil fertility methods would even choose

7 to use something like this. It just seems

8 contrary to and incompatible with organic

9 practices.

10 MEMBER AUSTIN: Tracy?

11 MEMBER FAVRE: Jay, just to

12 address that comment, I had those same

13 concerns on the chitin inhibition. I'm not

14 particularly for this material, but one of the

15 presenters yesterday did say that not all

16 chitin is the same and that the difference

17 between this product and others is that it was

18 specifically targeted for the kind of chitin

19 in the cell walls of the particular fungi that

20 caused the problem. And I think the issue

21 about the cockroaches was sort of debunked

22 anyway.
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1 MEMBER AUSTIN: Zea?

2 MEMBER SONNABEND: In addition to

3 looking at the direct effect on the soil that

4 any one compound would have, we have to look

5 at it in relationship to the alternatives to

6 that material. And I do not see this one as

7 having any greater effect than the other

8 things that are on the List as fungicides such

9 as copper and sulfur compounds. In fact, I

10 think it has less effect overall because it is

11 so short-lasting compared to copper and sulfur

12 which have residuals that will last for quite

13 a long time. And therefore, I feel that it is

14 a valuable tool as the people stated, in an

15 alternating situation where you can alternate

16 this very benign material with a harsher

17 material to avoid developing resistance. 

18 So I do see it as appropriate. 

19 With any relatively new material, we're not

20 going to have the benefit of grower experience

21 to compare it to the alternatives that are

22 listed on labels only because it has not been
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1 allowed in organics so far. And so we just

2 don't have growers who are stakeholders that

3 are going to be able to report to us. 

4 But I do think that it is a better

5 choice in many of these harder-to-control

6 diseases than what we have now, and truly for

7 things like late blight in tomatoes and the

8 disease which I can't pronounce, that Jerry

9 Thomas was here about, those that truly are

10 not other choices. You just take your lumps

11 and move on.

12 MEMBER AUSTIN: Mac, do you have a

13 question?

14 CHAIRMAN STONE: Excuse me. 

15 Apologize for disrupting the flow of the

16 conversation, but I guess point of order. We

17 should have a motion and a second for

18 discussion purposes.

19 MEMBER AUSTIN: Okay. The motion

20 that we had out of the Crops Committee was to

21 classify polyoxin D zinc as petitioned as a

22 synthetic.
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1 MEMBER FELDMAN: Second.

2 MEMBER AUSTIN: We have a second. 

3 Do we want to go ahead with the -- should we

4 go ahead and vote on this one, or do we want

5 to continue to discuss now that we have a

6 motion on the floor?

7 CHAIRMAN STONE: If there's

8 discussion on classification, then we can have

9 that discussion now. Then we can discuss --

10 MEMBER AUSTIN: Okay.

11 CHAIRMAN STONE: -- attributes in

12 the next motion.

13 MEMBER AUSTIN: Any further

14 discussion on the classification?

15 (No audible response.)

16 MEMBER AUSTIN: If not, I think

17 we're prepared to vote.

18 CHAIRMAN STONE: Okay. Colehour

19 is the first vote.

20 MEMBER BONDERA: Yes.

21 MEMBER FAVRE: Yes.

22 MEMBER BECK: Yes.
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1 MEMBER SONNABEND: Yes.

2 MEMBER FELDMAN: Yes.

3 MEMBER RICHARDSON: Yes. 

4 MEMBER DICKSON: Yes.

5 MEMBER FOSTER: Yes. 

6 MEMBER WALKER: Yes.

7 MEMBER FULWIDER: Yes.

8 MEMBER AUSTIN: Yes.

9 MEMBER TAYLOR: Yes.

10 MEMBER MARAVELL: Yes.

11 MEMBER THICKE: Yes.

12 CHAIRMAN STONE: And yes. Sounds

13 like unanimous 15-0. Harold?

14 MEMBER AUSTIN: Okay. For the

15 listing motion itself, to add polyoxin D zinc

16 salt to the National List at 205.601 as a

17 synthetic substance allowed for use in organic

18 crop production.

19 MEMBER BONDERA: I so move.

20 MEMBER THICKE: I'll second.

21 MEMBER AUSTIN: We have a motion

22 and we have a second. Is there any discussion
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1 on the listing motion? John?

2 MEMBER FOSTER: So the question

3 about statutory-ness -- I know it's not a

4 word, but I'll use it anyway -- I think the

5 National List was designed to be a list of

6 exceptions, so it's already a list of

7 exceptions. And if that wasn't okay, we

8 wouldn't have a list of exceptions. And the

9 exceptions only go on after, I would say, a

10 fair degree of scrutiny and those exceptions

11 aren't allowed unless they're listed. 

12 So I think the whole regulation

13 was built, designed, intended to allow a spare

14 number of exceptions, and I think this is a

15 good example of a preferable material that in

16 my view meets the criteria adequately and has

17 the potential to replace more problematic

18 materials. If it's a little bit better, then

19 that's better and we should go with better. 

20 If it's not perfect, it joins a long line of

21 things that aren't perfect. So I'm okay with

22 a little bit better, and I'll stop there.
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1 MEMBER AUSTIN: Francis?

2 MEMBER THICKE: Yes, I'd like to

3 address the issue of it being a more broad4 spectrum fungicide or, as it said in the

5 technical review, it actually has been

6 classified as an antibiotic by -- they listed

7 eight references for that. And on the label,

8 as I think Jay said, it's listed as a

9 fungicide and it also has a warning about

10 overuse and resistance, so we have to watch

11 out for that. 

12 And as far as being broad13 spectrum, there are listed in the technical

14 review 22 different pathogens that it's active

15 against. And so of course that means it's

16 pretty broad-spectrum and it would be as well

17 probably, as they actually say, against a wide

18 range of fungi, which would be beneficial as

19 well. So I'm concerned about that.

20 There was something you said

21 earlier and that in the petition that it's a

22 fungistatic and not a fungicide, but if you go
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1 on Google, the definition of fungicide, it

2 actually says it inhibits or kills fungus. So

3 it really is a fungicide.

4 And then the half-life is 32« days

5 at ambient -- you know, at 77 degrees

6 Fahrenheit at pH 7. So that's a long half7 life for soil bacteria -- soil fungi to be,

8 you know, working against it and then half is

9 still left. And often it can be cooler, so it

10 could have a longer time. So I'm concerned

11 about the effects on beneficial soil life and

12 especially, as I think Jay mentioned, if

13 you're trying to build up your soil life and

14 build that whole thing up in your soil, you're

15 going to be working against that.

16 MEMBER AUSTIN: I think as far as

17 the antibiotic part of it, the definition or

18 the explanation that the petitioner gave us,

19 the rationale that it was listed as a

20 fungicide rather than an antibiotic was that

21 this is not used in animal or human health,

22 strictly in plant control and the disease
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1 vector.

2 MEMBER THICKE: Okay. 

3 Interesting.

4 MEMBER AUSTIN: Francis?

5 MEMBER THICKE: I wouldn't argue,

6 actually. I think the distinction is fine,

7 but they did mention that. They called it an

8 antibiotic. But I think a fungicide is

9 actually more appropriate.

10 MEMBER AUSTIN: Yes. The other

11 thing I would point out, because we really

12 didn't cover this very well yesterday, we kind

13 of rushed through it; and these were some of

14 the concerns on the majority opinion coming

15 out of the Crops Committee, from some of the

16 speakers, also from the minority opinion

17 coming out of the Crops, was, you know, I

18 think we've heard it a little bit, was that

19 this is a unique mode of action. It's a FRAC

20 19. It will aid in resistance management,

21 rather than using the same fungicidal approach

22 over and over and over again. So the grower
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1 would be able to use it in a rotational

2 fashion.

3 The other positive part of that

4 was that it is a curative material, so that

5 they don't technically have to go out in a

6 prophylactic approach and apply it, that they

7 would be able to apply it after they've had a

8 infection rather than prior to infection,

9 where the materials, the fungicides that they

10 have currently would have to be preemptive and

11 put on prior to an infection starting to take

12 place and develop. So there are some

13 advantages in looking at the mode of action,

14 looking at how it would be applied, how it

15 would be utilized. 

16 I think total, I believe there

17 were five diseases that the material itself

18 would be effective in controlling. Alternaria

19 was one of those. Yes, I'm not sure that was

20 the one you'd been having trouble with. Gummy

21 stem and then Southern blight were kind of the

22 three that really stood out that really did
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1 not have very good control methods or

2 materials out there that -- especially in the

3 coastal regions where they really had a lot of

4 high humidity.

5 Any further questions? Jay?

6 MEMBER FELDMAN: I thought it

7 might be interesting for folks to be aware --

8 it's interesting you mention resistance

9 management, because on the label they have a

10 box that's identified as resistance

11 management, and they say that the fungicide

12 contains a Group 19 fungicide. Fungal

13 isolates with acquired resistance to Group 19

14 may eventually dominate the fungal population

15 if Group 19 fungicides are used repeatedly in

16 the same field or in successive years as the

17 primary method of control for targeted

18 species. This may result in partial or total

19 loss of control of those species by -- and

20 then this polyoxin D product which happens to

21 be ENDORSE Wettable Powder Turf Fungicide, or

22 other Group 19 fungicides. 
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1 And then they have a list of

2 resistant management practices that they

3 suggest in terms of utilizing, rotation --

4 uses like you're referring to, and monitoring

5 treated fungal populations for loss of field

6 efficacy. So there is, like we know from the

7 conventional side, where you get dependent on

8 these products you end up with a resistance

9 problem.

10 MEMBER AUSTIN: Well, and I think

11 that the general opinion or the practice or

12 approach was going to be that it was going to

13 be used as a tool, part of a rotational

14 process. And if I'm not mistaken, in the

15 information that we were presented with, this

16 is the only FRAC 19 material out there.

17 Any further discussions? Any

18 further questions?

19 (No audible response.)

20 MEMBER AUSTIN: Hearing none, I

21 think we're ready to vote.

22 CHAIRMAN STONE: Okay. Thank you,
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1 Harold. I'm thinking that Tracy is first.

2 MEMBER FAVRE: No.

3 MEMBER BECK: Yes.

4 MEMBER SONNABEND: Yes.

5 MEMBER FELDMAN: No.

6 MEMBER RICHARDSON: No.

7 MEMBER DICKSON: Yes.

8 MEMBER FOSTER: Yes. 

9 MEMBER WALKER: No.

10 MEMBER FULWIDER: Yes.

11 MEMBER AUSTIN: Yes.

12 MEMBER TAYLOR: No.

13 MEMBER MARAVELL: No.

14 MEMBER THICKE: No.

15 MEMBER BONDERA: No.

16 CHAIRMAN STONE: Chair votes no. 

17 MEMBER FELDMAN: Thank you. John,

18 we'll turn this over to you for IBA. Thank

19 you.

20 CHAIRMAN STONE: One second. That

21 was six yes and nine no, is that correct? Six

22 yes, nine no. The motion fails.
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1 MEMBER FELDMAN: Sorry, Mac. 

2 Okay, John. I was a little preemptive there. 

3 Thank you.

4 CHAIRMAN STONE: That would be

5 really the decisive/indecisive vote, wouldn't

6 it?

7 MEMBER FELDMAN: Yes.

8 (Laughter.)

9 MEMBER FOSTER: So we have next up

10 a petition material proposal, indole-3-butyric

11 acid, CAS No. 133-32-4. Going to be referring

12 to it as IBA from now on. 

13 We heard the summary before. I

14 think we'll go straight into the

15 classification motion, get us set up for any

16 discussion that might happen. 

17 I'd like to move to classify

18 indole-3-butyric acid, CAS No. 133-32-4, as

19 petitioned as synthetic. 

20 MEMBER BONDERA: I'll second that.

21 MEMBER FOSTER: Further discussion

22 on the classification motion? 
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1 Seeing none, we can proceed to

2 vote.

3 CHAIRMAN STONE: Thanks, John. 

4 We'll begin with Carmela.

5 MEMBER BECK: Yes.

6 MEMBER SONNABEND: Yes.

7 MEMBER FELDMAN: Yes.

8 MEMBER RICHARDSON: Yes.

9 MEMBER DICKSON: Yes.

10 MEMBER FOSTER: Yes. 

11 MEMBER WALKER: Yes.

12 MEMBER FULWIDER: Yes.

13 MEMBER AUSTIN: Yes.

14 MEMBER TAYLOR: Yes.

15 MEMBER MARAVELL: Yes.

16 MEMBER THICKE: Yes.

17 MEMBER BONDERA: Yes.

18 MEMBER FAVRE: Yes.

19 CHAIRMAN STONE: And yes. 

20 Unanimous 15-0 to approve.

21 MEMBER FOSTER: Next I'll make a

22 listing motion. I move to list indole-3-
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1 butyric acid, CAS No. 133-32-4, as petitioned

2 on 205.601 for the purpose of plant

3 propagation via dipping. Is there a second?

4 MEMBER AUSTIN: Second that.

5 MEMBER FOSTER: Thank you, Harold. 

6 Is there any further discussion on the listing

7 motion? Mac?

8 CHAIRMAN STONE: I'll just point

9 out, so now in plant stock rootings - can't

10 think of the term now -- but growers, if they

11 were to use this product, they could then use

12 it in planting stock that could become organic

13 a year later, I believe, because of the way

14 the regulation reads. So you couldn't use it

15 and sell the plant. You couldn't if it's an

16 annual or some of those types of things, but

17 it -- yes.

18 MEMBER FOSTER: More discussion or

19 comments on this? 

20 MEMBER FELDMAN: Just for the

21 record, could we explain the history on this? 

22 Would that be -- I guess it's in the written
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1 material, but it might be useful to --

2 MEMBER FOSTER: Sure. It was

3 petitioned first, I believe, in 2009. A prior

4 iteration of the Board, I believe, in 2011 

5 voted not to include it on the List. The

6 petitioner came back, narrowing the

7 application method. Also, pulling out some of

8 the finer details from the extensive

9 appendices in the first application, putting

10 some of those -- I believe not a whole lot of

11 new substantive information that wasn't in the

12 appendices, but made it more readily

13 available. That, along with the narrowed

14 application, got it back on our plate for

15 reconsideration.

16 With that, any more discussion or

17 comments?

18 I guess I'll just let it be known

19 that for four years I used this material; this

20 was about 15 years ago, as a plant propagator. 

21 So I don't know if past financial interest

22 counts here, but I assume not. I thought I'd
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1 get it out on the table.

2 Hearing no other comments, we'll

3 proceed to vote.

4 CHAIRMAN STONE: Voting begins

5 with Zea.

6 MEMBER SONNABEND: No.

7 MEMBER FELDMAN: No.

8 MEMBER RICHARDSON: No.

9 MEMBER DICKSON: No.

10 MEMBER FOSTER: Yes. 

11 MEMBER WALKER: No. 

12 MEMBER FULWIDER: No.

13 MEMBER AUSTIN: Yes.

14 MEMBER TAYLOR: No.

15 MEMBER MARAVELL: No.

16 MEMBER THICKE: No.

17 MEMBER BONDERA: No.

18 MEMBER FAVRE: No.

19 MEMBER BECK: Yes.

20 CHAIRMAN STONE: Chair votes no. 

21 That's 12 no, and 3 yes. Motion fails.

22 Thank you, John.
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1 Jay?

2 MEMBER FELDMAN: Thank you, Mac. 

3 I guess we'll return with tetracycline later. 

4 Thank you.

5 CHAIRMAN STONE: Right. So if my

6 memory serves me occasionally, I think we're

7 down to other ingredients and tetracycline. 

8 Is that the way the voting record looks?

9 So with that, I'd like to move

10 back to the other ingredient conversation that

11 several of us visited during lunch, got some

12 clarity to some of Nick's concerns and we had

13 -- I don't know if you all had some amended

14 language that you -- so what I'd like to do I

15 guess is let's get a motion and a second on

16 the table. If we make amendments to the

17 document, then it will be to approve as

18 amended when we get to the end of any changes. 

19 So we'll put, Michelle, the

20 original document up before we add Nick's

21 earlier OFPA criteria in that policy section. 

22 But I'll turn it back over to John.
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1 MEMBER FOSTER: So then I would

2 ask again, Zea, to kind of round us up, to

3 move us through the process.

4 MEMBER SONNABEND: Is the motion

5 we're putting on the table the revised

6 document that I presented this morning,

7 because those revisions have been approved by

8 the Subcommittee already? Okay.

9 So I move to adopt the other

10 ingredients -- oh, the ancillary substances

11 policy, formerly known as "other ingredients,"

12 as revised by the Handling Subcommittee and

13 presented.

14 MEMBER FOSTER: I'll second that.

15 CHAIRMAN STONE: So we can proceed

16 to vote?

17 MEMBER SONNABEND: Okay. So 

18 for --

19 CHAIRMAN STONE: Now for the

20 discussion.

21 MEMBER SONNABEND: In the way of

22 further discussion, I will start by saying the
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1 change that I heard us all agree to this

2 morning I believe was to -- moving down to

3 policy, the recommendation, policy and

4 procedure under policy, the first sentence to

5 read, "The NOSB intends to review other

6 ingredients found in substances on and

7 petitioned for the National List in accordance

8 with OFPA criteria." 

9 So I think we -- how do we proceed

10 then? If it's consensus we just keep going

11 with more amendments that are consensus? 

12 Okay. Then I do want to add one that we

13 didn't exactly talk about this morning but

14 that was sort of implied, which is: I would

15 like to change the title of the document to be

16 "Ancillary substances/other ingredients." 

17 (Laughter.)

18 MEMBER SONNABEND: Well, we want

19 to be consistent, don't we? Is there

20 consensus around that? Okay.

21 MEMBER MARAVELL: I would suggest

22 -- are we going to do one or the other? We're
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1 going to have two names for the same thing? 

2 I would suggest just doing one or the other.

3 MEMBER SONNABEND: Well, how about

4 other ingredients in parentheses instead of

5 hyphen? 

6 MEMBER MARAVELL: Fine.

7 MEMBER SONNABEND: Because people

8 have been recalling it that for so long, we

9 don't want to --

10 MEMBER MARAVELL: Right. That's

11 fine.

12 MEMBER SONNABEND: Okay.

13 MEMBER MARAVELL: Would the text

14 then reflect ancillary or --

15 MEMBER SONNABEND: Yes, and

16 because it's very cumbersome to make every

17 change in that regard now, if people will just

18 trust us for the final recommendation to try

19 and bring that language into consistency.

20 CHAIRMAN STONE: Or something like

21 that.

22 (Laughter.)
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1 MEMBER FOSTER: To make

2 consistent?

3 CHAIRMAN STONE: I'm okay with the

4 dual name in the title because the memo to the

5 Board was called other ingredients. 

6 MEMBER SONNABEND: Was called

7 other ingredients.

8 CHAIRMAN STONE: And we've changed

9 it, so this is the transition phase of that

10 name change.

11 MEMBER SONNABEND: Okay. So that

12 was the only consensus additional change I

13 heard this morning, and so if people have

14 other ones to propose now, the floor is open.

15 MEMBER FELDMAN: Okay. Yes, I

16 have a change in the first paragraph that I

17 think I can propose. 

18 MEMBER SONNABEND: The very first

19 paragraph?

20 MEMBER FELDMAN: Yes, the very

21 first paragraph. You heard a conversation

22 this morning about whether the law requires
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1 that other or auxiliary ingredients be

2 included on the National List, and I think the

3 broad answer to that is yes. And where we

4 have flexibility it appears is the form in

5 which it appears on the National List. So as

6 Lisa Brines explained, with inert ingredients

7 we're choosing to at least for the moment

8 discuss this things in group and presumably

9 that will lead to their listing in groups. I

10 don't know. I mean, that's one possibility.

11 So, and there are other groupings

12 on the List, as Miles pointed out. Excipients

13 I think was one, right? So I would propose

14 that part of the confusion is that people are

15 unsure as to what the intent here is, although

16 I think if you parse through the document you

17 might be able to find it. And you probably

18 will, but I think it's helpful to get it up

19 front.

20 So anyway, the first paragraph,

21 last sentence I would suggest should read --

22 I'll read the whole sentence starting with
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1 "Since" -- boy, that's a long sentence, Zea. 

2 "Since OFPA requires that each non3 agricultural ingredient be specifically listed

4 and because the National List does not

5 specifically list other ingredients commonly

6 found in formulated products, the NOP

7 identified the need for clarity and requested

8 that the NOSB develop a policy that specifies"

9 -- delete the words "whether these other

10 ingredients are allowed" -- that specifies

11 that all non-organic constituents of organic

12 foods be on the National List in some form."

13 MEMBER BONDERA: Can you reread

14 that, please?

15 MEMBER FELDMAN: Let's see, strike

16 the last one, two, three, four, five, six

17 words, "whether these other ingredients are

18 allowed," and say that "all allowed non19 organic constituents of organic foods be on

20 the National List in some form." Or maybe

21 "constituents" isn't the right word, but --

22 MEMBER MARAVELL: Could you repeat
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1 that one more time, Jay?

2 MEMBER FELDMAN: "That all allowed

3 non-organic constituents of organic foods be

4 on the National List in some form."

5 MEMBER BONDERA: Yes, Michelle,

6 you have to strike the "allowed on" and the

7 last six words. The final six words of your

8 -- yes, right there. The second time you say

9 "allowed," yes.

10 CHAIRMAN STONE: And just so those

11 in the audience know, we work very hard for

12 six months to avoid wordsmithing on the fly

13 like this. But I'm not saying it's not

14 necessary. I'm just saying that it's awkward. 

15 Nick?

16 MEMBER MARAVELL: Yes, I have no

17 objection to the word "constituents," but I

18 would just like to receive some input or

19 advice from the program or other members of

20 the Board if there is a better word to use

21 there.

22 CHAIRMAN STONE: No very strong
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1 feelings about it. Tracy?

2 MEMBER FAVRE: This seems a pretty

3 dramatic change from what the intent of what

4 this document was. And I'm a little

5 uncomfortable making this decision or this

6 change on the fly --

7 MEMBER FELDMAN: Yes.

8 MEMBER FAVRE: -- because if I was

9 reading this in a vacuum, I would make the

10 assumption that all the ancillary substances

11 would somehow end up being listed individually

12 on the List, or it could be interpreted that

13 way, and that's not the intent of this

14 document.

15 MEMBER SONNABEND: Miles, could

16 you explain what you explained at lunch to

17 Tracy?

18 MR. McEVOY: Yes. Well, we're

19 just trying to see what we said in 2011, and

20 it seems like it's missing a couple of things

21 there because we did identify the need for

22 clarity and requested that the NOSB develop a
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1 policy on this. We can't allow things that

2 are not allowed in the regulation. And so

3 it's clear in terms of other ingredients and

4 crop production; for instance, inert

5 ingredients, they're listed. They're on the

6 National List. The same for in livestock. 

7 There's the excipients. They're on the

8 National List. 

9 So we do need clarity in the

10 regulation in terms of how these ancillary

11 substances -- what do we call them now --

12 ancillary substances are listed in the

13 National List. So this seems like it could

14 work. It does spell out what the intent of

15 the proposal is, is that it clarifies what

16 ancillary substances are allowed and which one

17 are not. And you'd go through a process to do

18 that and they have to be on the List in some

19 form or another in order for us and certifiers

20 and businesses to know what ancillary

21 substances are allowed and which one are not.

22 MEMBER BONDERA: And I think my
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1 understanding is that we, the NOSB, don't know

2 what form that's going to take and that's why

3 that "in some form" makes sense, because we

4 don't know how they'll be listed as groups or

5 whatever. But if they aren't there, like you

6 said, they can't be dealt with. So that's at

7 least my understanding.

8 MEMBER SONNABEND: There are a

9 number of forms that this could take that do

10 not necessarily mean each individual substance

11 appears on the List. For instance, in crops

12 inputs there's one clause on the National List

13 that says "and inert ingredients not of

14 toxicological concern." So it could be a

15 parallel construction to that at its most

16 general. It could just say, a clause, "an

17 ancillary substance as identified in

18 guidance." Or it could be item-by-item

19 annotated by class, like all carriers, all

20 preservatives -- you know, by class. Or in

21 some cases it could be individual. But it

22 leaves it open, until the Department can come
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1 back to us with any further clarification and

2 until we start our review and see what comes

3 up in the course of review.

4 CHAIRMAN STONE: I think it

5 doesn't tie our hands too much to see what

6 form these things come in. I appreciate your

7 concern. I don't think it overly constricts

8 the Program and us to work together to figure

9 out what form this monster is going to look

10 like as we go forward.

11 I have a clarification question, a

12 procedural rookie chair question, I guess. So

13 I like because this group gets along well and

14 respects each other's time and we can have

15 conversation, but do we need to state -- have

16 people be called on for the record so we know

17 who is saying what, or is that captured

18 automatically somehow? It might look like

19 Tracy had said all of that discussion.

20 So let's go ahead while they're

21 getting back to that. That's just for clarity

22 later in the transcript. So any further
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1 discussion here? I think we're okay on this

2 language. Jay?

3 MEMBER FELDMAN: Okay. And then

4 as I discussed this morning, I think it would

5 be helpful since we are treading in -- well,

6 a lot of you know a lot about this area, but

7 for some of us in waters that are sort of like

8 net pens in the ocean. Sorry about that. 

9 When we talk about baseline criteria and other

10 ingredients, I really think we do need to put

11 a clause in there "as defined below but not

12 limited to." And that's under baseline. And

13 where we have those lists of categories, I

14 think they're well-intentioned lists, but we

15 may be missing something.

16 Oh, God, you think I can do that? 

17 Where's baseline? Well, I don't have the page

18 number because I've edited this so much, but

19 it says, "The baseline criteria are as

20 follows: Other ingredients." And then

21 there's (1) and (2) and then (3) and (4). So

22 "are as follows, but not limited to," and then
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1 we would have the list.

2 MEMBER SONNABEND: Are you sure

3 you want to say that, because already it's

4 everything that's possibly allowed in food in

5 the United States?

6 MEMBER FELDMAN: Well, is it?

7 MEMBER SONNABEND: Yes, that's

8 what EFIS is.

9 MEMBER FELDMAN: See, that's why I

10 prefaced my comment.

11 CHAIRMAN STONE: So just so you

12 all know, Tony the transcriptionist, he is

13 clued in partly by microphone position, but he

14 knows our names and he knows our voices by

15 now, so he can capture that kind of

16 conversation. I like that it can be a little

17 less formal since so far in this conversation

18 we're doing well of not arguing across the

19 table with dueling microphones. So thank you

20 all for that. And it allows for a little

21 cleaner and faster conversation, a little less

22 formal conversation.
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1 So, Zea?

2 MEMBER SONNABEND: So you're

3 withdrawing that change, right, Jay?

4 MEMBER FELDMAN: Okay.

5 MEMBER SONNABEND: Other suggested

6 changes?

7 (No audible response.)

8 MEMBER SONNABEND: Does that mean

9 we're ready to vote?

10 MEMBER FELDMAN: Yes.

11 MEMBER SONNABEND: Yes? Awesome. 

12 Nick, you're ready to vote?

13 MEMBER MARAVELL: Yes.

14 CHAIRMAN STONE: Going once, going

15 twice.

16 MEMBER MARAVELL: Am I ready to

17 vote, Mr. Chair?

18 CHAIRMAN STONE: Yes, I believe

19 you are.

20 MEMBER MARAVELL: Okay.

21 MEMBER FELDMAN: I just want to

22 say that I hope that there's some openness to
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1 tweaking this document as we move along,

2 because as we dig into this we may find that

3 we are limiting ourselves. But I think the

4 intent is clear. If we follow the National

5 List criteria and the compliance with OFPA, I

6 think that's what important here. How we go

7 about generating the list and so forth is

8 going to be an ongoing process, I hope. Hope

9 we're not setting this in stone.

10 CHAIRMAN STONE: I'll suggest

11 that, yes, we're -- Program asked us to help

12 figure it out. We will be very much a work in

13 progress with the Program, but I'm sure

14 they're going to kick a lot of this back to us

15 and consider our capabilities of time and

16 expertise and they'll have theirs. And it

17 will take a little while to flesh this out and

18 I'd like to be sure that the record reflects

19 how much energy and time this Board has put

20 into getting this document in an effort to

21 further refine and clarify the product that

22 carries the seal on behalf of the public
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1 confidence.

2 And I'll ask --

3 MEMBER SONNABEND: Point of order,

4 Mac? Sorry.

5 CHAIRMAN STONE: Oh, yes, ma'am?

6 MEMBER SONNABEND: I'm just not

7 sure, you know, the parliamentarian could say,

8 are we then supposed to vote on the amendments

9 suggested now as amendments and then add them

10 to the whole motion, or is it just one vote?

11 CHAIRMAN STONE: Well, if you

12 hadn't interrupted me, I was going to get to

13 that.

14 MEMBER SONNABEND: What?

15 CHAIRMAN STONE: If you hadn't

16 interrupted, I was just getting to that.

17 MEMBER SONNABEND: Okay. Sorry.

18 (Laughter.)

19 CHAIRMAN STONE: So if Zea or

20 Harold that made the motion and seconded see

21 these as friendly amendments, say yes for the

22 record.
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1 MEMBER SONNABEND: Yes.

2 MEMBER AUSTIN: Yes.

3 CHAIRMAN STONE: So having that

4 being accepted as friendly amendments, we can

5 now vote on the motion. Any further

6 discussion?

7 Very good. So the voting will

8 start with Jay.

9 MEMBER FELDMAN: Yes. 

10 MEMBER RICHARDSON: Yes.

11 MEMBER DICKSON: Yes.

12 MEMBER FOSTER: Yes. 

13 MEMBER WALKER: Yes. 

14 MEMBER FULWIDER: Yes.

15 MEMBER AUSTIN: Yes.

16 MEMBER TAYLOR: Yes.

17 MEMBER MARAVELL: Yes.

18 MEMBER THICKE: Yes.

19 MEMBER BONDERA: Yes.

20 MEMBER FAVRE: Yes.

21 MEMBER BECK: Yes.

22 MEMBER SONNABEND: Yes.
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1 CHAIRMAN STONE: Yes. Unanimous

2 yes. Very good. Very good. Thank you all

3 very much. But don't feel too good about it

4 because look what we got to do now? 

5 (Laughter.)

6 CHAIRMAN STONE: Okay. Seeing the

7 time, the agenda, I know everyone in the

8 audience has been sort of like when are we

9 going to get to it? We're going to get to it,

10 the tetracycline conversation, right after a

11 15-minute break. It's 2:30. We'll come back

12 at 2:45. Thank you.

13 (Whereupon, the above-entitled

14 matter went off the record at 2:26 p.m. and

15 resumed at 2:44 p.m.)

16 CHAIRMAN STONE: I'll call the

17 meeting back to order. Appreciate everyone's

18 interest. Appreciate those in the audience

19 that have stayed with us the entire week. I

20 hope you can see and hear and feel the

21 anxiety, the decision that we're about to make

22 one way or the other. I know some people will
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1 be glad or excited, but fully realize there's

2 people sitting next to you that may be upset,

3 whichever way this thing goes. So we hope

4 that in one way or the other we're advancing

5 the organic seal, the integrity of organics,

6 short term and long term. But I just thought

7 about it at a break there, that remember

8 there's people that could be hurt by this

9 whichever way it goes. So just remember that.

10 Okay. Jay, I guess at this point

11 we'll ask for a motion and a second to get the

12 conversation started.

13 MEMBER FELDMAN: Thank you, Mac. 

14 I'm going to turn this over to Harold to

15 manage this because he has been carrying the

16 majority position and leading the Subcommittee

17 on this. 

18 We've already had all our

19 disclosures on this, so we're all set to go. 

20 Thank you, Harold.

21 MEMBER AUSTIN: Okay. Michelle is

22 going to throw this up on the screen.
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1 Based off of the oral comments and

2 testimonies that we heard yesterday, the Crop

3 Subcommittee has met and we're going to come

4 forward with a little bit of an alternative

5 motion compared to the one that we had

6 originally listed, a little bit of an

7 inclusion taking some commentary out of this

8 interest position that Lynn presented to us

9 yesterday. Trying to put this motion as we

10 move it forward, because this is a very

11 difficult issue with a lot of stakeholders on

12 every side of this equation being held in the

13 balance. So we're trying to bring something

14 forward that may be just a little bit more

15 balanced from the original proposal. 

16 The new motion as adopted by the

17 Crops Subcommittee recommends amending the

18 listing for tetracycline to remove the

19 expiration date of October 21st, 2014 and add

20 the following annotation: "205.601, Synthetic

21 Substances Allowed for the Use in Organic

22 Production as a Plant Disease Control. 
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1 Tetracycline for fire blight control in apples

2 and pears only until October 21st, 2016. 

3 Tetracycline may be used if the grower has

4 implemented an integrated system of practices

5 and materials to control fire blight. Orchard

6 management systems must demonstrate an annual

7 increase in the extent or number of the

8 alternative practices for managing fire

9 blight."

10 That's the motion.

11 CHAIRMAN STONE: Is there a

12 second?

13 MEMBER MARAVELL: I'll second, or

14 I'll make the -- are you making the motion 

15 or --

16 MEMBER AUSTIN: I'll go ahead and

17 make it as stated.

18 MEMBER MARAVELL: Okay. And I

19 will second.

20 MEMBER AUSTIN: Thank you, Nick. 

21 Mr. Chair?

22 CHAIRMAN STONE: Thinking about
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1 this a little bit as we enter this discussion

2 phase, a lot has been said over the last few

3 days, last few years around this conversation. 

4 Specifically to the Board, I would suggest

5 that we discuss it openly and people can speak

6 their views. And then at some point I'm going

7 to call time and each of us will go around the

8 table and just each of us will have a few

9 minutes -- we won't use a stop watch/stop

10 light, but each of us have a few minutes to go

11 around, and others that may not be comfortable

12 entering the fray, if you will. And once we

13 get through that round, there may be a few

14 closing remarks. But we could go back and

15 forth on this for a long time and not change

16 very much. So I just suggest we have that

17 process. And I'm thinking -- I'm not going to

18 say a time, but the -- okay. Thank you.

19 MEMBER AUSTIN: Okay. We have a

20 motion and we have a second. We'd like to

21 open it up for discussion at this time. Are

22 there questions or comment from the Board?
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1 (No audible response.)

2 MEMBER AUSTIN: Seriously?

3 (Laughter.)

4 MEMBER AUSTIN: Let me do that

5 again.

6 MEMBER SONNABEND: Well, I'm

7 confused because Mac said we'll talk about it

8 and then we'll go around. And so I don't know

9 whether to talk about it or wait until we go

10 around.

11 CHAIRMAN STONE: I guess I made a

12 presumption that there would be some start,

13 but maybe we've discussed it. Maybe we do

14 just go around. I just don't want to go back

15 and forth and back and forth and back and

16 forth. And so maybe we are ready to go

17 around. Why don't you start? Go for it.

18 MEMBER SONNABEND: Okay. The

19 majority position, you know, and I hope really

20 both positions in this issue feel a lot of

21 compassion and concern for the other side of

22 the issue, even if we are on one side of the
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1 issue. This is a hardship for everybody. 

2 It's no doubt about it, no matter which way we

3 go, as Mac said, it's going to be a hardship

4 for some group of people.

5 So those of us in proposing to

6 have an extension, because we feel that it is

7 so vital for the growers to be able to

8 transition out of this material in a way that

9 is feasible for their livelihoods, want to do

10 so in a way that it creates the most

11 definitive statement that we can possibly make

12 to consumers that this really is the end of

13 the material and acknowledging the concerns

14 that consumers have about the effect on human

15 health and the environment.

16 Well, I'll save the rest for my

17 wrap up. But this is the reason that we

18 modified our first motion, because we were

19 told by the interest people in the room that

20 acknowledging the concerns as some consumers

21 as far as definitive oversight and definitive

22 quantification of alternative practices would
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1 help appease their concerns. Even though some

2 people on the Board and some people off the

3 Board think this is already covered in the

4 law, we're absolutely willing to say it again

5 if it helps ease anybody's concern. And so

6 that's how the new motion is crafted.

7 MEMBER AUSTIN: Nick?

8 MEMBER MARAVELL: Yes, I'd like to

9 ask a point of clarification. We have a

10 resolution in addition to this, and my

11 understanding is regardless of which way the

12 vote goes on the listing motion, that we will

13 also vote on the resolution. The resolution

14 will be amended slightly because some of what

15 was in the resolution is now in the listing

16 motion. 

17 Am I correct in assuming that

18 there will be a second vote on the resolution,

19 which basically says we're phasing this out

20 and we're asking for research priority? So

21 there will be a second vote? Okay.

22 MEMBER AUSTIN: Right, I just
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1 wasn't going to bring it up until after the

2 first vote had taken place.

3 Questions? Comments? Nick?

4 MEMBER MARAVELL: Well, I'd like

5 to comment on this basically from a producer

6 perspective, because that's the stakeholder

7 group that I represent. 

8 You've heard quite a bit of this

9 before, but I think that I don't see this as

10 a majority and minority position. I see us

11 all on the same page. We attempted in Seattle

12 to start a process, and I think it's a process

13 we can be proud of. And we have come together

14 as a group. 

15 So I think we need to consider

16 what a farmer is thinking. We've worked with

17 the research community; I have for over three

18 decades, and I understand that certain things

19 just don't get worked out the way they do at

20 the research station. And also understand

21 that going forward we have nothing but

22 extremes in our weather outlook. We're being
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1 whipsawed from hottest to coldest, from driest

2 to wettest. There is no such thing as a

3 normal year anymore.

4 My concern is that this could be a

5 win for everyone because some of us got into

6 organic production because we believed that we

7 could have an impact on the larger agriculture

8 in this country. My hope here is that if we

9 were to follow the advice that we're getting

10 from the research community, which is that

11 we're on an edge here of transitioning out of

12 antibiotic control for fire blight -- we've

13 got little bumps in the road here in terms of

14 speed, registration of products, getting

15 established field trials up and running,

16 getting farmers to accept this. 

17 And as you can hear from farmers

18 who have worked with the research community

19 the past who testified with us, there are

20 always things that come up that are

21 unanticipated and you have to have that

22 ability to gather some real-time on-the-ground
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1 experience, particularly in this case when

2 you're dealing with a biological control agent

3 that needs to be handled very carefully, needs

4 to be applied according to very strict

5 protocols. And it's not easy. I mean I have

6 worked with biological control agents with the

7 research community over the years. Things

8 that work in the experimental stations or in

9 the lab sometimes fall flat.

10 Now what I'm suggesting in my mind

11 is that if we take the time necessary to

12 introduce this with the maximum chances for

13 success, we will have validated a process

14 where everybody can come together. And guess

15 what, this could be adopted by the much larger

16 tree fruit industry. And the consumers who

17 are saying they don't like antibiotics in

18 organic tree fruit can then say we don't want

19 them in any apples or pears. 

20 If we make the sledding go pretty

21 rough, it's not going to take well in the

22 producer community. It's not going to be as
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1 successful. It's not going to be perceived as

2 an accommodating type of entry whereby

3 innovative practices are being introduced in

4 a positive manner. 

5 So for those reasons, the

6 Subcommittee tried to balance all of these

7 concerns. And we have one proposal before us

8 which I feel balances those concerns, but it

9 doesn't balance them in the way that everyone

10 would like to see. I don't see in my mind any

11 division between what we're calling the

12 majority and the minority on this issue. I

13 see, you know, 24 months of difference, and

14 that's it. That's my statement.

15 MEMBER AUSTIN: Thank you, Nick. 

16 Colehour?

17 MEMBER BONDERA: Okay. Thank you,

18 Nick. I'm not really sure where to start, but

19 I'll try anyway.

20 You know, I kind of want to

21 respond personally at some level because you

22 and I, Nick, started on the National Organic
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1 Standards Board at the same time, the same

2 meeting in Seattle, facing this same topic. 

3 And I remember quite clearly; and I'm sure

4 many people that are sitting here were in the

5 room at that time, we went to what I consider

6 -- and this is personal, I understand, but for

7 me it was a compromise, suggestion and process

8 that ended up getting voted through. It

9 wasn't one way or another. And I think that

10 that is probably how this topic can get dealt

11 with, is if the players want to compromise,

12 which means nobody's going to get everything

13 they want. That's what the word "compromise"

14 means. 

15 And I feel that if you decide,

16 okay, let's figure out a compromise that we

17 can all work with, then that's one approach. 

18 But if the approach is black or white, either

19 or, has to do this, has to do that, it makes

20 it very hard to get everybody that's affected

21 or involved to be working together and

22 strategizing together to come up with
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1 something that they can accept and that they

2 can work with. 

3 And I think I feel that, you know,

4 in dialogue directly with you you've stated,

5 you know, we came with that compromise that it

6 would go until 2014 to make sure that things

7 have started to move along. And I feel

8 uncomfortable saying, okay, well things have

9 started to move along and therefore let's let

10 them move along further the same as they're

11 moving along. It's like since they've moved

12 along, my personal approach to life is, okay,

13 so let's figure out how to channel them

14 further down the path that we were identifying

15 that we wanted to do.

16 In this particular case we're

17 speaking of tetracycline exclusively. At that

18 point in time we were talking about

19 tetracycline and streptomycin. And I think in

20 today's meeting we were talking about another

21 antibiotic, and people were trying to even

22 open the doors wider. So I think that we're
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1 realistically not exactly having the same

2 conversation we had then, but it makes me feel

3 like, you know, are we talking about guiding

4 ourselves down a path and it's getting

5 narrower and we're trying to reach a

6 conclusion, or are we talking about extending

7 the same thing further? 

8 And I think those are two very

9 different approaches, honestly and frankly. 

10 And to be frank and honest and open with the

11 people in the room, we've had discussions

12 about, okay, what are some of those options? 

13 And I think that from my perspective some of

14 the options that are starting to be thought

15 about related to can we consider, you know,

16 looking at the emergency option, because --

17 and I don't know. 

18 I don't grow apples and pears and

19 I don't know -- and I could give you pretty

20 detailed personal experience on growing

21 coffee, which is also a perennial, and we had

22 the varroa mite come in -- not the varroa
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1 mite. That's honey. When we had CBB come in

2 and there was nothing to work with and nowhere

3 to go, you know, we had to go to the state --

4 they had to go to the Federal Government to

5 get guess what, Beauveria bassiana to be

6 allowed to be used to control the CBB. And

7 that was super hard work and everybody was

8 freaked about it for a long period of time,

9 like almost a year. And we had all these

10 special meetings at the state level with the

11 State Department of Ag and everybody else,

12 because I think that people do get concerned. 

13 And I understand quite personally,

14 quite directly how farmers -- you know there's

15 not a clear answer. And if you don't know

16 what the answer is, people get very worried

17 and wearied about these processes. But

18 specifically on this topic I think that we

19 have to -- well, I mean I won't be so specific

20 quite yet. I'll come back around, because I

21 think like in that case the CBB was in one

22 area of the Kona coffee region and it wasn't
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1 in the other areas. 

2 So a huge percentage of people had

3 zero problem with it. And I think that, you

4 know, then we're talking about a very small

5 segment, and so it's very easy to start

6 talking about that. And I think with this

7 whole topic with tetracycline we're not

8 talking about a very big percentage of the

9 apple and pear farmers that are certified

10 organic. We are not. We're talking about a

11 single-digit percentage. 

12 So I think that we just have to

13 make sure that we're talking about what we're

14 really looking at and not sort of trying to

15 make out for the worst case scenario, like

16 everyone's going to lose all of their Kona

17 coffee tomorrow if we don't find an answer. 

18 Well, that's true, but we're going to have to

19 work through the process. 

20 And I think that my feeling at

21 this point in time with this topic is, you

22 know, if we're not willing to work through a
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1 process and we're just going to stand firm in

2 certain conclusions, then I myself don't see

3 that I'm feeling like we're working that

4 carefully together. And I think whether or

5 not I can feel in my heart as an organic

6 farmer with organic integrity that I am

7 representing not just farmers, but the whole

8 organic community, when I try to speak about

9 it. So I need to be careful.

10 And I don't mean this to be a

11 response directly to you, Nick, but I'm

12 following what you said, and I think it's true

13 that now we need to make sure that we are as

14 a group, the 15 of us, coming up with a

15 solution that we all can feel comfortable with

16 and that we work with. And that's my personal

17 desire and goal, and I hope that we all want

18 to do that and can and will do that, because

19 I think that -- you know, I'll just wrap up by

20 saying, you know, as not just a small scale

21 farmer, but I direct market all my products

22 and, you know, losing 40 percent of my income
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1 because coffee disappeared like that was not,

2 you know, something I was seeking or wanting. 

3 And I can completely understand that, but I

4 can also completely understand, you know,

5 having to directly sell to the consumers, you

6 know, being able to talk to them and/or having

7 to not tell certain truths. So I think that

8 we need to be very careful, is my feeling. 

9 And so I think I hope that other people have

10 some things to say that will bring us

11 together, because that's what I would like. 

12 Like you said, let's all be together, and

13 that's what I'd like.

14 MEMBER AUSTIN: One of the things

15 that I'd like to point out is that as we sit

16 as a Board and we are trying to weigh the

17 balance for all stakeholders, this isn't just

18 about tree fruit. This is about all

19 stakeholders because this will impact a lot of

20 people and a lot of lives. This Board, eight

21 of the members sitting at these tables right

22 now sat in Seattle, as you said, Colehour. 
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1 There was an annotation made at that time to

2 extend that expiration date. I was in

3 Seattle. I heard you guys loud and clear, as

4 well as the rest of the industry did. The

5 challenge that you put forth with the

6 annotation to the industry, the stakeholder

7 group, the orchardists, was to go forward and

8 show us that you could make progress. 

9 The comments made at that time

10 were that we haven't seen that attitude. We

11 haven't seen you make that attempt. Go forth. 

12 We're going to give you to 2014. You come

13 back showing us that you can make some

14 progress and then we will take this

15 conversation back up again. That's exactly

16 what has happened. You know, Ken Johnson, you

17 know, immediately after the Seattle meeting,

18 you know, the Organic Tree Fruit Working Group

19 was put together from individuals across the

20 country. Ken Johnson got an OREI research

21 grant and started working on alternatives.

22 Prior to 2008 the volume of
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1 production in organic tree fruit was nothing

2 to compare to what it is today. When those

3 numbers were so small, no government agency

4 wanted to put forth the type of dollars for

5 the research money that would go forward to

6 take and help the researchers and the growers

7 try to find alternatives solutions to this

8 problem. It wasn't big enough of an issue. 

9 The chemical manufacturers would not put the

10 money forward because there was no money in it

11 for them. 

12 Now there's volume. Now there's

13 acreage. For the organic community as a whole

14 we've known grown to a point where we have

15 adequate access on all different fronts,

16 whether it's at farmers' markets, whether it's

17 sell from your farm to your clients, your

18 customers, your consumers, or whether we're

19 into the main chain source now. We can all

20 take pride in where we've been able to grow

21 together as an organic community, organic

22 today as it stands. 
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1 To stand here and make the

2 commitment to those organic stakeholders in

3 2011 that that Board made and to turn our

4 backs on the challenges and the promises made

5 to those guys would be a travesty. It's a

6 disrespect to the organic integrity, to the

7 organic integrity of this Board itself and to

8 the stakeholders. We've got the same issue in

9 front of us in 2016 with banana growers and

10 rotenone. The same type of annotation was

11 made to them. Go forth. We're going to give

12 you to this date. Come back. Show us that

13 you've made progress and we'll take the issue

14 back up. 

15 So if we're going to make these

16 promises to organic stakeholders, we've got to

17 take and have enough moxie to stand up, be the

18 type of people, show the integrity as an NOSB

19 that our organic stakeholders and community

20 can be proud of and that we as individuals can

21 be proud. 

22 It's not that the organic tree
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1 farmers, the pear and apple growers, don't

2 hear the consumer concerns. They hear it very

3 loud and clear. David Granatstein brought

4 test results on residues yesterday showing

5 seven different samples that were taken at

6 harvest time with zero detect, applications of

7 one to five applications of oxytetracycline. 

8 You know, maybe we can take and send forth a

9 resolution or a demand that the growers start

10 to take more physical results. You know, pull

11 some samples two weeks prior to harvest. 

12 Let's start taking and helping and ensure and

13 build the consumer confidence and trust back

14 in what organic stands for. 

15 This isn't about trying to take

16 and pull something over the eye of the

17 consumer. We all appreciate the consumer,

18 because if it wasn't for the consumer, the

19 organic farmers wouldn't be in existence

20 today. The flip side of it, it wasn't for the

21 organic farmer, the consumer wouldn't have the

22 access to organic products that are available
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1 today compared to where they were 10 years

2 ago.

3 Further comments? Questions? 

4 (No audible response.)

5 MEMBER AUSTIN: Nothing? Really? 

6 Come on, guys. Jay, you got to have

7 something.

8 (Laughter.)

9 MEMBER FELDMAN: I was waiting. 

10 MEMBER AUSTIN: Okay. You're

11 waiting for the go-around? Okay. Mac, you

12 know, I don't think we're getting enough

13 commentary as we thought we might. You know,

14 I guess it looks like we might be ready to do

15 the around the room. 

16 CHAIRMAN STONE: Okay. I'll be

17 glad to start. I think I have the similar

18 emotion that I saw and heard in Nick's voice. 

19 I think as a farmer and a direct marketer of

20 organic products, and the conversations that

21 I have, and looking people in the eye when

22 they ask why should I buy your organic kale or
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1 your organic chicken, and I explain to them

2 the differences. And they don't understand

3 all of the farming practices and all of the

4 angst playing God with a hurt animal and

5 deciding how to treat that animal or work with

6 that animal. 

7 So without going off the deep end,

8 I think that we've heard that the growers feel

9 very much they need this tool. We know that

10 the growers that are organic thinkers will

11 avoid this material as much as they can,

12 whether it's pragmatic expense. But they

13 know. I would sense that these growers are

14 not just happy, but proud if they don't have

15 to use this material. But the end of the day,

16 I have reservations that we let retail dictate

17 farm policy because Mother Nature in a great

18 way dictates farm policy.

19 I'm going to support this vote to

20 extend to this because I think the growers

21 need this tool. Because this is a farm policy

22 problem and it has a public perception issue,
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1 but it's a farm/Mother Nature policy that the

2 farmers are dealing with.

3 MEMBER WALKER: I would like to

4 begin by saying that this vote is a very

5 difficult vote. Dr. Mildred Smalley, the

6 Vice-Chancellor for Research at Southern

7 University, she said, "Research, if you know

8 the outcome, it is not research." My issue is

9 that even 2016, it appears to me as a

10 researcher, a teacher, more time would

11 probably still be needed. 

12 USDA every years requests

13 scientists at the 1890 Land-Grant

14 Institutions, the 1862 Institutions on

15 accountability and adaptability. USDA is

16 concerned about what can we do to get

17 stakeholders to adapt our practices, that they

18 give us these thousands, sometimes millions of

19 dollars worth of grant money. The difficulty

20 that we have found, I can say in the State of

21 Louisiana and maybe in other states as well,

22 is that even if the science is there, getting
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1 stakeholders to adapt it is also even a longer

2 and a slower slug. 

3 With that in mind, I would like to

4 say what Colehour had said and I had mentioned

5 when were dealing with animal welfare, a

6 consensus is a situation where at the end of

7 the day some will be happy and some will be

8 pissed off. But I'm reminded of the three

9 words of Nike: Just do it. So we are at a

10 point in time that we have to do what we have

11 to do. 

12 And I was appointed by Secretary

13 Vilsack to articulate the constituent group in

14 which he appointed me, and that was to be a

15 consumer and a public advocate. And based

16 upon that, I line up behind the consumers and

17 the public interests what I have heard,

18 although how difficult it is, is very

19 difficult. Because I would love to see the

20 extension to 2016, 2018, but I just don't

21 believe that even then it's enough time. 

22 So I would like to say that I
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1 think in the end that the organic community

2 will be ever stronger and better for whatever

3 the decision that we make.

4 MEMBER FULWIDER: I want to talk

5 first about what I've heard from consumers and

6 then what I have heard from producers. 

7 With the consumers there's been a

8 range of those who want complete prohibition

9 of antibiotics, and there is also those who

10 support their local producers working toward

11 eliminating antibiotic use. And we've heard

12 testimony at this and at past meetings that

13 children are willing to eat tasty apples, but

14 not necessarily the one that come from

15 disease-resistant varieties. From producers,

16 not all of the producers are requesting

17 antibiotic use. They don't all need it, and

18 those who do are using it sparingly. 

19 I would like to see the university

20 research completed to support the producers in

21 the effort to eliminate antibiotics. 

22 Livestock producers in the organic industry
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1 are required to use antibiotics to relieve

2 animal suffering. Those treated animals are

3 allowed to live out their lives. They get to

4 go to another farm and the farmers do not

5 necessarily have a financial loss because they

6 can move those animals at the going

7 conventional rate. 

8 Orchardists do not have this

9 option. They can't pick up the tree and sell

10 it to their conventional neighbor. And I

11 would much prefer to live next door to an

12 organic orchard that's using antibiotics

13 occasionally under the supervision and

14 oversight of their certifier than to live next

15 to a conventional orchard. 

16 MEMBER AUSTIN: Anybody else? 

17 Just go around the room now?

18 CHAIRMAN STONE: Yes.

19 MEMBER AUSTIN: Want me to go? 

20 Why don't I pass it over to Jennifer and we'll

21 just come back. Jennifer?

22 MEMBER TAYLOR: I think that the
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1 Board, this Board with a lot of the

2 conversation that may support any kind of

3 resolution that does not adhere to the

4 previous board's recommendation to withdraw in

5 2014 -- I think that that hinders the progress

6 of the farming population, as well as it

7 doesn't benefit the consumers either. And I

8 think that the thought of the previous Boards

9 have not been reflected and won't be reflected

10 if we continue this process of moving the

11 date. And I think that I would have to

12 represent my role as an advocate for the

13 consumer, the public interest, and I would

14 actually revert back to the 2014 deadline.

15 MEMBER MARAVELL: I would just

16 like to acknowledge what Colehour said, that

17 there's a very small percentage of antibiotic

18 use on organic farms, and that's a testament

19 to the ingenuity and commitment of organic

20 farmers. But I would like to point out at the

21 same time that there is fire blight pathogen

22 on virtually every orchard in the United
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1 States and if the conditions are right; and

2 that may only happen once every 5 or 10 years,

3 that that -- you don't know. It's like

4 Russian roulette. You don't know if you're

5 going to get it. The research community may

6 eventually come up with a field test so that

7 you could verify in time, but we're not there

8 yet.

9 And so, Calvin, yes, there will

10 always be a need for research. Well, you need

11 job security.

12 (Laughter.)

13 MEMBER MARAVELL: But I think on

14 balance, you know, getting that research into

15 practical hands is what this resolution, the

16 Committee resolution as currently proposed

17 would do. 

18 MEMBER THICKE: Well, I would

19 first say that I was really impressed with all

20 the people speaking on this issue that on both

21 sides was very heartfelt. Everybody believed

22 strongly in what they were talking about. So
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1 there is really no bad position on this in

2 some way.

3 Myself, I have the

4 environmentalist position. I'm also a

5 producer. So I look at both sides. Actually

6 I would prefer more of a compromised position. 

7 And I may be speaking out of school, but if

8 this proposal fails, there will perhaps be

9 another one that's more of a compromise that

10 would allow an amnesty for three years,

11 meaning if a producer had to use antibiotic,

12 the crop could not be sold that year as

13 organic, but they would remain certified. And

14 since it seems like maybe only once every five

15 years is when they have to spray, the

16 likelihood of having to spray is not real high

17 and they have a relief valve, another

18 opportunity. So I think that's the way we

19 really need to go because it's kind of an

20 amnesty. 

21 On the other side, the NOSB has

22 been, because of maybe the turnover, has been
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1 saying over and over we're going to end this. 

2 And then new Board Members come on and then

3 we're going to end this. So that's more of an

4 amnesia-kind of a program, is that we just

5 keep on forgetting what we said we're going to

6 do and then we say we're going to do it again. 

7 And I really can't support that.

8 And from my experience with the

9 field trip, we saw three producers and two of

10 them were very committed and they didn't spray

11 that often. And I am quite certain that the

12 small producers -- and they have a local

13 market that they would be able to make this

14 work. And so I will not support extending to

15 2016.

16 MEMBER BONDERA: I mean I feel a

17 little uncomfortable. I feel like I already

18 said a few words. I mean the only thing I

19 could add to anything that's gone in my mind

20 since we've talked and I guess from the

21 perspective of some of what you all said, I

22 really frankly and honestly and in my heart do
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1 not feel this is an either/or kind of

2 discussion. I do not feel it's a both

3 discussion. 

4 I really feel like the approach

5 that I at least carry and from my experience

6 dealing with other people who are producers

7 carry, they're not -- producers aren't looking

8 for the bottom line of money. What they're

9 carrying, organic producers are carrying is a

10 different world view of understanding how

11 things work. And you can't only factor in,

12 well, the consumer perspective, well, the

13 farmer perspective, you know, which one are

14 you going to choose? Well, in this case, like

15 in this room at this table you have to

16 acknowledge the fact that the environmental

17 perspective is equally represented, and has to

18 be. And so you're already up to three even if

19 you only count that portion of the people. 

20 And so I think for me when we're

21 talking about looking at it, the critical

22 thing is really to make sure we're looking at
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1 the whole picture of what is involved and

2 what's affected and making sure that we're

3 thinking about those issues. So not only does

4 the fruit carry that whatever we're going to

5 call it, contamination or whatever -- so you

6 have that product and you're eating it, but,

7 okay, is it on the leaves? Okay. Is it going

8 to be there later in the soil? And we're

9 talking about soil health. And we're talking

10 about a lot of broader issues, you know, water

11 and things like that. 

12 So I think we need to make sure

13 we're considering all of those factors and not

14 one component. And that's how I look at and

15 think about organics as a farmer. So I think

16 that that's all I'll add. Thank you.

17 MEMBER FAVRE: For my part this

18 has been a very difficult decision. I don't

19 know if it's a blessing or a curse that I was

20 not on the Board when some of those earlier

21 decisions were made. It would be very easy to

22 wish that previous boards had taken this
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1 decision off of our plate so that we didn't

2 have to make this decision.

3 But having said that, I think that

4 the difficulty in this is that we've been

5 dealing with in some cases people that have

6 been getting sound bites of information

7 converted to black and white issues when this

8 is a very nuanced issue with shades of gray

9 answers. And I've said this multiple times in

10 our conversations, if these problems were easy

11 to be solved, they would have been solved

12 already. So it's important for us to not make

13 a decision based on not having the full

14 picture. 

15 I also think it's possible that

16 the farmers that would be impacted would feel

17 that this was a fairly capricious decision on

18 our parts when there's finally progress being

19 made. So from my perspective, I would like to

20 have the research completed. I would like to

21 give the farmers the time to have the tools in

22 place so that we aren't potentially
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1 devastating their operations. And let's be

2 very clear: These are individuals with

3 families and livelihoods that are looking at

4 being potentially significantly damaged either

5 in the short term or permanently based on

6 these decisions. 

7 MEMBER BECK: So I had to prepare

8 a statement. I'm going to read it, because

9 otherwise I'll get nervous. I also feel like

10 this is very -- it has me nervous, very

11 nervous because so many people's interests are

12 at stake here. So I'll go ahead and just

13 read.

14 So I respect and acknowledge the

15 concerns of all who will be impacted by this

16 proposal. I'll state that I am unequivocally

17 in favor of an extension until 2017 at the

18 earliest. However, in an attempt to

19 compromise I'm in favor of voting for the

20 revised and annotated centrist proposal with

21 a 2016 expiration date. This proposal was

22 revised to take into account the very real
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1 concerns of both consumers and farmers alike. 

2 And as others have indicated, we have a real

3 opportunity today to pass a proposal that is

4 relatively acceptable to all who are members

5 of this organic community.

6 The arguments that have resonated

7 with me over the past few days include some of

8 the following: The U.S. domestic organic

9 apple and pear industry must be preserved. 

10 We're talking about farmers' livelihoods who

11 have been following their OSPs and have been

12 in compliance with the National Organic

13 Program. The conversion of organic acres back

14 to conventional acreage is for me, and for

15 many probably could be quite heart wrenching. 

16 And honestly, to shrink the organic industry

17 to me would be a real shame. I also feel that

18 the arguments that fact-based expiration dates

19 based upon the availability and outcome of

20 research must be proposed. The tendency to

21 propose arbitrary expiration dates for the

22 sake of compromise has not been a good
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1 practice. 

2 Also the work of the current

3 research is very promising and I commend the

4 progress that's been made. I wholeheartedly

5 feel that the researchers should be provided

6 the adequate amount of time needed to complete

7 their studies and to allow the time for

8 growers to learn about and adopt these

9 alternatives.

10 And lastly, I feel that there is

11 an opportunity to better educate consumers so

12 that, as Tracy was saying and others, they

13 have the holistic picture of both sides of --

14 or the whole story. And I think that in many

15 instances it feels that there's just an

16 opportunity there for them to know the

17 entirety of the issues that are on the table. 

18 And so that's what I've got for

19 you all. Thank you.

20 MEMBER SONNABEND: Thank you. 

21 Well, we here as Board Members have listened

22 over the last three days, and for some of us
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1 much longer than that, to everyone's concerns

2 on this issue. And we all agree, as was

3 stated at the outset, that really every one is

4 appointed to this Board to try and make the

5 organic community better and try and make the

6 organic community grow from whatever way we

7 feel is appropriate.

8 The consumers in the room feel

9 understandably concerned about their food and

10 feel that efforts to remove this from the list

11 have been stalled several times. I think

12 antibiotics potentially has some real reasons

13 to be concerned for, and it goes beyond what

14 the science says or doesn't say and into just

15 what people feel in their hearts about this

16 going forward. Growers feel dis-empowered

17 from this process because of being closed out

18 from commenting entirely in 2008 and feel like

19 they weren't heard in 2011. 

20 I think that really both growers

21 and consumers are the victims here. They're

22 the victims of a system that doesn't
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1 prioritize organic research and development of

2 alternative products and the victims of just

3 not having political power to be able to force

4 these through our government/corporate system. 

5 In 2011, a statement was made for

6 growers and consumers to work together towards

7 the ending the use of this material. Since

8 that date this has happened with some success. 

9 In the grower community we're committed to

10 following the trajectory that we're on towards

11 tools for everyone to have success with

12 alternative control measures, but we're not

13 there yet. For pears in the Western U.S., for

14 apples in the Midwest and East, and certain

15 microclimates that are different than the ones

16 the materials have been tested in already.

17 Key products are not even

18 registered yet and will not be by 2014

19 expiration. Therefore, the grower community

20 feels that we need to have the extension so

21 that growers and consumers of organic fruit

22 can reach together towards an end use of this
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1 material. Any steps we can take to achieve an

2 extension and reassure consumers at the same

3 time we are willing to take. This is the

4 reason for adopting some of the centrist

5 annotation language into our proposal. 

6 As I said yesterday and will say

7 again clearly, that with two more years this

8 will be the end of it. Disruption to people's

9 orchards and livelihoods is too depressing for

10 me to contemplate. After spending my entire

11 career on having sound and sensible rules for

12 organic consumers and farmers alike, I just

13 cant see that ripping their organic orchards

14 out, period, or converting back to

15 conventional is appropriate at this time. So

16 therefore I am going to support the proposed

17 motion for an extension.

18 MEMBER FELDMAN: Thanks for

19 calling on me earlier, Harold. I don't have

20 a prepared statement and I'm not even sure

21 what more I can add to the discussion. I

22 wanted to give you more of a sense of how I
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1 personally come to where I am on this. 

2 You know, I see, and I'm sure you

3 all see similarly in your own decision making

4 process, you sort of -- I approach this on

5 different levels. I approach this from a

6 science perspective, science and policy

7 perspective, I approach this as an advocate

8 representing constituents who like many of you

9 have mentioned, and I approach this as a

10 parent of children that grew up in an organic

11 household. 

12 You know, the first thing that I

13 do usually when I am confronted with these --

14 really all of them are difficult decisions;

15 this one is particularly difficult -- is start

16 with the science. And when we first got on

17 the Board, our class, we didn't have the

18 technical reviews that we have today. We were

19 doing a little scrounging around for our own

20 research, and John was sending us down rabbit

21 holes, and other people had their own charts

22 of how to get information. And at one point
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1 we had six rabbit holes lined up that we would

2 sort of follow. 

3 And we didn't even know where the

4 historical records were on the decisions that

5 had preceded us. And we all labored over

6 that, but we yearned for information and it

7 started with what had happened before, what

8 had previous boards done, what was the

9 substance around those discussions, what did

10 the science say, and then where is the new

11 science on this? And, you know, I know that

12 doesn't help when you're in an immediate

13 crisis, because a lot of crises, as I've

14 experienced working on the conventional side,

15 are born out of decisions that keep going and

16 going and going and never stop. The crisis is

17 quite predicable, but it's identified as an

18 emergency and unpredictable. 

19 And we see a lot of this crop

20 resistance where conventional monocultures

21 result in resistance that is very predicable. 

22 But some people wake up and say, oh, I had no
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1 idea my crop was going to fail and I don't

2 have a pesticide I can use and I need to be

3 able to use an unregistered -- or a chemical,

4 one that's not registered for this use.

5 So I say all this because you

6 never know when you're at the right spot to

7 make a decision. You can't know it while

8 you're in it. And I find that over and over

9 again and I tend -- some of the people I

10 represent say I'm too flexible, though I know

11 you guys wouldn't see it that way. 

12 You know, and so the question

13 really is how do you really feel comfortable

14 with the decision you make after having been

15 in a conversation, tracking the history of the

16 Board on this issue for so many years? Even

17 before 2008, you know, the original Board

18 grappled with this.

19 As an advocate, as you all do in

20 your different groups you represent, you have

21 to sort of look at where the people are that

22 you're representing, and everybody I think is
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1 doing a good job of doing that. And, you

2 know, that was built into the statute. The

3 statute really forces us to communicate with

4 each other so that we can try to find a way to

5 do what others have said, grow the industry,

6 grow organic agriculture.

7 And so we do the best we can to

8 explain the viewpoint of the people that we

9 represent. And on the public interest side we

10 search around for bringing science into this

11 discussion, because we know the need is there

12 and we know the people that rely on materials

13 can express themselves and need to defend what

14 they do and their livelihoods and their

15 families and so forth. But we have to balance

16 that with the science. So I'm really pleased

17 to see in this last meeting in Providence and

18 now in this meeting we have the benefit of

19 bringing in people steeped in the science who

20 can help us make these tough decisions. 

21 And I think on the issue of

22 antibiotics, it's one that I really didn't
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1 expect the level of concern when I first dug

2 into this. I figured this was a small use, 

3 that this -- you know, we had taken care of

4 animal agriculture. The medical community was

5 concerned about, you know, therapeutic uses,

6 clinical uses. How could this really make

7 that much of a difference? And I was sort of

8 shocked to learn the level of concern when I

9 spoke to about a dozen physicians before

10 someone referred me to Dr. Morris.

11 So the science -- and I'm not

12 going to obviously go through the science --

13 but the science I think is clear. The

14 advocacy and the positions that people take in

15 the environmental community is really often

16 unpopular, historically. I mean, Nick, you

17 referred to climate change and, you know,

18 environmentalists took a lot of abuse in

19 raising climate change in many years, earlier,

20 you know, that their models were no good and

21 this and that, whatever. We took a lot of

22 abuse in advocating organic agriculture in the
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1 '80s. 

2 And so, you know, that need to

3 stay in touch with the people that are

4 supportive of organic, buying organic,

5 consumers, environmentalists that are making

6 the case for organic growth, why it's so

7 important and all these arenas from, you know,

8 trying to protect against global climate

9 change, drought resistance, protection of

10 soil, health, water, air, food, et cetera.

11 So in many ways my constituents

12 are really shareholders of the organic

13 industry. They're shareholders and they're

14 investors. And you know how mad shareholders

15 can get sometimes, right, if you don't deliver

16 the goods. You know, and investors want to

17 see the entities they invest in do the right

18 thing, or make money, or do something. But

19 they have a stake, they have a stake in

20 certain things happening and they're not

21 disconnected from what they have a share in or

22 what they have an investment in. 
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1 And I'm seeing, you know, as I

2 travel around the country, I talk to people

3 everyday on the phone from around the country,

4 that that stake that people feel in organic is

5 very strong. And so there is this element of

6 feeling that, either from their own ignorance

7 or for whatever reason, that they don't have

8 the right information or they were misled on

9 this particular ingredient.

10 Now, as a parent, you know, when

11 you raise kids in an environment with organic,

12 you have a lot of discussions with your spouse

13 about whether it's worth the investment,

14 especially if they're not coming out of an

15 environmental background. And so you have not

16 only abuse at work from people beating up on

17 you, you have the abuse of your constituents

18 who don't feel you're hanging tough enough. 

19 Then you go home in the evening and you have

20 to argue for putting a high percentage of your

21 family budget into purchasing organic food. 

22 So I've been abused up and down the line here. 
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1 It's a good thing.

2 But I do have a lot of agreement

3 with my wife about how important it was and is

4 to raise our kids with organic, but I'll tell

5 you funny story. And, you know, they know all

6 the reasons why that go well beyond what they

7 put in their mouth. They understand I started

8 out working on organic because I was mostly

9 concerned about farm workers and farm worker

10 exposure to pesticides in the fields and that

11 we could reduce our reliance on chemicals in

12 the workplace and protect workers. And, yes,

13 we could protest consumers, but that wasn't

14 ultimately -- at least originally my concern. 

15 And so my kids went out on their

16 own. They went to college. They got their

17 own places. And I get a call one day from --

18 I forget whether it was my son or daughter --

19 and my daughter goes, dad, I just got back

20 from the store and I was standing over the

21 dairy case and I couldn't believe it, butter

22 was $5 a pound organic and there was butter
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1 sitting right next to it was half the price. 

2 I said what did you do? Oh, I bought the

3 organic, but I can't believe I had to pay that

4 much for it. 

5 But the important thing is that I

6 want you guys to understand, and I think you

7 do, that the investment that people have in

8 what you guys do as growers is incredibly deep

9 and even young people like that can understand

10 that they have to dig deeper in their pockets

11 to support this. So we on the flip side might

12 need to do things that aren't easy, aren't the

13 things we would rather do, but we believe we

14 need to do to retain that trust and support

15 among the people that in the past generation

16 and the next generation will support organic

17 production. 

18 So with that, I apologize to any

19 harm that may be caused by my vote. That is

20 not the intent. I believe that in the end I

21 pray and believe that we will work through

22 this, at the same time that I feel deeply that
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1 this is a necessary step to protect people's

2 trust and faith in organic production as we

3 move forward. Thanks.

4 MEMBER RICHARDSON: This is tough,

5 you know, and I really respect all of the

6 comments that have gone before me. So

7 passionate. Zea, I love what you said.

8 So let me be clear for the record

9 that I have not read or heard any scientific

10 peer-reviewed evidence that persuades me that

11 there are residues of oxytetracycline in or on

12 organic apples and pears, and I'll continue to

13 eat U.S. organic fruit.

14 I urge, at the same time, residue

15 testing on harvested fruit as soon as we can,

16 this year starting, to refute the inaccurate

17 and misleading information that presently is

18 in the media and on the internet. However,

19 consumers assume that there are no antibiotics

20 used in organic agriculture and the ongoing

21 use of this antibiotic obviously undermines

22 consumer confidence in the integrity of the
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1 U.S. organic label, especially, as I say, in

2 the face of all the recent media frenzy filled

3 as it is with half-truths and inaccuracies. 

4 You can tell that makes me mad.

5 As a scientist, I understand that

6 research takes many years to provide results. 

7 Indeed, it may be years before we have a clear

8 understanding of the efficacy of new products

9 for controlling fire blight, especially in the

10 face of climate change. And therefore, if we

11 pass this, I expect that continued extensions

12 for use of oxytetracycline may be requested

13 because many will wait to make changes in

14 their agricultural practices and won't make

15 the changes in their agricultural practices

16 until they're really pushed to do so. That's

17 been my experience in agriculture over the

18 last 30 years. 

19 Meanwhile, antibiotic use is not

20 permitted in European or Canadian organic

21 apple and pear production. In the broader

22 context -- and it's important to look at this
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1 -- tetracyclines are critically valuable in

2 world public health and the low-level, sub3 therapeutic intermittent application of

4 antibiotics in production of apples and pears,

5 whether conventional agriculture or organic

6 agriculture, poses a serious health risk for

7 development of bacterial resistance to this

8 important antibiotic, and its use in fire

9 blight control should be rapidly phased out if

10 we're to continue to use this class of broad11 spectrum antibiotics for human health.

12 I recognize that my vote against

13 this recommendation will have serious economic

14 impacts on many hard-working farmers, and I'm

15 sorry about that. 

16 MEMBER DICKSON: I've been coming

17 to these meetings since 2004, and you know,

18 this is obviously a board that only works on

19 complicated, gray, difficult issues, and I

20 think this is the hardest one I've ever seen

21 and thought about. And, you know, I want to

22 start out by saying that I'm completely
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1 humbled to have seen so much openmindedness

2 and willingness to engage and argue and open

3 our minds in hallways and at dinners and in

4 this room and at this podium and, you know,

5 the candor and the courage, frankly, has been

6 amazing. 

7 As the retailer on this Board I

8 have approached this issue from several

9 different perspectives, but at the end of the

10 day, one where, you know, I've talked to both

11 a lot of shoppers and customers and the people

12 who deal with them directly, and I've talked

13 directly with a lot of growers and the people

14 who buy products from those growers. And as

15 a retailer we consider both our customers and

16 our growers and our suppliers to be

17 stakeholders in our business. And in an ideal

18 world we make decisions that satisfy both of

19 those groups and help them grow together and

20 add value to the organic supply chain. 

21 You know, my phone started ringing

22 on this issue months and months ago. Our
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1 buyers out in California and Washington and

2 the Upper Midwest and the Northeast have all

3 heard from their growers that are at serious

4 risk. And our customers who've heard other

5 messages are frankly and correctly shocked

6 that antibiotics are part of organic

7 production. That is, you know, a really big

8 disappointment for any customer who hears

9 about this issue. That's not a question.

10 You know, in deliberating on this

11 issue as a company, the only way we could even

12 feel comfortable explaining to our customers

13 that we would support an extension on the use

14 of tetracycline is if we could say there is a

15 concrete hard-dated end time for this and this

16 is not going to happen again, that there is,

17 you know, 24 extra months that are there for

18 a very specific reason, and after that we

19 cannot support any extended use of this

20 material. 

21 Sometimes that's a satisfactory

22 explanation. A lot of people do, you know,
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1 just like within this Board -- none of those

2 conversations are black and white. None of

3 them are simple. We all stood in orchards on

4 Monday morning and talked to growers who were

5 showing us their blocks of trees that had been

6 eviscerated by fire blight. You know, I don't

7 know if anyone on the Board talked to the

8 barista across the street this morning, but he

9 was really worked up about this issue. And,

10 you know, so was my mom and so are our

11 neighbors and our families and our friends. 

12 And they're hard conversations, just like the

13 one we're having right now.

14 Like I said, I believe the use of

15 antibiotics in livestock or in terrestrial

16 agriculture is not consistent with consumer

17 expectations of organic agriculture, and I

18 think we all agree on that. Antibiotic

19 resistance is a real problem and one of the

20 reasons that we should ensure that antibiotics

21 are not part of organic agriculture. However,

22 consumers and our stakeholders expect this
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1 Board to make a decision that carefully

2 balances the needs and expectations of many

3 different stakeholders, consumers, retailers,

4 growers, certifiers, the environment. 

5 And in this case, you know, the

6 question is not whether to ban antibiotics

7 from tree fruit production. The question is

8 when and how, and can we give the growers a

9 bridge that, you know, balances the very clear

10 right thing to do and expectations of

11 consumers with the survival of those growers. 

12 And, you know, I don't necessarily have

13 anything dramatic or new to add to the

14 conversation, but just to say that this has

15 been excruciatingly difficult to process for

16 everyone here, and I do plan to vote yes on

17 this proposal. 

18 MEMBER FOSTER: So I remember that

19 first year, too, Jay. And as I remember it,

20 I just was mapping the rabbit holes. And then

21 we all went down them together, for better or

22 for worse. But I'm glad you mentioned that,
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1 because it reminded me of those early days,

2 which shocks me to say because it seems like

3 just eons ago already, and I know it was just

4 a couple of years ago. 

5 But I still feel so fortunate to

6 be part of the process. And as I've said many

7 times in these meetings in the last few years,

8 I feel endlessly privileged to be part of the

9 process, as agonizing as it is sometimes for

10 a whole bunch of reasons. But even today I'm

11 just in awe of our collective wisdom and

12 relative civility. It's very meaningful to

13 me.

14 So I'm really glad to see what I

15 think of as really robust, promising,

16 inevitable progress toward removing

17 tetracycline off the List entirely, and I

18 think we're really close. No surprise, I'll

19 be voting in favor of the extension proposal. 

20 I think that that progress has been genuine

21 and heartfelt and sincere, and I think we owe

22 the growers that are part of our community
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1 that institutional good faith that we've shown

2 other parts of our other constituencies in the

3 past.

4 I know, you know, as a group or as

5 individuals, we/us as individuals, there's

6 going to be criticism, and that's kind of --

7 we all kind of signed up for that. And it's

8 not the first time. Won't be the last. None

9 of us like it, but no matter which way it

10 goes, that's part of the deal. 

11 What can I say other than the Dude

12 abides.

13 (Laughter.)

14 MEMBER FOSTER: Obviously a lot of

15 facets here, a lot of interested parties. And

16 it's as it should be. That's our process,

17 albeit if it's imperfect. As most of you

18 know, I'm generally not compelled by kind of

19 reductionist or extremist arguments. They

20 just don't hold a lot of truck for me, of any

21 stripe, either side, but especially those that

22 appear to be designed to kind of cloud things
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1 over. I don't care for that. Yes, I don't

2 care for the intent. I don't know, it's just

3 not compelling to me, so I tend not to put a

4 lot of water in that bucket.

5 Those on the Board who have been

6 on conference calls on Crops or Handling the

7 last few years have heard me say that, you

8 know, materials like this -- this is a good

9 example -- used very sparingly, strategically

10 and then only in the context of a very

11 thoroughly vetted organic system plan, system

12 of inspection, verification, reinspection, and

13 that verified OSP and 205, 206 -- all those

14 cascading requirements for pest management, I

15 think, is in the context of a very solid

16 regulatory system that I have faith in.

17 Again, not surprisingly, I don't

18 want to lose that context. I think that's an

19 essential context. And when we talk about

20 materials in Subcommittee, or in a larger

21 context like this, I think we forget that they

22 exist outside of a vacuum, and I want to keep
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1 driving that point home. I think that's a

2 very important point. 

3 I've heard a lot of kind of word

4 choices and syntax that seem to drive us away

5 from the critical question. They're driving

6 us toward implication. And as one of my good

7 friends used to say, innuendo and out the

8 other. 

9 (Laughter.)

10 MEMBER FOSTER: And I would much

11 rather just hear direct answers to direct

12 questions. That would be much more helpful

13 for me in the future. 

14 So since the proposed use

15 extension, it doesn't feel to me to be really

16 based in developing science, really, or even

17 method. It's I think a derivative of

18 compromise. I really anticipate, predict, if

19 you want to call it that, that the existing

20 2014 deadline is going to fall far short of

21 what's going to be required to register, test,

22 implement, distribute, manufacture, all those
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1 things. That commercialization process is not

2 going to be there for these alternatives, I

3 don't think. I'd be happy to be proven wrong. 

4 I really would be. I just don't see it. 

5 That's not my experience in the past.

6 I share some others on the Board's

7 opinion. I don't know that 2016 is enough,

8 but it could be. I'm willing to move the ball

9 a little bit farther if it needs to be. I

10 think we're close and I'd like to see that.

11 I think the vagaries, variability

12 of the crops, the plant pathogens at hand --

13 I don't think the existing deadline allows a

14 realistic commercial scaling. It seems more

15 than wishful thinking to me. It seems

16 fantastic in the truest sense of the word. 

17 Remote from reality I think is one definition. 

18 It doesn't feel realistic to me. 

19 I think a lot of the resistance

20 concerns can be very serious. I believe those

21 have been sufficiently addressed by the

22 science we have heard. That's my opinion. It
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1 doesn't sound to me like an additional two

2 years would cause anything but -- and I had to

3 write this part down -- an unlikely

4 possibility of unlikely transfer of something

5 that is unlikely to exist more than a few days

6 every few years in any given relevant

7 environment. There's a lot of things that can

8 happen. The world's an imperfect place. 

9 Things are going to happen. 

10 It doesn't sound to me like this

11 is worth the penalty that a significant

12 portion of our own community has been counting

13 on for a while, and I think we're so close. 

14 I just don't see penalizing that cohort, that

15 part of us, with certain undue burden and

16 hardships because of a chance of a chance of

17 a chance of a concern, especially not when we

18 are so -- I do think we are really close, and

19 to remove the concern entirely. 

20 And as others have pointed out,

21 not just from the organic community, but if

22 these work in organics, we have lots of
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1 empirical evidence in the most dyed-in-the2 wool conventional environments, like the

3 valley I'm used to growing in. We've got a

4 lot of experience that the benefits of organic

5 reach far beyond organic ground. And this

6 could be another great example of that, that

7 as we develop these tools for organic, the

8 rest of conventional agriculture can move a

9 little bit closer to us. That's what I really

10 like about this.

11 I know we are all working to

12 remove the materials completely. We all agree

13 on that. We're really close. And it's in

14 this context -- and context is critical to the

15 decision -- that this extension makes

16 reasonable process and it makes reasonable

17 sense. So I plan on supporting it. Thank

18 you.

19 MEMBER AUSTIN: Okay. I'll wrap

20 us up and then I guess then we'll take it to

21 a vote. As all of you in the audience could

22 hear, there's a lot of passion from the 15
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1 members of this Board. Everybody is voting

2 with their heart. Everybody is talking with

3 their stakeholders at their best interest. I

4 think the science came from two different

5 directions and I think there was compelling

6 evidence to displace some of the concerns, I

7 think both from Dr. Stockwell's presentation

8 -- I also think from the residue sampling that

9 Granatstein was able to take and provide for

10 us yesterday. 

11 I think the point that we're

12 missing is that the organic growers right now

13 -- this is not a carte blanche use. Not every

14 organic acre of apples and pears is getting

15 treated. Those that need the treatment are

16 the ones getting treated. And as has been

17 pointed out, it's pretty minuscule, but yet it

18 could have a serious impact to handlers, to

19 producers, to processors, wholesalers,

20 retailers and ultimately the consumer. I hear

21 the concerns with those that have to represent

22 the consumers. 
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1 There's been a lot of things going

2 on in the news that have got the consumers

3 scared. They've got them wondering about the

4 safety of their food, but has anybody shared

5 with them the information that Dr. Granatstein

6 just provided to us yesterday, that out of

7 seven samples there was zero detectable

8 residues? The one stat that was used was what

9 the development of the standards by the EPA,

10 which is totally different than what any

11 industry will use to sample residues on a

12 normal basis, would be. And that's misleading

13 and it's not based on what I feel is the way

14 we should be presenting the information.

15 I also think when it comes those

16 that have to take and stand up and protect the

17 rights and the concerns of the consumers have

18 to vote with their conscience and with their

19 stakeholders. I think the one opportunity

20 that we have that we're missing is that by

21 denying the ability to move forward, by

22 denying the opportunity to increase the
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1 residue sampling, by showing that the concerns

2 -- maybe are real -- maybe they're not as

3 large of a concern as they're being made out

4 to be. And I'm not going to sit here and say

5 either way. I'm just making the statement

6 that there's an opportunity. 

7 I think the opportunity is for us

8 as collective organics stakeholders --

9 shareholders, I think, Jay, is the word that

10 you used -- I think all of our shareholders or

11 stakeholders have a place at the table. They

12 all have an invested interest in this process. 

13 They all have an invested interest of where we

14 have brought the organic industry today from

15 where it was 10 years ago, 20 years ago, 30

16 years ago. These growers have put a lot of

17 blood, sweat and tears into this. They're up

18 in the middle of the night frost-protecting

19 their crops this time of the year. They're

20 out in the middle of the winter. When you're

21 sitting in your nice warm rooms, offices,

22 businesses, they're out in the cold freezing
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1 their butts off taking and pruning, protecting

2 their crops, doing the things that need to be

3 done in order to protect the trees, prune the

4 trees. It's a way of life for them.

5 This isn't just about taking and

6 putting something out that maybe it's right,

7 maybe it's wrong. It's a way of life for

8 them. They're doing this because they're

9 passionate about it, just as each of you in

10 this room are passionate about what you do.

11 The final thing I want to say is I

12 think if we don't move this forward we're

13 going to miss an opportunity for the organic

14 communities from all fronts to come to the

15 middle to find balance. If we don't find

16 balance, we're turning our backs on the very

17 essence of what the organic principles stand

18 for. 

19 The final point to state is I'm

20 proud to be sitting on this Board as a

21 handler's rep listening to everybody's

22 passion. But even further, I'm proud to be a
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1 member of one of the truest, the purest

2 environmental groups in this country, and that

3 is the American farmer. Not just the American

4 farmer, but the organic farmer, because the

5 organic farmers are passionate about what they

6 do. They have to depend on that life, on that

7 soil, the land, for their living. Are they

8 going to intentionally go out there and do

9 something that's going to destroy that ground? 

10 Hell no. They're not. They're going to

11 protect it with every fiber in their body. 

12 You know, and I'm sorry, but I'm

13 starting to get a little bit passionate, and

14 I apologize. But it's an issue. And we're

15 going to disrupt people's livelihoods if we

16 vote and vote this measure down. I will vote

17 for it, and I'm going to vote for it not on

18 behalf of the grower, not on behalf of the

19 apple and the pear people. I'm going to vote

20 for it on behalf of the organic community,

21 because it's the right thing to do. 

22 Any further discussion?
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1 (No audible response.)

2 MEMBER AUSTIN: Mr. Chair, I think

3 we're ready to vote.

4 CHAIRMAN STONE: Well, I want to

5 thank all of you all. I know that those of

6 you in the room could feel what just happened

7 here. So we'll go for a vote. Jean, we start

8 with you.

9 MEMBER RICHARDSON: No.

10 MEMBER DICKSON: Yes.

11 MEMBER FOSTER: Yes. 

12 CHAIRMAN STONE: And let's go slow

13 to make sure we get this one right.

14 MEMBER WALKER: No.

15 MEMBER FULWIDER: Yes.

16 MEMBER AUSTIN: Yes.

17 MEMBER TAYLOR: No.

18 MEMBER MARAVELL: Yes.

19 MEMBER THICKE: No.

20 MEMBER BONDERA: No.

21 MEMBER FAVRE: Yes.

22 MEMBER BECK: Yes.
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1 MEMBER SONNABEND: Yes.

2 MEMBER FELDMAN: No.

3 CHAIRMAN STONE: Yes. 

4 Six no, nine yes. Motion fails. 

5 Jay?

6 MEMBER FELDMAN: I'd like to

7 introduce a motion, if that's okay -- and I

8 think Michelle has it -- on tetracycline. I'm

9 sorry. I just need a minute here. Sorry, I

10 lost it.

11 Why don't we go to the resolution

12 first? Sorry. I'll be prepared for this. 

13 Zea has a resolution that follows on the

14 previous motion.

15 MEMBER SONNABEND: Yes, we

16 proposed a resolution along with our original

17 motion, and I am looking for it. Okay. Even

18 though the motion for extension fails, I feel

19 like we need to have some resolution to

20 indicate the need for high priority for

21 research still. And so I would like to put

22 forward the amended motion that I circulated
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1 to everybody. It says, "The National Organic

2 Standards Board is committed to the phase-out

3 of this material. In addition, the Board

4 strongly advocates to USDA a high priority for

5 increased support for research into the

6 alternative practices and materials." It

7 really should say "for control of fire

8 blight."

9 Is there a second?

10 MEMBER BONDERA: Second.

11 MEMBER RICHARDSON: Second.

12 CHAIRMAN STONE: Discussion? 

13 Sorry, Nick?

14 MEMBER MARAVELL: Yes, just

15 because we sort of changed the context a

16 little bit, we may want to say, "The National

17 Organic Standards Board is committed to the

18 phase-out of either tetracycline or

19 antibiotics in organic practice," whichever --

20 you know, we just sort of "this material." I

21 mean, it may be sufficient, it may not be.

22 MEMBER SONNABEND: That's true. I
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1 guess there's no motion to precede it that

2 passed, so I guess we would say phase-out of

3 tetracycline. I accept that as a friendly

4 amendment. Does the second, whoever seconded

5 it?

6 MEMBER BONDERA: Yes.

7 MEMBER SONNABEND: Okay. 

8 MS. ARSENAULT: Zea, instead of

9 "this material" you want to insert

10 "tetracycline?"

11 MEMBER SONNABEND: Yes, instead of

12 "this material" in the first sentence.

13 MEMBER FELDMAN: Do you want to

14 ask for the vote?

15 MEMBER SONNABEND: Well, I thought

16 Mac was supposed to ask for the vote, but I

17 think --

18 CHAIRMAN STONE: Sorry. I was

19 making sure Michelle spelled it right while

20 everybody's watching. 

21 Any further discussion?

22 Okay. We'll call for the vote,
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1 and we start with Joe.

2 MEMBER DICKSON: Yes.

3 MEMBER FOSTER: Yes. 

4 MEMBER WALKER: Yes.

5 MEMBER FULWIDER: Yes.

6 MEMBER AUSTIN: Yes.

7 MEMBER TAYLOR: Yes.

8 MEMBER MARAVELL: Yes.

9 MEMBER THICKE: Yes.

10 MEMBER BONDERA: Yes.

11 MEMBER FAVRE: Yes.

12 MEMBER BECK: Yes.

13 MEMBER SONNABEND: Yes.

14 MEMBER FELDMAN: Yes.

15 MEMBER RICHARDSON: Yes.

16 CHAIRMAN STONE: Yes. 

17 Vote is unanimous.

18 MEMBER FELDMAN: Okay. Mr. Chair,

19 sorry for this, but that was the appropriate

20 order. I'd like to introduce a motion and

21 then we can have a discussion on this. You

22 should all have an emailed copy of this, and
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1 we have it up on the screen as well.

2 This is tetracycline for use on

3 fire blight in apples and pears. I won't read

4 all of this, but I'll read portions of it. 

5 And if you'd like to make any amendments to

6 it, we can discuss this.

7 "But the Crop Subcommittee

8 proposes to let the tetracycline listing of

9 205.601 expire and recommends that the NOP

10 declare an emergency program for fire blight

11 control in apples and pears running from

12 October 21, 2014 to October 21, 2017. 

13 "In order to minimize potentially

14 devastating loss of trees during the period

15 that growers believe is necessary to make the

16 transition, the NOSB recommends that the NOP

17 facilitate use of emergency provisions of the

18 Organic Foods Production Act."

19 And then we explain in here the

20 legal authority under 7 CFR 205.672, "when a

21 prohibited substance is applied to a certified

22 operation due to a federal or state emergency
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1 pest or disease treatment program and the

2 certified operation otherwise meets the

3 requirements of this part, the certification

4 status of the operation shall not be affected

5 as a result of the application of the

6 prohibited substance, provided that any

7 harvested crop or plant part to be harvested

8 that has contact with a prohibited substance

9 applied as a result of the federal or state

10 emergency pest or disease treatment program

11 cannot be sold labeled or represented as

12 organically produced." 

13 So the motion is, "without any

14 change to the NOP rule and without extending

15 the 2014 expiration date of tetracycline on

16 the National List, the NOSB advises the

17 Secretary to create a national emergency

18 disease treatment program for fire blight

19 control in organically certified apples and

20 pears authorizing the use of oxytetracycline

21 until October 21, 2017, in accordance with

22 205.672 and 7 U.S.C. 6518(k)(6).
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1 "The NOSB advises the Secretary

2 that such a program will require a certified

3 farm to document to its accredited certifier

4 that non-antibiotic control methods had

5 already been employed, that conditions

6 indicate the need for treatment, such as

7 predictive disease outbreak on models based on

8 temperature and moisture conditions and the

9 stage of growth of the full trees or extreme

10 weather conditions, the date and locations of

11 the trees sprayed with oxytetracycline, and

12 the procedures to prevent commingling of any

13 resulting non-organic harvested product with

14 certified product. 

15 "If growers use tetracycline

16 during this period, they will not be able to

17 sell the treated crop as organic, but they

18 will not lose their certification if the

19 certifier finds they have implemented an

20 organic systems plan."

21 And then there's a recommendation

22 to the NOP on guidance on alternative
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1 practices that fit into several categories.

2 I'm not going to read them all. And this

3 comes partially out of the centrist proposal. 

4 "Implement a systems-based approach that

5 integrates prevention, monitoring and control

6 of fire blight, monitoring techniques, control

7 techniques, steps to address long-term

8 strategies, monitoring of the orchard for fire

9 blight to determine if it is likely to become

10 a threat to the orchard, and informing of the

11 certifier about antibiotic applications."

12 So that is the motion and I'm

13 looking for a second on that.

14 MEMBER RICHARDSON: I'll second

15 that.

16 MEMBER FELDMAN: Discussion? 

17 Thank you. Go ahead.

18 MEMBER SONNABEND: If no one

19 raises their hand, I guess I start. I have

20 mixed feelings about adopting such a motion. 

21 And while conceptually I would like the

22 emergency way out for the growers who feel it
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1 would help them, I am completely opposed to

2 this very prescriptive and detailed guidance,

3 stuff that's in here because this was never

4 vetted to any of the organic community except

5 for those in the centrist know. And it's

6 completely inappropriate for what we're

7 dealing with in California where we're dealing

8 with a lot of other problems that have to do

9 with balancing scab treatments with these

10 treatments and completely unrealistic

11 suggestions about bloom thinning, which

12 doesn't apply California, etcetera. 

13 So I just really can't go for this

14 very prescriptive language. And I would want

15 to hear from the NOP whether they really feel

16 guidance is necessary at all, because you do

17 cover this in your points within the upper

18 part of the motion, one, two, three and four.

19 MEMBER FELDMAN: Right.

20 MR. McEVOY: Well, this is a very

21 new proposal here. We haven't had time to sit

22 and analyze it. So if it passed, we'd have to
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1 take a look at it and get back to you, because

2 there's a lot of information in here and a lot

3 of new concepts that we'd have to have

4 reviewed by staff, including legal staff.

5 CHAIRMAN STONE: I talked to

6 Brenda about this a little bit and the

7 certifiers can manage this. The committed

8 growers, they've got some source separation

9 for EU compliance that they're sort of working

10 through, which is brand new for them this year

11 I guess, as well last year. So it's doable. 

12 It's burdensome, but you heard how committed

13 they are to their growers and they work to

14 great lengths. I should have said during the

15 other ingredients discussion how much work

16 John alluded to and how many countless hours

17 that the certifiers work to verify that

18 integrity of those products out there.

19 So this is doable on the ground. 

20 There's the other marketing sort of structures

21 and that kind of thing, but this is something

22 that could provide a safety net for some
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1 people, and I just want to give a shout out to

2 the certifiers that will bear the work load on

3 behalf of this, what we're working through.

4 MEMBER FELDMAN: Harold?

5 MEMBER AUSTIN: A couple different

6 things to point out, and I guess it will

7 provide somewhat of a safety net, although I

8 don't think much. A couple things. Bloom

9 thinning. You know, there are certain

10 varieties depending on how they're planted, 

11 especially in apples, that actually get

12 blossom thin. So not every variety, every

13 block, every type of planting is going to get

14 a bloom thinner on it. Density is already --

15 you know, on the existing ranches that we're

16 talking about, it's already established. They

17 can't modify that. I mean it is what it is. 

18 And the same thing would apply to

19 the genetic resistance and rootstock and

20 scion. I mean if this is a temporary order,

21 it's an order that is talking pretty much

22 about stuff that's already in existence. 
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1 To divert their crop, most of the

2 growers in Washington are involved in a food

3 safety program either SQF1000 or GlobalGAP

4 Tier 1 or Tier 2. If they're a GlobalGAP

5 certifier with a fruit cooperative, it means

6 that they then have their food safety

7 certificate as a part of that warehouse's

8 certificate. So if they have to convert their

9 fruit from organic over to conventional for

10 that crop year, they may have some problems

11 trying to move it, because a certificate -- if

12 you're a Tier 2 you're underneath the

13 warehouses and it's not a stand-alone

14 certificate for you as a grower. So that's

15 going to create an issue.

16 Processors wouldn't accept the

17 fruit as well under the climate that we're now

18 in where everybody is gearing up trying to

19 head towards what the FDA's Food Safety

20 Modernization Act is going to be. Washington

21 State, our growers have really gotten ahead of

22 this process and I don't know of very many
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1 that are not certified either SQF1000 or

2 GlobalGAP Tier 1 or Tier 2 at this juncture.

3 So that creates an issue. It really does.

4 Smaller growers probably could

5 handle it a little bit more so I think if

6 their acreage was really small, but you know,

7 if you've got any kind of volume at all, it's

8 going to create some serious problems where

9 that fruit's going to end up. Most likely a

10 little bit of it gets sold. A lot of it's

11 going to end up going to the landfill. And if

12 you're that type of grower, a smaller grower,

13 you may not be able to afford that. I mean

14 that's your livelihood. 

15 So, yes, I think there's some

16 things in here that could help. I think

17 there's some things that we're already doing

18 as organic growers, but I do think, as Zea

19 pointed out, some of this stuff isn't

20 practical in certain specific areas. But I do

21 think the bloom thinning, that's not going to

22 be, you know, a one-size-fits-all because not
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1 everybody's bloom thinning because some are

2 doing it be hand. And we do have the fruit as

3 a concern, too, where it's going to end up at.

4 MEMBER FELDMAN: Thank you. Jean?

5 MEMBER RICHARDSON: I might

6 suggest that we might be able to amend the

7 motion as it is on the floor; and I'm the

8 seconder of the motion -- is that we simply

9 stop the recommendation at the end of the

10 first paragraph and that it simply goes on to

11 say, "The NOSB recommends that the NOP issue

12 guidance on alternative practices to implement

13 a systems-based approach that integrates

14 prevention, monitoring and control of fire

15 blight," and simply leave it at that and

16 eliminate the prescriptive detail which will

17 vary enormously as we understand in its

18 application in the different areas. 

19 MEMBER FOSTER: If that were done,

20 does that change the uncertainty I thought I

21 heard in the Program's thinking about this?

22 MR. McEVOY: No, there's a lot of
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1 things here that we have not run through any

2 kind of review process. So it could be fine,

3 but we haven't had a chance really to analyze

4 how this would fit into the existing emergency

5 pest provision under 672, what kind of

6 authority we have to do this. So there are a

7 number of questions here.

8 CHAIRMAN STONE: Yes, along those

9 lines I think this -- I know there's some

10 fancy footwork that the Program will have to

11 do to -- the existing regulation doesn't allow

12 for the rapid -- the growers have to have full

13 capability to make the decision-this-morning14 and-go-do-it-this-afternoon-sort of an

15 approach, not waiting on approvals from

16 government agencies, or certifiers for that

17 matter. So it has to be structured in a way

18 that's functional on the ground, or else it

19 looks like we did something but didn't really. 

20 But I guess that also suggests

21 that -- this is a recommendation. The Program

22 a lot to ruminate on this one, and as Miles
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1 said, get legal counsel involved in stuff. So

2 I don't know that we need to overly wordsmith

3 it because it is a recommendation and they'll

4 have to turn that back around, and we'll have

5 time to see this again before anything

6 happens.

7 MEMBER FELDMAN: Nick?

8 MEMBER MARAVELL: Yes, I'll ask

9 Miles and anybody else who might know, has

10 this section of the regulation ever been

11 invoked before?

12 MR. McEVOY: Repeat that, Nick,

13 yes.

14 MEMBER MARAVELL: Yes, I asked

15 anybody whether in the audience, at the table

16 or on the NOP staff, has this aspect -- maybe

17 not in just this way, but has this aspect of

18 the regulation ever been invoked before? It's

19 generally referred to as the Emergency Spray

20 Provision.

21 MR. McEVOY: Six-seventy-two, the

22 Emergency Spray? Yes, it's under
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1 consideration currently with the citrus --

2 what's it called, Asian citrus --

3 MEMBER SONNABEND: Asian citrus

4 psyllid.

5 MR. McEVOY: Psyllid.

6 MEMBER SONNABEND: But that's a

7 true government-mandated --

8 MR. McEVOY: Right.

9 MEMBER SONNABEND: -- emergency

10 spray, not just organic.

11 MR. McEVOY: Right. So I don't

12 know if they've started the spraying, but

13 they're going to be spraying some organic

14 citrus orchards in California for the psyllid.

15 MEMBER MARAVELL: Well, I would

16 point out this is a very important distinction

17 that Zea has just mentioned, that this would

18 only apply to organic growers. The

19 conventional growers, this would be of no

20 value to anyway. And so that does put, you

21 know, a limitation on it which might make it

22 easier, might not. 
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1 MEMBER BONDERA: Yes, I just want

2 to say that I think given where we're at right

3 at this moment, from my perspective, I agree

4 that this isn't necessarily perfect. It was

5 put together very quickly. Like Harold was

6 saying, it's not going to work for everybody

7 and do everything, but it may help some and I

8 think it may be worth the time and energy and

9 effort that is put in. And I mean I can

10 understand from the programmatic perspective

11 the costs, but I just don't see the negative

12 aspect. So I would say my perspective is

13 let's try to move forward with some

14 potentially positive opportunity given the

15 circumstance where we're at right now.

16 MEMBER FELDMAN: Zea?

17 MEMBER SONNABEND: I too have some

18 concerns about whether it actually can be

19 implemented or not, but to address Harold's

20 concerns, it's better than we have now for

21 those people who can work it. And the people

22 who can't work with it because of GlobalGAP
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1 and the like just have to make their choice

2 based on the other options. So, you know, I

3 don't think they have to send fruit to the

4 landfill, but they may have to pull out of

5 organics altogether or find an alternative way

6 to control fire blight. But to help those

7 people who we can help through this program if

8 it can be adopted seems worthwhile to try. 

9 I would feel more comfortable if

10 it said in the part that the NOSB recommends

11 guidance -- I would feel more comfortable if

12 it said "the NOSB suggests that the NOP issue

13 guidance," so it's not part of a

14 recommendation, because I see that the very

15 complicated issue of guidance might distract

16 from getting a rulemaking done on this. So if

17 it's a suggestion, they can work through it

18 and not have to have the same weight as a

19 recommendation.

20 CHAIRMAN STONE: Jay, I'm going to

21 suggest that if a couple of you Crop Committee

22 maybe get together and decide on some
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1 wordsmithing and where to draw the line here. 

2 Basically we just lobbed an IED in the

3 Program's lap and they're trying to see just

4 how they can handle it and just what -- and

5 then they can better advise us. 

6 So if we take a break for I'll say

7 15 minutes. After the break we'll finalize

8 this. We've got workplan and a little bit of

9 a wrap up. So I hope everyone will stay in

10 the audience because there's a few things yet

11 we'd like to convey to the audience. Thanks.

12 So I don't know what time it is. 

13 Back at 4:45. So 12 minutes.

14 (Whereupon, at 4:31 p.m. off the

15 record until 4:43 p.m.)

16 CHAIRMAN STONE: Okay. We're

17 going go on back to work. We'll wrap up this

18 meeting.

19 So I think what we've decided; and

20 again with consultation from many of you in

21 the audience, this is an attempt, because of

22 the tough emotional decision that we made a
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1 little bit ago and a safety net, if you will,

2 but this Board normally scrutinizes every

3 word, Nick, and we think we need to give this

4 more time to senesce into a document and a

5 process and a procedure. The Program has a

6 lot to consider at the -- just the inner

7 workings of this on our behalf. Consumers and

8 industry, everyone needs to have a look at

9 this. That's our normal open policy. 

10 I don't like the precedent setting

11 of just throwing something together and people

12 haven't read it and fully digested it. But we

13 do want to get the word out to the growing

14 community, growers, that we're considerate of

15 their concerns and may be able to craft a

16 methodology that can provide some safety net

17 to some individuals.

18 So I think what we decided was

19 that we'll keep this basic motion, keep this

20 basic language as a recommendation and make a

21 motion to the Program to work with us in this

22 next term, put this subject on the workplan
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1 for the Crops Committee for the summer term

2 and the Program will be working with us

3 obviously to see if we can implement something

4 like this, what would it look like and get

5 input and feedback from the related

6 shareholders. I like that word, Jay and

7 Harold. 

8 So if you want to -- I'm not sure,

9 Jay, just how we want to take this intent and

10 make the motion is more about this

11 consideration. 

12 Nick?

13 MEMBER MARAVELL: Yes, I

14 respectfully want to go on the record here

15 because "we" does not represent my opinion in

16 this particular case. And let me just say

17 what we're trying to do and why I feel that we

18 might be overplaying this a bit.

19 Under the statute, the Organic

20 Foods Production Act, it enumerates several

21 responsibilities that the Board has to carry

22 out. It says "the Board shall." And one of
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1 those is we shall advise the Secretary

2 regarding emergency treatment programs. I

3 have no problem with vetting this and making

4 this a public discussion, but that's not the

5 Board's call. That's not our process. Our

6 process stops when we provide advice to the

7 Secretary. I can see that the Program may

8 want to get further input on this in terms of

9 advising the Secretary. The only thing that

10 we're doing is carrying out our mandated

11 responsibility under the statute.

12 So I don't really think that the

13 United States we can rework this until the

14 cows come home, but I don't think it makes any

15 difference. All we're doing is providing some

16 advice to the Secretary. That's all we're

17 doing. And we are mandated in law to provide

18 that advice when we find conditions that we

19 feel warrant the Secretary being advised of

20 that. And particularly to slow this down

21 within the NOSB with procedural activity in

22 the case of an emergency treatment program I
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1 think is a bad precedent. I think we simply

2 tell the Secretary, hey, we got a problem

3 here, and then it's up to the Secretary to

4 evaluate that and take whatever process the

5 Secretary wants to do. 

6 And I would also think that if

7 this is something that the Secretary wants to

8 evaluate, it would probably be better to have

9 a motion on the record rather than, well, you

10 know, they're sort of thinking about doing

11 this and we're not quite sure what they're

12 going to say. I mean we should just put it

13 out and say it. And if it turns out that

14 we're wrong and we should do something else,

15 we'll certainly take appropriate action at the

16 next meeting. 

17 So that would be -- I know you're

18 not pleased with this, Miles, but that would

19 be -- yes, I understand this is not going to

20 make your life easy, but it's not making our

21 life easy. We're in a very tight spot here. 

22 If there were a condition where we did need to
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1 invoke this because something was happening

2 right now, I don't see how we could take the

3 attitude, well, let's wait until the next

4 meeting and put it out for public comment when

5 that's not what this is about. I don't feel

6 that was ever the intent of the statute.

7 So I can fully understand how I

8 may be wrong in this case. That doesn't upset

9 me at all to be wrong, but I would

10 respectfully want to be on the record as

11 saying I would not vote to table this motion. 

12 I would send it forward. And if it turns out

13 that we are wrong, I don't think we've done a

14 lot of damage, but we may have done the right

15 thing.

16 CHAIRMAN STONE: Colehour?

17 MEMBER BONDERA: Yes, I would like

18 to -- and I know it's not the case, but I

19 would like to second Nick's motion, even

20 though he didn't make a motion. But I agree

21 with what -- I agree honestly and that's what

22 I was feeling during the break, too, is what
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1 if this couldn't wait? What if this was right

2 this second? And using this process to block

3 I think is a very poor precedent. And I don't

4 know what the Program imagines or thinks, but

5 I think that that's not the appropriate

6 strategy for us to be carrying out our role

7 here. We are not implementing action. We are

8 advising, and our advice can't just be in an

9 emergency put it on the table. So that's my

10 -- I support what he said.

11 CHAIRMAN STONE: Zea?

12 MEMBER SONNABEND: Do you guys not

13 realize that tetracycline is still allowed

14 this bloom season and next year and it's not

15 until 2015 that this would have to kick into

16 effect if it passes? I mean we're not talking

17 about having an emergency right now. It's

18 still allowed for two more seasons.

19 CHAIRMAN STONE: Correct. How

20 many more times you want to have this

21 discussion?

22 MEMBER FELDMAN: Why don't we
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1 withdraw our motion and convert this into a

2 motion that requests that the Program

3 investigate the ability of the Department to

4 adopt an emergency program that enables the

5 apple and pear producers with fire blight to

6 utilize tetracycline from October 21, 2014

7 through October 21, 2017?

8 MEMBER MARAVELL: Is that under

9 the Emergency Spray Provision?

10 MEMBER FELDMAN: Yes, I'm sorry,

11 under 7 U.S.C. 6518(k)(6) and Rule -- I don't

12 have it here, 205.672. Do we want to adopt

13 that as a motion? Does that work?

14 MR. McEVOY: Yes, that sounds

15 fine.

16 MEMBER FELDMAN: Anyone type it

17 out? 

18 MEMBER RICHARDSON: Can you read

19 back that motion, Michelle? 

20 CHAIRMAN STONE: Yes, somebody's

21 going to rewrite that and I think it needs to

22 -- so we can repeat it.
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1 Nick, did you have a question?

2 MEMBER MARAVELL: No. Well, I'd

3 like to make a comment that, you know, part of

4 my concern here is specific to this instance,

5 but part of my concern here goes more

6 generally to the statutory authority of this

7 Board. So I think people should consider that

8 in terms of setting this as a precedent.

9 CHAIRMAN STONE: Okay. So

10 somebody's succinct-ifying that motion on

11 paper?

12 MEMBER FELDMAN: Yes, I'm writing

13 it out. Should we go on and come back?

14 CHAIRMAN STONE: You want to go on

15 and come back to that?

16 The last thing on our agenda is

17 work plans and other business. So if

18 Michelle's not having to work on that motion,

19 then we'll go ahead and pull up work plans. 

20 We'll put Crops off until last, Jay, so you

21 all can work on that. 

22 So the work plans, again for those
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1 in the audience, when we're wrapping up

2 preparations for this meetings;

3 recommendations, proposals, et cetera, we also

4 look at work plan. The Subcommittees develop

5 those. We get petitions. We have sunset. 

6 We're looking forward. We take input from

7 written comment and personal comments at the

8 meetings and develop these work plans, what's

9 priorities. We discuss that with the Program

10 because we have to be pragmatic in what we can

11 get done, not just what we want to get done. 

12 So I guess if Committee chairs --

13 we're going to put Crops off until last. I'm

14 not sure just the order they're in. So if the

15 Committee chairs can sort of be a little bit

16 ready here, we'll work through these. And it

17 looks like Joe is up first with CACS.

18 MEMBER DICKSON: Thank you, Mac,

19 and pardon me while I open my work plan

20 document here. Oh, look, it's on the screen.

21 Our fall work plan for the

22 Compliance, Accreditation and Certification
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1 Subcommittee are -- the main piece of it is

2 the follow-up on the fall 2009 NOSB

3 recommendation on retail certification. That

4 was a process sort of started by several

5 earlier boards and not quite completed. And

6 we're looking to sort of resolve a few very

7 important questions about how the various

8 exemptions apply to retailers and how they

9 don't, and retail organic certification and

10 some of that territory.

11 We have a discussion document

12 centered around how certifiers apply

13 205.206(e), that John Foster's leading the

14 work on. And we offer our services to the

15 Program should we be able to provide any

16 guidance or work around implementing the Sound

17 and Sensible Initiative and look forward to

18 more dialogue with the Program on that.

19 And then finally, as we learned

20 today we will also be potentially working on

21 a discussion document or a proposal around the

22 exclusion of water related to the percentage
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1 of organic calculation and some of the

2 subtleties around nut milks and teas and

3 various high water content materials and how

4 their percentage is factored into organic

5 product calculations. 

6 And that is our work plan as I

7 know it now.

8 CHAIRMAN STONE: Does anyone

9 that's not on the CACS have any questions or

10 comments about that work plan?

11 Okay. I don't have my binoculars

12 with me. That looks like Crops sunset and

13 petition, so we'll scroll on down. We'll come

14 back to Crops. GMO ad hoc, that would be Miss

15 Jennifer.

16 MEMBER TAYLOR: Yes, sir. I can't

17 read that, but is it the same as what we had

18 previously? Okay. 

19 We are very excited about the

20 opportunity to use the transparency

21 communication docket system. And under that

22 system, when it's implemented, we will be able
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1 to take information such as the seed purity

2 document and the excluded methods documents

3 and receive additional information from our

4 public community.

5 What we have on our work plan as

6 we move towards the fall meeting is to proceed

7 with information gathered from the public and

8 from this meeting and develop a proposal

9 perhaps looking at seed purity, or maybe we'll

10 study it for awhile; we're not quite sure in

11 that direction how we'll take that, as well as

12 the excluded methods document that we received

13 information on. We are hopeful that we will

14 also be able to take that information and

15 receive additional information maybe through

16 the docket system as well or other methods and

17 bring that to a possible proposal for the fall

18 meeting again.

19 Other topics that we will be

20 looking at are prevention strategy guidance

21 for excluded methods in crops and handling and

22 tracing GMO's input. Is that on there,
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1 tracing GMO's input? I have that on my work

2 plan here. It is? Okay. And that's a

3 proposed discussion document also for the

4 fall.

5 I'm hopeful that we will be able

6 to look at farmer's choice. That's something

7 that I have been talking about and the

8 Committee talked a little bit about with Mac

9 as well, but have not presented that

10 information to the Subcommittee yet. 

11 So that's our plan as we proceed

12 towards the fall.

13 CHAIRMAN STONE: All right. Thank

14 you, Jennifer.

15 Any questions or clarifications

16 from Board Members?

17 All right. Waldo, you're up with

18 handling.

19 MEMBER FOSTER: Gibberellic acid

20 could be on our list. The current status is

21 on hold at the moment. I believe we're

22 waiting for a response from the petitioner. 
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1 We have ammonium hydroxide; which Jean has

2 been working on, a petition to remove glycerin

3 from 605. We have a petition for PGME as a

4 boiler water additive. We'll also be working

5 on 2015 sunset items; four of them I believe,

6 gellan gum, marsala, sherry, tragacanth gum,

7 I believe. And we've assigned all -- I

8 believe a total of eight items we have leads

9 for.

10 Depending on how these go, we may

11 or may not have more room to work on

12 materials. We also will, I'm sure, continue

13 discussions, if nothing else, on ancillary

14 substances. I would imagine that we'll have

15 continuing dialogue on that, given the level

16 of interest I think the community has

17 expressed in that. 

18 That's all I have at the moment. 

19 CHAIRMAN STONE: Thanks. Any

20 questions or clarifications from other Board

21 Members?

22 Okay. Tracy will be swimming in
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1 work this session. Livestock.

2 MR. FAVRE: As we're going to be

3 the all aquaculture all the time channel on

4 the Livestock Subcommittee, although we do

5 have one outlier with the methionine for the

6 organic poultry feed proposal we'll be

7 addressing, we've got one, two, three, four,

8 five, six, seven eight, nine, I believe,

9 aquaculture materials that have been proposed,

10 as well as the omnivore diet response, or the

11 next step for the discussion document which

12 I'm going to have some feedback for you here

13 in just a moment, as well as we have added to

14 our work plan the vaccines from excluded

15 methods from the GMO ad hoc committee. 

16 Will you go ahead and pull that up

17 for me, please?

18 We do have a little bit of

19 feedback from specifically the methionine

20 issue in regards to the omnivore diet

21 discussion document that we put out for the

22 last meeting where we got absolutely
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1 unequivocal feedback that the community did

2 not want meat scraps in poultry or pork diets. 

3 So as we're moving forward with this we have

4 some summary statements here, and it's

5 basically that we are continuing to seek

6 feedback for input on ways to solve this

7 dilemma for omnivore diets, and are really

8 exploring all sorts of potential options, and

9 looking at promising alternatives, and looking

10 at the options for encouraging, and promoting

11 research into those areas. These are just

12 some of the summary statements that we put

13 together.

14 We did get some feedback on the

15 herbal methionine option that we were looking

16 at from a report back in December 2012 that

17 essentially that trial was ineffective. And

18 so there needs to be some more research done

19 into that to see if it truly is a viable

20 alternative or if we need to abandon that as

21 a potential option. And the Methionine Task

22 Force has just funded a major research study
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1 to be conducted looking at the implementation

2 of the step-down proposal, and there's going

3 to be quite a lot of work put into that

4 between now and the fall meeting, and we're

5 looking forward to hearing from them on that.

6 So really the final thing we

7 really want to say is that we've got to find

8 a way to reduce synthetic from this industry. 

9 Still struggling with issues. It's not

10 probably -- or maybe it is on the same order

11 of magnitude as we've gone through here with

12 oxytet, but it's a similar issue where there

13 is no good replacement yet. So we're

14 struggling with it. And we want to really

15 keep the stakeholders and the public abreast

16 of what we're doing. 

17 At the same time we want to

18 emphasize even though the proposal for meat

19 scraps in the omnivore diet discussion

20 document was rejected pretty soundly, we still

21 want to make a statement as a board that we

22 want to encourage the natural foraging
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1 behavior part of that discussion document. 

2 And so we'll be providing some additional

3 feedback at the fall meeting. 

4 And I think that wraps it up for

5 Livestock.

6 CHAIRMAN STONE: Thanks, Tracy. 

7 Any further discussion, clarifications from

8 the Board?

9 Okay. Materials. Miss Zea, if

10 you're not working on that motion.

11 MEMBER SONNABEND: Thank you, Mac. 

12 So our big work plan item for the next time is

13 to examine and update the petition on the

14 technical review process. The Department has

15 sent us a number of bullet points to work on

16 and I believe plans to send us some more. I

17 imagine we are going to fold into it the

18 process for limited scope TRs and in fact the

19 confidential business information portion as

20 part of that. And we may also undertake the

21 issue around convening of technical advisory

22 boards and/or a working group policy. 
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1 Also the definition of production

2 aids from this discussion document may

3 continue to be worked on. And then yearly we

4 will present our yearly list of research

5 priorities from all of the committees. So we

6 will be nagging or asking all of the

7 committees to assemble their research

8 priorities and give it to the Material

9 Subcommittee.

10 Our ongoing project is petition

11 and TR tracking. We don't have to do too much

12 these days because Lisa does such an admirable

13 job of sending a monthly update on where we

14 stand and we all look at it over. And then at

15 some future time we may undertake how to

16 address scientific uncertainty. Thank you.

17 CHAIRMAN STONE: Okay. Any

18 questions, clarifications? That reminded me

19 that we've a little conversation, Executive

20 Committee and individually, that one way that

21 maybe we can -- we talked about reducing the

22 number of people on each committee, depending
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1 on the work load for that term. But we've

2 also talked about we may combine a committee

3 or two here, save some staff time with the

4 program so they can work on other ingredients

5 or some of these other items. So it may look

6 a little different when we come back when you

7 see recommendations in the fall, or it may

8 not. I'm not sure.

9 Okay. Policy. Colehour.

10 MEMBER BONDERA: Thank you. So

11 the Policy Development Subcommittee intends to

12 regroup around what happened with the material

13 initiation discussion document that we worked

14 through at this meeting. So that is still at

15 least tentatively ongoing. 

16 I think our primary emphasis will

17 be on review and updates to the Policy and

18 Procedure Manual. At this point in time we

19 are essentially trying to redo the whole

20 thing, which is not something that's been

21 tried to be done in one fell swoop. So as

22 I've communicated to both the Subcommittee and
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1 the Executive Subcommittee, it seems like we

2 may need to have that also be on at least the

3 spring '14 agenda. 

4 And although they aren't on the

5 screen in front of you right now, I still have

6 on this list some things that are going to

7 have to get I think clarified. For example,

8 the program came out with a memorandum on the

9 subject of conflict of interest, however, the

10 NOSB in no format adopted or updated our

11 conflict of interest policy. So like was

12 stated in the last Executive Subcommittee

13 meeting before we came here, what we have to

14 work with is what exists right now in the

15 Policy/Procedure Manual. They have put forth

16 a memo, but that is not our adopted policy. 

17 So my personal opinion is that will need to be

18 on an agenda.

19 And it's also not on this screen

20 right now, but we have talked about

21 decisive/indecisive determination of NOSB

22 votes. And the program has told us that they
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1 would be providing a memo on that topic, but

2 we kept it on the work plan because we didn't

3 know what that would entail or when that would

4 happen. And so, my feeling as the Chair is

5 that that should still be on the work plan at

6 this time, unless we agreed to withdraw it. 

7 So I think that that's all that I

8 -- yes, I think that covers what I wanted to

9 share. Thank you.

10 CHAIRMAN STONE: Thanks, Colehour.

11 Any questions, clarifications?

12 All right. I've asked John, the

13 Vice Chair of Crops, if he can run down the

14 crop list while Jay -- are you ready? 

15 MEMBER FELDMAN: Yes.

16 CHAIRMAN STONE: Oh, okay. I

17 thought you were working on the motion still. 

18 Sorry.

19 MEMBER FOSTER: And let me just

20 step away from being Vice Chair of Crops right

21 now.

22 CHAIRMAN STONE: Oh, yes, Nick,
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1 who is Vice Chair?

2 MEMBER FELDMAN: I got it.

3 CHAIRMAN STONE: Okay.

4 MEMBER FELDMAN: Sorry. Okay. 

5 For the fall meeting we have vinasse on the

6 agenda. This is a petition. We have a

7 petition that recently came in on

8 streptomycin. We have aquaculture. These are

9 used in aquatic plants, so carbon dioxide,

10 chlorine, micronutrients, lignin sulfonate and

11 vitamins B1, B12 and H. We have a petition on

12 magnesium oxide as well. And then we are

13 still working on the inerts, so the Inerts

14 Working Group is working away and we may have

15 some work to do, at least do an update. 

16 Hopefully we'll have some good news to report.

17 And then one of the new issues

18 that we'd really like community input on is

19 contaminants in farm inputs. This started out

20 being called compost, but we've adopted a

21 broader construct of how we move forward on

22 this. So that is on the list as well.
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1 And then we'll be starting to work

2 on issues that will not be on the fall '13

3 agenda, but spring '14. And these are

4 sunsets. Sulfurous acid, sodium carbonate,

5 peroxyhydrate and aqueous potassium silicate. 

6 We'll start our TRs on that.

7 Then the other thing we haven't

8 really talked with the program yet is when we

9 should start or could start working on

10 guidance related to the bio-mulch, whatever. 

11 We're calling it biodegradable mulch. So that

12 is something we may ask the program about

13 starting work on. I don't know what the time

14 table is for that.

15 Did I get everything?

16 CHAIRMAN STONE: That's enough.

17 MEMBER FELDMAN: Thank you. Yes,

18 and then we'll also be working on the

19 emergency provision for -

20 CHAIRMAN STONE: Okay. Questions

21 or clarifications on the work plan?

22 All right. Thank you very much. 
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1 So do you have a motion drafted

2 over there?

3 MEMBER SONNABEND: Here's the

4 motion while Jay's looking for it. Move to

5 request that the NOP investigate the ability

6 of the Secretary to invoke its authority under

7 the Emergency Spray Program's provision of the

8 Organic Foods Production Act, 7 U.S.C.

9 6518(k)(6) and Act 7 C.F.R. Section 205.672 to

10 allow the emergency use of oxytetracycline for

11 fire blight during the period of October 21st,

12 2014 to October 21st, 2017.

13 MEMBER FELDMAN: I guess we should

14 introduce this as a motion.

15 CHAIRMAN STONE: Yes, let's maybe

16 see if we're going to -- the language is going

17 to change any. Or we could get a motion and

18 a second on the floor.

19 MEMBER FELDMAN: Okay. I'll

20 introduce this as a motion. Can I get a

21 second?

22 MEMBER RICHARDSON: Second.
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1 CHAIRMAN STONE: All right. Nick?

2 MEMBER MARAVELL: I have a point

3 of order. Was there a previous motion on the

4 table that was made?

5 MEMBER FELDMAN: I think the

6 record will reflect that it was withdrawn and

7 seconded. I think you --

8 MEMBER MARAVELL: It was

9 withdrawn? I wasn't aware of that.

10 CHAIRMAN STONE: It wasn't

11 withdrawn at the table, so we do need to

12 withdraw it at the microphone.

13 MEMBER MARAVELL: Right. 

14 Because --

15 MEMBER FELDMAN: Oh, okay. 

16 MEMBER MARAVELL: So if you want

17 to make a motion to withdraw it, I would

18 welcome the opportunity to vote against it and

19 then I can --

20 MEMBER FELDMAN: Okay. 

21 MEMBER MARAVELL: Just do it in a

22 hurry. 
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1 MEMBER FELDMAN: I'll introduce a

2 motion to withdraw the original motion in

3 deference to the Department's need to

4 investigate this issue in good faith so that

5 we can move forward a program that addresses

6 emergency conditions for growers who are

7 experiencing fire blight. I need a second,

8 please.

9 MEMBER RICHARDSON: I second that.

10 CHAIRMAN STONE: Motion and a

11 second to withdraw the original emergency

12 spray plan. Anyone like to comment?

13 Seeing none, I guess we still have

14 to do this formally. So we'll proceed to the

15 vote, and John goes first.

16 MEMBER FELDMAN: We don't need to

17 do that. We withdrew the motion. You never

18 voted for it. We never got to a vote. We

19 were in discussion.

20 MEMBER MARAVELL: Excuse me?

21 MEMBER FELDMAN: We never voted on

22 the previous motion.
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1 MEMBER MARAVELL: No, we didn't.

2 MEMBER FELDMAN: Right. We

3 withdrew it before you had a chance to vote.

4 MEMBER MARAVELL: I'm not trying

5 to vote on that. I'm trying to vote on the

6 motion to withdraw it. 

7 CHAIRMAN STONE: I think we still

8 have to -- we have a motion and a second.

9 MEMBER FELDMAN: No, I think we

10 can just withdraw it.

11 MEMBER BONDERA: Nick, we have to

12 vote on withdrawing the motion, is that

13 correct?

14 MEMBER MARAVELL: I don't know if

15 we have to. I'd love to, but I don't know if

16 we have to. I mean I'm not a parliamentarian,

17 but normally when there's a motion on the

18 table you can't just -- you can make a motion

19 to table which then requires a vote. You can

20 make a motion to withdraw, or you can vote it

21 down. But I'm not a parliamentarian and I'm

22 not trying to give the Chairman a hard time. 
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1 I'd just like the opportunity to vote against

2 withdrawing it. That's all.

3 CHAIRMAN STONE: All right. So

4 let's go this way: All in favor, say aye?

5 Any opposed?

6 MEMBER MARAVELL: No.

7 CHAIRMAN STONE: Very good. Okay. 

8 The ayes have it.

9 MEMBER FELDMAN: Thank you, Nick,

10 for getting that on the record. And I do

11 think you're raising an issue that we should

12 resolve. So are we back to the motion --

13 CHAIRMAN STONE: We're back to the

14 motion --

15 MEMBER FELDMAN: -- just to get

16 back on track here?

17 CHAIRMAN STONE: Right.

18 MEMBER FELDMAN: I introduced the

19 motion. Jean seconded the motion that was

20 read by Zea.

21 CHAIRMAN STONE: Can you blow that

22 up just a little, Michelle, please?
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1 Can you all tell? Is that enough

2 to work with without being prescriptive?

3 MR. McEVOY: Yes, we can work with

4 that.

5 CHAIRMAN STONE: Any other Board

6 Members see -- not going to give you too long. 

7 Okay. Kind of like the aye and no thing, but

8 -- so we'll proceed with the vote. And let's

9 finish this out formally and we may think

10 about this aye and nay thing, but -- so, John,

11 you get to start.

12 MEMBER FOSTER: Yes. 

13 MEMBER WALKER: Yes.

14 MEMBER FULWIDER: Yes.

15 MEMBER AUSTIN: Yes.

16 MEMBER TAYLOR: Yes.

17 MEMBER MARAVELL: Is it my turn? 

18 Yes? No. 

19 MEMBER THICKE: Yes.

20 MEMBER BONDERA: Yes.

21 MEMBER FAVRE: Yes.

22 MEMBER BECK: Yes.
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1 MEMBER SONNABEND: Yes.

2 MEMBER FELDMAN: Yes.

3 MEMBER RICHARDSON: Yes.

4 MEMBER DICKSON: Yes.

5 CHAIRMAN STONE: Chair votes yes. 

6 So that's 1 no, 14 yes. Motion carries.

7 Thank you. 

8 Miles, we appreciate you all's

9 interest in working with us to develop a

10 system if and in fact it can be workable, it

11 may not be helpful. We hope it might be or

12 provide some safety net.

13 Okay. Does anybody else that's on

14 the Board have any other business or something

15 to bring to the attention?

16 Well, I'll just like to -- oh, I'm

17 sorry, Miles. Go ahead.

18 MR. McEVOY: Yes, I just wanted to

19 let people know that the President released

20 the budget yesterday and in the budget for

21 USDA includes a $2 million increase for the

22 National Organic Program for --
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1 (Applause.)

2 MR. McEVOY: -- enforcement and

3 international trade arrangements. So a $1.5

4 million increase for increased enforcement and

5 half a million dollars for working on

6 international trade arrangements. So that's

7 just one of a number of things that would need

8 to happen. Currently we're under about five

9 percent less money this year than we had last

10 year. And that's just some information for

11 you. There you go.

12 CHAIRMAN STONE: So even more work

13 for you. That's good. 

14 I'd like to close out this meeting

15 with just a couple of thoughts. This Board

16 recognizes that nobody rotates off next year. 

17 These 15 of us, we get to share the next year18 and-a-half, almost two years together. So I

19 look forward to us furthering the

20 relationship-building that this afternoon

21 really did. I think it brought us closer as

22 individuals. Having breakfast this morning
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1 with people that were on each side of this

2 difficult issue and the share and the love

3 that they showed for each other was just

4 really rewarding. 

5 But I also have to say to some of

6 those in the community that created an

7 environment of mistrust and often used twisted

8 or misleading language, it doesn't really pass

9 the sniff test of organic principles to a lot

10 of us that on this side of the microphone have

11 to really wrestle with these things. And a

12 strong consumer advocacy is very important to

13 this whole process, but it makes it harder to

14 do our job on this side of the table.

15 I want to recognize not just the

16 NOP staff that's here, but those of you all

17 back in D.C., and many of you work from around

18 the country, for all the work you do. And I'd

19 like for those of us on the Board and everyone

20 in the audience to give Michelle Arsenault a

21 big round applause for all that she does.

22 (Applause.)
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1 CHAIRMAN STONE: So last I'll just

2 say, and I'll try to do it without crying, but

3 I've never been more proud of a group of

4 people than today. Thank you.

5 (Whereupon, the above-entitled

6 matter went off the record at 5:23 p.m.)

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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A

abandon 375:20

abbreviated 179:19

abides 328:12

ability 20:12 68:5

278:22 335:21

366:3 384:5

able 20:17 21:14

32:15 49:2 79:2

87:7 97:14 107:18

161:19 162:6

169:22 178:3

235:3 242:1,7

256:17 275:7

287:6 289:20

301:13 309:3

313:3 334:9

346:16 352:13

353:6 360:15

369:15 370:22

371:14 372:5

above-entitled

106:9 269:13

393:5

abreast 376:15

absence 76:14

absent 17:10,12

183:18 205:21

absolute 174:13

absolutely 60:19

79:10 86:14 135:9

223:15 276:4

374:22

Abstain 228:6

abstained 112:17

118:1

abstention 13:16

15:15 228:18

abuse 315:18,22

317:16,17

abused 317:22

ACA 18:22 25:4

170:15

ACAs 19:20 20:20

23:13 25:1,6,13

32:15

accent 101:20

accept 107:21

110:14 197:11

278:16 282:1

342:3 351:16

acceptable 198:22

306:4

acceptance 67:5

accepted 179:6

268:4

accepting 155:15

access 29:12 32:6

32:10 178:13

289:15 291:22

accessible 183:2

accommodate

25:20

accommodated

30:5

accommodating

280:2

account 305:22

accountability

294:15

Accreditation 3:16

3:20 368:22

accredited 346:3

accurate 138:19

170:6 177:19

224:17

accusations 84:12

accused 85:17

achieve 20:18

85:11 310:1

acid 3:25 7:17 8:3,7

8:11 9:10,12

10:15 37:9,12,14

37:18 38:3,5,11

42:4,4,9,11,14

43:10 44:4,16

107:1,14 108:1,17

109:10 110:13,16

246:11,18 248:1

372:19 383:4

acids 3:24 204:22

218:6 220:19

221:7 222:21

224:2 225:19

acknowledge 21:16

159:10 298:16

302:16 305:14

acknowledged 26:3

215:17

acknowledging

275:13,20

acknowledgment

232:16

acquired 243:13

acre 334:14

acreage 289:13

306:14 352:6

acres 306:13

acrimony 67:15

Act 28:12 59:16

206:9 344:18

351:20 361:20

384:8,9

action 76:15

107:14 241:19

242:13 363:15

365:7

active 101:8 210:9

210:10 239:14

activity 229:14

362:21

actual 99:14 178:9

180:16 184:21

208:7

ad 370:14 374:15

adapt 294:17 295:1

adaptability

294:15

add 12:15 14:21

17:11 22:21 30:17

33:5 45:6 47:18

49:10 51:3 64:4

88:19 90:8 110:15

126:20 127:18

129:14 134:4

152:2 155:4

163:19 172:22

174:15,16 175:19

185:3 219:5

222:12 237:15

251:20 253:12

267:9 271:19

301:19 303:16

310:21 323:20

326:13

added 10:16 24:6

25:2 42:6,9 48:10

49:8 52:5,9,12

61:17 65:13 74:2

152:11,18 155:5

176:2,5,11 180:13

221:9,11 222:6

374:13

adding 51:12

128:22 155:7,10

221:22

addition 8:10 11:19

14:7 16:8 198:11

207:12 234:2

276:10 341:3

additional 10:8

11:17 14:5 22:11

29:6 50:12 62:12

80:5,7,10 89:19

131:20 177:5

187:14 189:14

212:7 213:18

215:20 229:22

255:12 332:1

371:3,15 377:2

Additionally

177:21

additive 96:17

176:4,6 227:11

373:4

additives 90:3

93:18 140:11

176:1

address 10:9 77:3,4

152:20 164:5

233:12 239:3

347:7 357:19

378:16

addressed 19:21

331:21

addresses 386:5

addressing 92:11

126:10 374:7

adequate 158:11

216:7 222:7

289:15 307:6

adequately 238:16

adhere 298:3

adherence 61:2

Adjournment 4:17

adjuster 9:12

Administrator

2:12

admirable 378:12

ado 7:13

adopt 252:9 307:8

366:4,12

adopted 102:13

206:15 271:16

279:15 358:8

380:10,16 382:20

adopting 136:2,3

310:4 347:20

adoption 25:5

advance 8:20 12:8

14:18 16:18

advancing 270:4

advantages 242:13

adverse 44:1

advice 65:16,20

199:6 258:19

278:9 362:6,16,18

365:8

advise 359:5 362:1

advised 362:19

advises 345:16

346:1

advising 362:9

365:8

advisory 2:14 93:2

377:21

advocacy 315:14

392:12

advocate 295:15

298:12 311:7

313:19

advocates 341:4

advocating 315:22

affairs 98:8

affect 159:1
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affixes 174:3

afford 352:13

afternoon 18:8

40:6 124:16 125:5

391:20

ag 120:12 284:11

age 96:2

agencies 191:2

354:16

agency 289:3

agenda 8:7 17:17

21:14 37:3 38:3

38:12 124:11,22

169:10 191:15

269:7 367:16

380:3,18 382:6

383:3

agent 17:2 174:5

279:2

agents 176:2 279:6

ago 18:6 37:11

46:19 76:12 95:18

158:22 219:3

249:20 292:2

323:22 327:3,4

336:15,15,16

360:1

agonizing 327:9

agree 43:22 64:8

84:14,14 134:1,13

135:6 177:15

188:5 216:10

253:1 308:2

325:18 333:12

357:3 364:20,21

agreed 381:6

agreement 5:21

134:5 182:10

187:7 318:2

agrees 42:2,17

agribusiness 69:16

agricultural 13:14

14:9 15:14 31:7

85:22 90:1 112:12

116:8 120:5,12

138:16 146:15

147:5 164:20

166:18 171:16

173:13 182:13

257:3 321:14,15

agriculture 1:2,3

53:1 97:18 193:8

278:7 314:6 315:4

315:22 320:20

321:17 322:5,6

325:16,17,21

333:8

Ah 124:14

ahead 28:6 109:3

121:21 125:10

189:11 218:7

220:11 230:7

231:12 236:3,4

262:20 272:16

305:12 347:17

351:21 367:19

374:16 390:17

aid 143:10 182:4

183:6 199:17

241:20

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53:20 60:15 62:2

63:4,18 64:2,3

66:21 67:9,15

73:17 87:2 113:4

118:11 157:9

178:9 225:16

232:19 234:9

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139:18 209:8,11

213:19 214:8

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279:9 330:20

368:21 369:2

371:6,17 372:4,12

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okay 7:6,6 13:20

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128:10,19,21

129:16,17 134:16

135:19 145:8,15

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164:16 167:20

168:4,15 169:5

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somebody 68:4

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somebody's 36:19

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somewhat 25:22

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son 318:18

song 22:1

SONNABEND

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2017 215:13 305:17

344:12 345:21

366:7 384:12

2018 295:20

205 3:22 329:13

205.206(e) 369:13

205.302 174:1

181:20

205.302(a) 171:10

205.601 98:21

207:10 237:16
202-234-4433

Neal R. Gross & Co., Inc.

Page 445

248:2 271:20

344:9

205.602 38:20

205.603 207:11

226:1

205.603(d) 227:11

205.605 8:11 16:9

37:9 43:1 103:5

129:18 175:13

176:3 223:4

205.605(b) 17:11

110:16 123:7

205.606 11:20

12:12 14:8 15:15

54:18 114:16

115:7 117:14

176:3

205.672 344:20

345:22 366:12

384:9

206 329:13

21 95:12 344:12,12

345:21 366:6,7

21st 271:19 272:2

384:11,12

218 3:24

22 239:14

229 3:24

24 280:13 324:17

246 3:25

251 3:26

271 3:26

29th 8:8 46:19 3 3 3:1 99:2 167:3

173:3,11 175:9

207:14 250:21

263:21

3s 100:20

30 59:12 125:10

158:18 321:18

336:15

30th 14:3

32 240:4

368 4:12

37 3:8 53:22

390 4:14

393 4:17

4

4 4:7 19:4 23:18

24:3 98:22 100:19

141:18 167:4

176:15 200:17

201:19 207:1,13

208:3,8 210:21

215:13,14 263:21

4A 207:5

4B 207:6

4,000 53:9

4:31 359:14

4:43 359:15

4:45 359:13

40 47:1 286:22

41 3:9

45 3:10

5

5 3:3 18:22 23:17

178:18 179:22

180:14 192:15

299:2

5,5-Dimethylhyd...

123:6

5:23 393:6

50 3:10 47:2 97:3

59 3:11

6

6 179:14 187:6

189:13

6th 1:12

601 38:7 147:16

605 37:12 89:11

140:15,18 146:21

147:2,10,19 148:8

148:22 153:16

165:15 166:2

373:3

605.606 138:21

606 56:20 89:11

103:5 113:3

146:17,19 153:17

166:3

6518(k)(6) 345:22

366:11 384:9

67 19:4

672 354:5

69 3:11

7

7 3:6 98:20 181:18

198:14,17 199:11

240:6 344:20

345:22 366:11

384:8,9

7th 14:4

70 180:17,21

77 240:5

8

8 26:1 182:12 221:9

8,000 86:21

8:00 1:12

8:02 5:2

80 61:7

80s 316:1

88 3:12 18:18,21 9 9 19:1 182:21

9th 16:6

9:55 106:10

92 3:12

921 1:12

95 3:13 48:15 180:3

180:18,20 189:16

189:17,19

98 3:14

99 89:13
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 

446

National Organic Standards Board

USDA

04-11-13

Portland, OR