National Organic Coalition Advocates to Keep Organic Seal Strong

National Organic CoalitionThe National Organic Coalition is a cross-sector alliance of fourteen organizations from across the U.S., including the Northeast Organic Farming Association. Our member organizations represent diverse stakeholder groups in the organic community – we are farmers, consumers, environmental groups, certifying organizations, retailers, and progressive businesses coming together to be a strong and united voice for integrity in the USDA National Organic Program.

Our coalition came together in 2001, just as the federal organic regulations were being finalized and put into place. Since that time, NOC has been working in various arenas, including Congress, the U.S. Department of Agriculture (USDA), and the National Organic Standards Board, to garner support and federal resources for organic programs, organic research, and plant breeding to benefit organic farmers. In addition, our collaborative efforts are aimed at keeping the organic standards strong, to ensure they are consistent and enforced across the board, and to work for continuous improvement in the standards. NOC believes that strong standards keep family farmers in the game and ensure that organic is valuable for all scales of businesses.

Our coalition is unique because we operate with a consensus model – a model that is often challenging given the wide range of perspectives represented within our diverse coalition. But our consensus process allows us to develop well-vetted policy positions and proposals that are informed by multiple viewpoints and have support across stakeholder groups. This type of cross-sector collaboration is especially valuable in our work at the National Organic Standards Board (NOSB), a citizen board that advises the USDA on issues related to the organic standards and has statutory authorities under the Organic Foods Production Act of 1990 (only materials recommended by the Board can be put on the National List of Approved and Prohibited Substances). The NOSB, which has 15 seats with slots reserved for different stakeholder groups, must also develop proposals that can garner widespread support because proposals need a 2/3 majority to pass (10 out of 15 board members must vote in favor for a proposal to move forward to the USDA as a formal recommendation). This requirement for a 2/3 majority also helps ensure that the voices of small and mid-size operations are heard and represented through the NOSB process because of the delicate balance of stakeholder seats on the board, including seats occupied by small or mid-size farmers. It has been a basic principle of the NOSB that no one group should dominate over the others.

NOFA’s participation is invaluable to our coalition work The Northeast Organic Farming Association Interstate Council is a long-standing and actively engaged participant in NOC. NOFA brings to NOC a strong grassroots voice from the thousands of farmer and citizen members who participate in NOFA chapters across 7 Northeast states. NOFA’s engagement in NOC also helps us pack a punch in our work on the Hill. NOC members, including NOFA, are represented on the hill by our DC-based policy director, Steve Etka, whose depth of experience and extensive network of contacts are an invaluable asset in our efforts to advance organic and protect the integrity of the program. Steve Etka has been working with NOC since our inception – for over 16 years.

The Northeast Congressional delegation includes key champions for organic agriculture. Senator Leahy of VT, is an author of the 1990 organic law and senior member of both the Senate Appropriations and Agriculture committees. From NY, Senator Gillibrand (D-NY) and Representatives Faso (R-NY) and Maloney (D-NY) are crucial on the Agriculture committees, and Sen. Schumer (D-NY) has been a strong advocate of organic. From CT, Senator Murphy (D-CT) and Representative DeLauro (D-CT) are vital in their roles on the Senate and House Appropriations committee. From NH, Senator Shaheen (D-NH) serves on the Senate Appropriations Committee and Representative Kuster (D-NH) is on the House Agriculture Committee. From MA, Representatives McGovern is on the House Ag Committee and Representative Clark is an appropriator. NOFA’s participation in NOC is essential given the critical role of these members of Congress in the Farm Bill and Appropriations processes.

Wins for Organic
NOC has also achieved wins for organic through the Farm Bill process, despite unfavorable odds. For example, in the 2014 Farm Bill, NOC worked with Congressional allies to reinstate funding for the National Organic Certification Cost Share Program after the program was eliminated in the House bill. The certification cost share program is especially important for small and medium scale operations, for whom annual organic certification fees can be cost-prohibitive. NOC believes diversity of scale within organic certification is essential to protect the integrity of the organic seal.

In the 2014 Farm Bill, we also secured mandatory funding for organic research and a one-time infusion of funds to create the Organic Integrity Database at the USDA. NOC is optimistic that we will see a boost in funding for organic research plus enhanced provisions to address organic import fraud in the 2018 Farm Bill. We are encouraged by the leadership role that House Ag Committee member John Faso (R-NY) has taken by introducing the Organic Farmer and Consumer Protection Act and the bipartisan nature of these Farm Bill provisions. Here, again, NOFA’s advocacy, and specifically the work done by NOFA-NY, has been important in securing support from Representative Faso.

Regulatory Hurdles
The National Organic Coalition has been a strong proponent for continuous improvement in the USDA organic program. As the organic industry grows and evolves, regulatory improvements are critical to ensure consistency in the standards and a level playing field. The regulatory changes made in 2010 to clarify access to pasture (the ‘pasture rule’) are one such example where NOC and NOC member organizations successfully advanced changes to strengthen and clarify the organic regulations. This regulatory improvement is a big achievement. However, NOC is currently concerned that in some cases enforcement of the pasture rule is falling short and we are urging USDA to take immediate action to bring bad actors in the dairy sector and their organic certifying agents into compliance.

While promulgating new organic regulations has been challenging under previous administrations and in all political environments, the current Administration’s focus on pulling back regulations presents an added barrier to ensuring the integrity of the USDA organic seal. There are several key areas where NOC believes regulatory improvements are essential:

Import Fraud – eliminating the exclusion from certification for uncertified entities is one of the most important actions that can be taken to increase the integrity in the global organic control systems.

Poultry – NOC is strongly opposed to the withdrawal of the Organic Livestock and Poultry Practices rule. Unequal enforcement of federal organic standards has long been a problem in the organic poultry and egg sector.

Dairy – Another regulatory issue that must be addressed relates to the transition of dairy cows into organic. OFPA requires organic milk and dairy products labeled as organic to come from dairy cows continuously managed as organic from the last third of gestation. However, in recognition of the short supply of organic dairy breeder stock in 1990 when the law was passed, an allowance was included for a one-time conversion of conventional dairy cows to organic as long as they are managed organically. Unfortunately, with two interpretations of this provision, it has turned into a loophole that has allowed some dairy operations to circumvent the last third of gestation requirement altogether, and to bring conventionally managed animals into their operations on a continuous basis. In 2015, USDA proposed an Origin of Livestock rule to clarify that section of the law and ensure consistent enforcement of the standards, but USDA currently has no plans to finalize the rule.

Hydroponics – It is NOC’s view that hydroponics/aquaponics/aeroponics systems do not meet the letter or spirit of the OFPA and should not be allowed in organic production. The USDA should halt the continued certification of hydroponic systems until specific regulations for these types of operations go through the NOSB recommendation process and are then adopted through the proposed and final rule process.

How can we make progress in the current political environment?

We are facing new challenges and these new challenges demand new tactics. More farms and businesses, including conventional agribusinesses and manufacturing companies, want to take advantage of the market opportunity and premiums that the USDA organic seal provides.How can we ensure that the organic seal, which was born out of our grassroots movement to transform our food system, remains true to its founding principles? The framework we have established with the Organic Foods Production Act of 1990 provides us with a strong foundation.

NOC asserts that abandoning the foundation we have already laid with the organic law and organic regulations is irresponsible and could leave us in a weaker position given our broader vision of transformation. NOC’s approach in this political environment is focused on cultivating champions for organic on both sides of the aisle; we will continue to increase our grassroots reach in key states and grow our power to influence key decision-makers at the USDA and in Congress to address gaps in the enforcement of organic standards and to demonstrate the value of organic regulations.

NOC also believes we need to work equally hard using multiple tactics simultaneously and in multiple arenas to re-gain full integrity of our organic certification system – legal, marketplace, legislative, administrative, grassroots and media outreach strategies are all components of our much-needed campaign to win back our standards. We support efforts undertaken by other groups in other arenas. However, the entire organic community needs to make sure these efforts are coordinated, synergistic and do no harm to the thousands of family farmers and businesses already adhering to the existing organic standards, both in spirit and to the letter of the law.

NOC invites you to become more engaged in protecting the integrity of the USDA organic seal. Sign up here to get updates and action alerts: www.nationalorganiccoalition.org