NOP

Material Sunset Process Announced by USDA will Break Regulatory Logjam

The USDA National Organic Program (NOP) last week posted a plan to update the National Organic Standards Board (NOSB) material “sunset review” process to address a broken system that has challenged the organic community for some time. We believe that this proposal will break some of the existing regulatory logjam and allow the NOSB to focus on larger issues that matter to organic consumers and producers.

Planting Stock Guidance from NOP

On February 28, 2013, the National Organic Program (NOP) issued Guidance Document NOP 5029, "Seeds, Annual Seedlings, and Planting Stock in Organic Crop Production." This final guidance describes the NOP’s direction to the industry and certifiers regarding how these materials may be sourced and treated, and specifying which records are necessary in order to meet the USDA National Organic Standards. In general, few substantial changes affect CCOF annual crop producers.
 

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Practices, Not Paperwork Initiative

In the last six months CCOF has been in an ongoing dialogue with the National Organic Program (NOP) and USDA about issues we see in the certification and accreditation process that are overly reliant on paperwork and unnecessarily drive up costs. We are concerned that small operators may be leaving the NOP due to both the difficult paperwork and costs of organic certification.

Elaboration on CCOF's Comments on the Proposal to Extend the Expiration Date for Oxytetracycline

CCOF is committed to ending the use of antibiotics in organic fruit production. We believe that a longer time period is necessary for oxytetracycline than the current 2014 expiration date because of the continuing research in varying locations and seasons that would ensure success, the need for registration of new materials, and enough time for grower education and outreach. We would like to see an extension in the range of 2017 to 2020 for phase out; however, we support the majority position to extend the expiration date for the use of oxytetracycline to October 21, 2016.

NOP Improves Organic Integrity

Recently, the NOP issued final rules and instructions to certifiers that provide important improvements to certification and require certifiers to raise the bar for both unannounced inspections and testing. These efforts help ensure that organic certification is rigorous and meaningful in the marketplace while guaranteeing that all NOP certified operations and certifiers are required to meet similar requirements. CCOF has performed both unannounced inspections and residue testing for some time and is therefore pleased to see these requirements effectively instituted by NOP.

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Update on Allowance of Sodium Nitrate for Crop Production

Sodium (Chilean) nitrate is currently allowed for use only so long as it is not more than 20% of the crops total nitrogen needs. This material is scheduled to sunset (come off) the list of prohibited natural materials in October. The National Organic Standards Board has recommended that it be relisted as completely prohibited; however, proposed rulemaking has not yet occurred, meaning that final rulemaking will not be achieved before the October deadline. The material will then come off the list and will be allowed without a specific restriction on quantity.

Updates to National List of Allowed and Prohibited Substances

Earlier this year, the National Organic Program published a final rule renewing over 200 listings on the National List of Allowed and Prohibited Substances that were scheduled to expire this year. The rule also made changes to the substances listed below. CCOF has contacted affected clients directly; however, if you use any of the materials listed below and have additional questions, please contact us.

Changes to Requirements for Organic Package Labels

A recently released NOP notice may require you to take action! Please review the labeling changes carefully and contact us at ccof@ccof.org or (831) 423-2263 if you have questions.

By January 1, 2014, all package labels for organic products must state "Certified Organic by CCOF" BELOW the name and contact information for your operation.

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