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Letter to Tom Vilsak – April 2021

Today, on Earth Day 2021, Francis Thicke, a leading pillar of the organic farming community and former member of the National Organic Standards Board (NOSB) spoke on behalf of 40 other former NOSB board members. Together they wrote to current USDA Secretary Vilsak to voice their “concern that the integrity of the National Organic Standards has eroded significantly over the years”.

The full letter can be read by clicking here   We’ve copied excerpts below:

“In some cases the Standards have devolved from the original intention of OFPA, as in the example of enclosed poultry porches substituting for outdoor access. In other cases, a lack of strong enforcement of existing standards has led to well-documented cases of fraud and an economic burden on organic operators who follow the rules, versus those who do not. We think the erosion of the Organic Standards is in violation of the Organic Foods Production Act of 1990 and is undermining consumer confidence in the integrity of organic food and the confidence of real organic farmers in the integrity of the USDA National Organic Program. 

In the last eleven years, the National Organic Program has failed to successfully bring a number of key NOSB recommendations to rulemaking. This failure has led to real damage to trust in and the integrity of the organic program, as the NOP has failed to respond to serious challenges to the meaning of organic from industry. We urge you to take immediate action on the following NOSB recommendations;

  1. Production Standard for Terrestrial Plants in Containers and Enclosures (Greenhouses), passed in 2010.
  2. The USDA published a proposed rule to close the loopholes related to ‘Origin of Livestock’ (80 FR 23455) in 2015

Furthermore, we call on the USDA to take immediate action to enforce those standards which have been inadequately enforced. 

  1. The Pasture Compliance Program. Public trust in the USDA organic seal is faltering due to highly public examples of poor enforcement of the Pasture Rule on large CAFO operations. The 2017 series of articles in the Washington Post have brought tremendous scrutiny to this problem. These large producers should be required to be exemplars of the rule.

2. Grain Fraud. Despite significant Congressional funding to stop fraud in imported grain certified as organic, there has been little regulatory action taken to alter this failure. Action should be taken immediately to protect both American farmers and consumers.

While this letter contains key issues, there are other issues of importance not raised here. The National Organic Program can only thrive if it is built on public trust. This trust relies on the integrity and transparency of the National Organic Program. We NOSB members and the organic community have invested years in trying to protect the National Organic Program. We urge the USDA to act on these NOSB recommendations aimed at enhancing the foundational goals as spelled out in the Organic Food Production Act.

Signed by the following former members of the National Organic Standards Board: 

Michael Sligh (1992-1997) 

Robert Quinn (1992-1995) 

Fred Kirschenmann (1995- 2000) 

Joan Gussow (1996-2001) 

Eric Sideman (1997-2002) 

Owusu Bandele (2000-2005) 

Jim Riddle (2001-2006) 

Dave Carter (2001-2006) 

Goldie Caughlan (2001-2006) 

George Siemon (2001-2006)

Ann Cooper (2002-2004) 

Dennis Holbrook (2002-2007) 

Nancy Ostiguy (2002-2007) 

Hubert Karreman (2005-2010) 

Jeff Moyer (2006-2001) 

Joe Smilie (2006-2011) 

Daniel Giacomini (2006-2011) 

Jennifer Hall (2006-2011) 

Kevin Engelbert (2006-2011) 

Steve DeMuri (2007-2012) 

Katrina Heinze (2007-2012) 

Kristine Ellor (2007-2012) 

Barry Flamm (2008-2013) 

Jay Feldman (2010-2015) 

Wendy Fulwider (2010-2015) 

Joe Dickson (2010-2015) 

Calvin Reuben Walker (2011-2016) 

Robert (Mac) Stone (2011-2016) 

Jennifer Taylor (2011-2016) 

Colehour Bondera (2011-2016) 

Nicholas Maravell (2011-2016) 

Zea Sonnabend (2012-2017) 

Harold Austin (2012-2017) 

Tracey Favre (2012-2017) 

Francis Thicke (2013-2018) 

Paula Daniels (2015-2015) 

Harriet Behar (2016-2020) 

Jesse Buie (2016-2021) 

Emily Oakley (2016-2021) 

Dan Seitz (2016-2021) 

Dave Mortensen (2017-2020)

We hope today’s Earth Day letter is the first of many ripples outward to bring back the original intention of the organic standards after a 2017 vote at the NOSB. That vote was also the end of Francis Thicke’s term.

His departing comments are worth the re-read. View those by clicking this link.