CCOF wrote to the USDA

November 29, 2012The Honorable Kathleen MerriganDeputy Secretary, U.S. Department of Agriculture1400 Independence Ave., SWWashington DC, 20250Dear Deputy Secretary Merrigan,As the USDA National Organic Program (NOP) reaches the significant milestone of its 10 th anniversary, wewanted to take this opportunity to congratulate the USDA on the significant milestones achieved andacknowledge the opportunities before us.Since 2002, the organic marketplace has seen tremendous growth and expansion. This has benefitedfarmers, processors, and consumers alike. The organic sector is making positive contributions to theenvironment, the economy, and jobs creation. The NOP has standardized requirements, providedoversight, and strengthened enforcement, paving the way for such growth.In order for the organic sector to continue to thrive, we need to work at maintaining diversity of scale andscope. The USDA 2010-2015 Strategic Plan calls for increasing the number of organic farmers in thecountry to 20,655 by 2015. While overall trends for numbers of certified organic operations areincreasing (16,564 in 2010 and 17,281 in 2011), we continue to see high attrition numbers. A 2008report, "Factors Associated with Deregistration Among Organic Farmers in California" by L. Sierra, K.M.Klonsky, R. Strochlic, S. Brodt, and R. Molinar of UC Davis, California Institute for Rural Studies, noted anumber of reasons for such attrition, and found burdensome paperwork to be at the top of the list.CCOF periodically surveys our certified members, whose views we believe are reflective of certifiedoperations more broadly. Overall, members are satisfied with the services that they receive from CCOF.However, there are concerns expressed which we take very seriously. Concern regarding paperwork, feesand response times are all consistent and related threads in survey responses. Feedback indicates aperception that paperwork is redundant or duplicative, and that certification costs are particularlychallenging for small operations (which comprise nearly sixty percent of our certified members).The ever increasing processes and paperwork required to verify organic compliance drives the cost ofcertification up for the certifier, which results in increased cost to the farmers and other organicoperations. We believe that some of the processes are procedural and are not adding additional value interms of verification of organic practices. As a non-profit certifier, CCOF Certification Services, LLC worksto keep costs as low as possible, particularly at entry levels. Through our other programs, CCOFconsistently advocates for funding of the National Organic Certification Cost Share program. We arecommitted to ensuring integrity of organic standards and certification. However, we are concerned theorganic sector will not meet the USDA goals for growth of organic operations without additional action tostreamline the process to simplify cost and paperwork that are particularly burdensome for smallgrowers.As part of our effort to partner with USDA in addressing these challenges, our certification organizationCCOF Certification Services recently submitted the attached letter to Miles McEvoy, Deputy

Administrator of the NOP, outlining some of our recommendations on how the NOP can work withcertifiers to increase the focus on organic practices while decreasing the emphasis on paperwork.Our suggestions included:1. Support Practices Not Paperwork in Instructions to Certifiers2. Support Operations Responding to Onsite Situations3. Support Use of Tools other than Noncompliance4. Support Updates to OSP During Inspection5. Support Certifier Assistance in Completing & Modifying OSP6. Support and Encourage Electronic Documentation Systems7. Support Simplified Continuation of Certification Processes8. Support Collaboration Between Certified Operations and Certifiers9. Discourage Reliance on “Described in the OSP”10. Support Increased Inspector QualityWe hope you will encourage and support the NOP in moving toward implementing theseimprovements.Looking to 2013 and beyond, we would also like to continue working with the USDA on the followinggoals for organic producers and handlers to be more competitive in today’s marketplace.1. Keeping organic relevant. The organic seal must remain the “gold standard” among theincreasing array of competing labels. In order to do this, we need to make sure the philosophy ofcontinuous improvement remain an integral aspect of organic standards. Organic standardsshould be expanded to address broader issues of sustainability (energy efficiency and renewableenergy usage, sustainable packaging, etc.), animal welfare, and social justice. We would alsoencourage the agency to protect and support the organic brand in the marketplace.2. Expanding interagency partnerships. Great strides have been made in this area, not the least ofwhich is the recent Organic Literacy Initiative. The USDA should continue to offer high levelcoordination among agencies to ensure that organic producers receive equal access to USDAprograms and services that will increase their competitiveness and ensure the USDA strategic goalof increasing the number of certified organic farms in the US is met. This includes increasingaccess to loans, export assistance, extension, and NRCS cost sharing and technical assistance. Forexample, by creating a formal “transitional” status for organic, the NRCS would have a benchmarkfor those wanting to use conservation programs to transition to organic. In addition, interagencysharing of price data could help to strengthen organic crop insurance coverage. Informationregarding organic compliant and experimental treatments for invasive pests should be regularlyprovided to the Animal Plant Health Inspection Service (APHIS).3. Promoting public procurement of organic food. The USDA should strengthen relationshipswith other federal agencies to increase procurements of organic food and ingredients for publicinstitutions such as schools, hospitals, cafeterias and other facilities with food services.4. Expanding interagency partnerships around food safety. USDA should continue to work with2

FDA to ensure food safety regulations for the Food Safety Modernization Act (FSMA) arecompatible with organic farming practices. The USDA should provide educational resourcesspecifically to assist organic farmers in developing and implementing scale-appropriate foodsafety plans and with resources specifically for organic farmers.5. Preventing GMO contamination. USDA should continue and strengthen its leadership role inprotecting organic farms from GMO contamination by increasing coordination among agenciesand contributing to policy solutions. We believe that research in co-existence approaches andseed supply, such as the priorities identified in the AC21 recommendations, are particularly ripefor agency coordination.6. Updating the Organic Food Production Act (OFPA). The NOP should periodically review OFPAand make recommendations to Congress regarding necessary revisions, particularly related toany obstacles to maintaining organic as a gold standard while ensuring the program works forsmall operations. Delay of the 2012 Farm Bill may offer an opportunity for consideration ofrecommendations beyond needed enforcement authority.There is no question that in this economy there are many opportunities for the public sector to invest tocreate growth and efficiency in the organic sector. Continued rapid growth of the organic sector – evenduring economically challenging times and with relatively little direct financial support from the publicsector—demonstrates that there is vast opportunity to provide consumers with more agricultural choiceswhile creating jobs and promoting environmental sustainability.CCOF Director of Policy and Programs Brise Tencer and I look forward to the continued partnership withUSDA to achieve these goals.Thank you for consideration.Sincerely,Cathy CalfoExecutive Director/CEOCC:Mark Lipson, Organic and Sustainable Agriculture Policy AdvisorMiles McEvoy, National Organic Program Deputy AdministratorEnclosure: CCOF Letter to NOP- Practices Not Paper3