CCOF wrote to the USDA

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