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Soil Health and Farm Finances | Building Consumer Trust | NOSB Preview

“I’m a dirt person. I trust the dirt. I don’t trust diamonds and gold.”  ~Eartha Kitt

Featured Topic: Building Consumer Trust

It’s easy to forget that a normally unexciting regulatory process—such as National Organic Standards Board review of materials every five years—has consequences for consumers with every organic bite they take. Those consumers bring their expectations to the table, literally and figuratively. W&A’s own Joe Dickson took a moment to talk to us about consumer expectations and building trust as the era of Strengthening Organic Enforcement gets underway.

In the time since the organic regulations were enacted, how has consumer trust changed?

One of the biggest things that has changed in the last 20 years is the speed that information travels. Consumers now have information at their fingertips and the ability to fact check. We’ve also got advocates and influencers keeping an eye on brands and sharing findings that have undermined consumer trust in big brands.

What are the organic standards development and certification processes doing right to encourage consumer trust?

When USDA took on organic standards, it was a little bit of a trade off. The organic community gained credibility by having government enforcement with the full rigor and teeth of the federal government behind the standards. From a trust perspective, we gained concrete rules and real enforcement. On the flip side, because the government doesn’t have the agility to change direction quickly, we’ve fallen behind in some consumer expectations. We’ve lost the ability to quickly evolve the organic standards to meet consumer expectations. We see that with the Organic Livestock and Poultry Practices standards. The National Organic Standards Board passed an unanimous recommendation for it in 2012, and it’s still not a regulation. Consumers who have heard that animals don’t have great living conditions on some organic farms have genuine concerns.

The other big trade off is marketing the organic seal. USDA doesn’t have the same marketing apparatus as private industry does, so it falls on organic brands to help consumers understand the benefits of organics. There’s so much to tell about the benefits that it’s hard to get the message across. One group that’s done a great job distilling the benefits of organic is Organic Voices/Only Organic.

What could be improved?

With all the work USDA and the National Organic Program is doing on Strengthening Organic Enforcement, and the issues that led to it, consumers have heard about the potential for fraud. Imported products are a vulnerability, and the new standards increase scrutiny on imports. I think the NOP is now taking real substantive action on vulnerabilities, whether they are real or perceived.

Beyond organic, consumers are keenly aware that ‘cleanwashing’ and ‘greenwashing’ exist. Brands have to be honest, and make clear, specific measurable promises about their ingredients and how they are safeguarding human health and the environment, and they have to engage in a real dialogue with consumers in what they want and need. The promises we make on labels need to be factual and relevant. It’s all about taking a consumer promise and making sure it’s true.

Joe DicksonFor over 20 years, JOE DICKSON has driven the creation of innovative standards, certification programs and educational content that helps shoppers, brands and retailers align consumer intent with real impact throughout the supply chain. He served on the National Organic Standards Board from 2010-2015 and has established a solid track record of developing standards and certification programs in food, agriculture, cosmetics and textiles. Joe has built his career developing rigorous standards and accessible, relatable information that builds deep trust between consumers and brands. He will be speaking on “Building Consumer Trust in an Era of Consumer Skepticism” September 29 as part of Radicle Science’s Radicle Perspectives series. Register here.

NOSB Fall Meeting Preview

NOSB Fall Meetings Will Be October 17, 19 and 24-26
The National Organic Standards Board Fall 2023 meeting will be held live online and in person from 10 a.m. to 5 p.m. Eastern time October 24-26. The meetings are free and open to the public, and registration is not required unless you wish to provide public comment noon- 5 p.m. Eastern on October 17 or 19. Sign up to make a live online public comment as soon as possible, but no later than September 28, 2023. Each person may sign up for only one three-minute speaking slot on October 17 or 19, and date preference requests will be accommodated if possible.

The meeting agenda includes reports from the USDA and the NOSB board discussions.

Please take the time to submit comments, especially if any material up for sunset review is one your business uses. Materials face the prospect of elimination from use if the NOSB does not see evidence that they are necessary for organic agriculture or production. Written comments are due September 28 and may be submitted online via, Docket # AMS-NOP-23-0026.

Agenda Overview

Crops Subcommittee


  • Potassium sorbatepetitioned for use as an active ingredient for plant disease and insect control/suppression in field and greenhouse applications. NOSB requests comments on potassium sorbate’s efficacy as an insecticide or plant disease control.

2025 Sunset Substances Review

For some materials (in italic), NOSB has asked for additional stakeholder input. See the committee materials for details. The committee will vote on these materials at the Fall meeting.

§205.601 Sunsets: Synthetic substances allowed for use in organic crop production:

As algaecide, disinfectant, and sanitizer, including irrigation system cleaning.

  • Alcohols: Ethanol
  • Alcohols: Isopropanol
  • Sodium carbonate peroxyhydrate—restricted to approved food uses

As herbicides, weed barriers, as applicable.

  • Newspaper or other recycled paper, without glossy or colored inks—also under consideration as compost feedstock.
  • Plastic mulch and covers.

As insecticides (including acaricides or mite control).

  • Aqueous potassium silicate
  • Elemental sulfur
  • Lime sulfur

As slug or snail bait.

  • Elemental sulfur

As plant disease control.

  • Aqueous potassium silicate
  • Elemental sulfur
  • Lime sulfur
  • Hydrated lime

As plant or soil amendments.

  • Elemental sulfur
  • Liquid fish products —can be pH adjusted with sulfuric, citric or phosphoric acid. The amount of acid used shall not exceed the minimum needed to lower the pH to 3.5.
  • Sulfurous acid

As a plant growth regulator

  • Ethylene gas 

As a production aid

  • Microcrystalline cheesewax

205.602 Sunsets: Nonsynthetic substances prohibited for use in organic crop production:

  • Potassium chloride

Handling Subcommittee


2025 Sunset Substances Review

For some materials (in italic), NOSB has asked for additional stakeholder input. See the committee materials for details. The committee will vote on these materials at the Fall meeting.

§205.605(a) Sunsets: Nonagricultural (Nonorganic) substances allowed as ingredients in or on processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food group(s)).’’:

  • Calcium carbonate
  • Flavors
  • Gellan gum (high-acyl form only)
  • Oxygen
  • Potassium chloride 

205.605(b) Sunsets: Nonagricultural (Nonorganic) substances allowed as ingredients in or on processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food group(s)).’’:

  • Alginates
  • Calcium hydroxide
  • Ethylene
  • Glycerides (mono and di)
  • Magnesium stearate
  • Phosphoric acid
  • Potassium carbonate
  • Sulfur dioxide
  • Xanthan gum

205.606 Sunsets: Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic.”:

  • Fructooligosaccharides (FOS)
  • Gums – water extracted only (Arabic; Guar; Locust bean; and Carob bean)
  • Lecithin – de-oiled
  • Tamarind seed gum
  • Tragacanth gum

Livestock Subcommittee

2025 Sunset Substances Review

The committee will vote on these materials at the Fall meeting.

§205.603 Sunsets: Synthetic substances allowed for use in organic livestock production:

As disinfectants, sanitizer, and medical treatments as applicable.

  • Alcohols: Ethanol–disinfectant and sanitizer only, prohibited as a feed additive.
  • Alcohols: Isopropanol–disinfectant only.
  • Aspirin
  • Biologics–Vaccines
  • Electrolytes
  • Glycerin–allowed as a livestock teat dip, must be produced through the hydrolysis of fats or oils.
  • Phosphoric acid–allowed as an equipment cleaner, provided no direct contact with organically managed livestock or land occurs.

As topical treatment, external parasiticide or local anesthetic as applicable

  • Lime, hydrated–as an external pest control, not permitted to cauterize physical alterations or deodorize animal wastes.
  • Mineral oil–for topical use and as a lubricant

Materials Subcommittee

2023 Research PrioritiesNOSB’s annual list of research priorities for organic food and agriculture

Compliance, Accreditation & Certification Subcommittee



SOE Update

USDA Offers Quick Overview of Efforts to Strengthen Organic Enforcement
The United States Department of Agriculture’s Office of the Inspector General issued an informational report on the agency’s efforts to strengthen organic enforcement. Pages 4-5 provide a brief overview of what the Strengthening Organic Enforcement regulations require of businesses that work with organic products. The report also examines other actions USDA has taken to improve oversight of organic products, including risk-based oversight and enforcement, interagency coordination and intellectual property protection for the USDA Organic seal.

Strengthening Organic Enforcement Deadline Countdown
As of September 13, we are down to 27 weeks until the March 19, 2024 compliance date for the Strengthening Organic Enforcement regulations. That’s just 189 calendar days, or 128 work days. Given the way work can slow down around the end-of-the-year holidays, best to get going now. If you or your supply chain partners have need for additional support in getting ready, let us know.

Check Your Progress on SOE at Organic Grower Summit
Wolf & Associates COO John Foster will moderate a panel on “The SOE Deadline Looms—Are You Ready?” at the Organic Grower Summit November 29–30 in Monterey, California. Speakers will focus on navigating and adhering to the new Strengthening Organic Enforcement requirements for organic producers and handlers.

The all-star line up includes Dr. Jennifer (Jenny) Tucker, Deputy Administrator at USDA National Organic Program; April Vasquez, Chief Certification Officer for California Certified Organic Farmers; Meredith Kiser, Compliance Director at Heath and Lejeune; Theojary Crisantes, Chief Operating Officer at Wholesum; and Bianca Kaprielian, CEO and Co-Owner of Fruit World. Western Growers and the Organic Produce Network put on the Summit.

NOP News

Transition Program Web Site Now Available
For those interested in switching to organic farming, processing or handling, the USDA Transition to Organic Partnership Program’s new web site offers plenty of resources, including information about mentoring program, which is free to mentees and pays mentors. In addition, there are events and activities in each of the partnership regions.

More New Topics In the Organic Integrity Learning Center
In its efforts to ensure a highly skilled workforce for the organic sector, the National Organic Program has added topics to the Growing the Organic Workforce course on the Organic Integrity Learning Center:

  • Establishing a Cooperative Business: Resources for Organic Professionals 
  • Organic Inspector Recruitment Programs

Courses are free and self-paced.

International News

EU Will Not Create Rules for Organic Sea Salt
The European Parliament voted on July 11 to reject a proposal to create detailed production rules for organic sea salt and other organic salts for food and feed. In the absence of those rules, organic salt operators may be certified as organic on the basis of the principles and general production rules of Regulation (EU) 2018/848, and European Union Member States have the option to use detailed national production rules.

Wales to End its Organic Farming Support Program
As of December 2023, the Glastir Organic support program for organic farms will close. Organic farms will then have to apply to the Sustainable Farming Support Scheme. A new program is in the works, but details will not be available until the end of the year. Opposed to the move, the Soil Association reports that the changes will remove £3.1 million of support dedicated to organic farms. Within the United Kingdom, Wales has the highest proportion of land area certified as organic.

The Survey Says…

Building Healthy Soil Enhances Farm Economics
A nationwide study of 30 U.S. farms found that for 29 of those farms soil health management systems (SHMS) boosted net farm income by an average of $65/acre. (One organic farm was excluded from this average due to high revenue from price premiums.) Farmers interviewed for the study used a wide range of soil health management practices including cover crops, no-till, reduced till, strip till, rotational grazing, livestock integration, and manure incorporation.

The multi-year and data-driven collaboration among the Soil Health Institute, the National Association of Conservation Districts, and the United States Department of Agriculture Natural Resources Conservation Service also found:

  • On average, when implementing SHMS, it cost producers $14/acre less to grow corn, $7/acre less to grow soybean and $16/acre less to grow all other crops.
  • Yield increases due to SHMS were reported for 42% of farms growing corn, 32% of farms growing soybean, and 35% of farms growing other crops.

Farmers also reported additional benefits of adopting SHMS, such as decreased erosion and soil compaction, earlier access to fields in wet years, and increased resilience to extreme weather.

Sources of Organic Soil Nutrients Examined
In a study of nutrient needs of organic farms in Europe as the region ramps up its organic agriculture, researchers found that across the 71 farms studied, an average surplus of nitrogen, a small surplus of potassium, and a small deficit of phosphorus. However, based on farm gate nutrient balances, deficient nutrient supply was found on 24%, 66% and 56% of farms for nitrogen, phosphorus and potassium, respectively. The study concludes that “increasing the organic land base as planned will either require that more land be dedicated to legumes to secure a sufficient N supply (and consumer demand increases) or through the provision of more external inputs.” The authors suggest that the organic sector will need to reconsider sewage sludge, among other options, as a source of nutrients as more land shifts to organic production.

Young People Feeling Pressure to Use Food Choices to Change the World
Generation Z, those born between 1996 and 2010, are feeling stressed about their food choices, according to a survey from Ketchum Food Research. More than other generations, 63% of Gen Zers feel too much pressure to change the world and are more likely to believe their food choices need to signal their health, values and political beliefs. There is a significant gap between what they say and what they eat, with 76% saying that sustainability is in important factor, but only 16% reporting that they look for sustainably sourced ingredients when they buy. Meanwhile, 73% feel that food companies only care about profit, and 72% think the food system is broken.

Inside the Beltway

EPA Denies Petition to Tighten Water Pollution Regulations for CAFOs
The Environmental Protection Agency (EPA) has denied a 2017 petition from Food and Water Watch, Center for Food Safety and 31 others to revise the Clean Water Act regulations to address water pollution from concentrated animal feeding operations (CAFOs). Instead, the EPA will evaluate the Clean Water Act National Pollutant Discharge Elimination System for improvements, including a detailed look at the pollution reduction guidelines for CAFOs. EPA will also convene an Animal Agriculture and Water Quality subcommittee under the Farm, Ranch and Rural Communities Federal Advisory Committee to gather input to best address the water quality problems from CAFO discharges, a process expected to take 12-18 months.

Organic Community

#IGrowYourFood Event to Celebrate the World’s Organic Farmers
On September 14, organic and agroecological farmers are invited to share videos, articles, or photo stories explaining why they #LuvOrganic as part of the fifth annual I Grow Your Food Day. Policymakers, organizations, advocates and citizens then amplify their messages, re-post their videos, and join the conversation on how organic can be a pathway to true sustainability. The effort is part of the  #IGrowYourFood project. IFOAM-Organics International and the Intercontinental Network of Organic Farmers Organizations will hold a live stream discussion on September 14 at 7 a.m. EDT (1 p.m. Central European Summer Time) to celebrate the anniversary and discuss “Nourishing the world in times of crises- Farming and food production for the future.”

Congratulations to Organic Stewardship Award Recipients!
The Rodale Institute honored three outstanding individuals working toward an organic planet. This year’s recipients are

  • Mark Lipson, creator of the Organic Farming Research Foundation’s policy program and later a policy advisor to the Secretary and Deputy Secretary for organic and sustainable agriculture. He consults on food policy strategies as Pacific Plate Organics and is an Associate at Wolf & Associates.
  • Gene Kahn, founder of Cascadian Farm and the NOSB’s first Crops Committee chair. When he and his partners sold Cascadian Farm to General Mills, he became their first VP, Global Sustainability Officer
  • Chellie Pingree, represents Maine’s 1st  District in Congress and is a national leader in climate policy.

Congratulations one and all for the well-deserved honor!