Residue Testing, Certifications, Crop Insurance Among Issues Addressed by IFPA in Recent NOSB Comments

October 3, 2024

Washington, DC – In response to industry feedback sought by the National Organic Standards Board (NOSB) Fall Work Agenda, the International Fresh Produce Association (IFPA) addressed a myriad of topics and concerns in comments developed in collaboration with the organization’s Organics Committee.

“We appreciate the opportunity to comment and strongly encourage the NOSB to consider fresh produce growers when considering regulatory actions and votes that will impact the specialty crop community,” said IFPA Director of Production & Environmental Policy Sara L. Neagu-Reed. “Our members rely on a wide variety of methods and production inputs for various crops, growing regions, and production methods in organics and they must continue to have access to tools and substances to ensure crop viability and prosperity.”

Among the topics addressed in IFPA’s comments were:

Residue Testing for a Global Supply Chain

IFPA cited the need for certifiers to understand laboratory sampling guidelines given some facilities have specific considerations regarding sampling procedures (time, temperature, quantity, etc.). With respect to third-party testing, the organization urged that these entities are properly certified and work with expert laboratories with AOAC accreditation to develop standard operating procedures that boost confidence in the samples, chain of custody and labeling. IFPA recommended that any outsourced samples be done in lab from an approved state or federal list of accredited laboratories.

IFPA highlighted its ongoing work with the U.S. Environmental Protection Agency and U.S. Food and Drug Administration on the process for establishing and updating tolerances and action levels outside of common pesticides. “We recommend that if residue testing detects a prohibited material above 0.01 ppm, the certifier must notify the operation that the product may not be sold as organic and issue a non-compliance,” said Neagu-Reed.

Consistency in Organic Seed Use

In response to the NOSB seeking better understanding the nuance of the organic seed sector, IFPA stated its members do not find it difficult to comply with the current organic standards for seed use given the flexibility to use conventional untreated seed as an alternative; however, IFPA noted that while compliance and current requirements take administrative time, the biggest challenge is a lack of new market development of viable organic seed. The organization welcomed the opportunity to continue discussing the research and market development needs to improve organic seed quality and quantity in the commercial market.

Climate-Induced Farming Risk and Crop Insurance

IFPA noted that its members appreciate the NOSB’s recognition of how critical risk management and insurance options are, given they are tailored to the specific risks generated through organic production. Although producers find that low enrollment in crop insurance can be attributed to factors such as the lack of accurate data for product creation or insurance costs vs. insurance payouts, IFPA stated growers are interested in creation of a crop insurance policy when certain considerations are made around quality, condition terms, and pricing. Neagu-Reed noted that “insurance coverages must be equitable to those of conventional products to reduce creation of an unintended barrier to entry.”

Risk-based Certification

IFPA believes a uniform and consistent approach to risk-based organic certification may be difficult to implement and enforce and recommended that the National Organic Program be more agile in incorporating more risk mitigation measures into organic standards, but only if the new measures result in less audits and improved equity as an added benefit.

Other topics addressed in IFPA’s comments were compost production for organic agriculture and production inputs including carbon dioxide, pear ester, hydrogen peroxide, ammonium soaps, horticultural oils, pheromones, ferric phosphate, potassium bicarbonate, magnesium sulfate, potassium phosphate, as well as inert ingredients in pesticide products.

For additional insight into IFPA’s efforts on behalf of the organic fresh produce community, including advocating for a new Farm Bill that includes organic policies that support the growth of the industry, visit the Organic Policy area of the organization’s website.

Residue Testing, Certifications, Crop Insurance Among Issues Addressed by IFPA in Recent NOSB Comments

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