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Dear Secretary Vilsack :

We are highly disturbed by the arrogance exhibited by the current management at the National Organic Program. We hope you will re-examine recent unilateral changes that have been made that undermine the collaborative public participation Congress intended when they passed the Organic Foods Production Act (OFPA) of 1990.

There is little doubt that some of these changes, specifically to sunset, violate the intent of Congress (as illustrated by the letter Sen. Leahy and Rep. DeFazio, OFPA’s two primary authors, sent you two weeks ago).

The Cornucopia Institute has some recommendations regarding the National Organic Standards Board (NOSB) that we are, once again, offering to you for your consideration. Our motivation is to partner with the Department in creating a truly exemplary program, as Congress envisioned, protecting the integrity of the organic label.

This year, as you know, four new members will be appointed to the NOSB. When Congress passed OFPA, they designated membership slots on the NOSB for various constituencies involved with organic food and agriculture. We believe that past appointments to the NOSB have not always been legally in line with the slots for which the individual was appointed. For example, an employee of the General Mills corporation was proposed for appointment to the NOSB as a consumer representative by the previous administration. The proposal generated such an uproar in the organic community that the individual proposed for the seat withdrew her nomination (she was, however, later appointed to the Board as a scientist representative).