By George Szczepanski, Director, Production, Supply Chain & Environmental Policy, International Fresh Produce Association
Originally printed in the April 2022 issue of Produce Business.
The International Fresh Produce Association (IFPA) believes that, together, we can create a vibrant future for all. This may seem a tall order, but the way can be simple: increase consumption of fresh fruits, vegetables and floral. Not only will our population benefit from the nutritious and safe products, but our businesses will thrive and prosper.
This is at the core of what we do: recognizing that our industry — which is rich with variety of both commodities and philosophies — exists because of and for our consumers.
This is one of the inputs we considered when drafting comments submitted to the National Organic Program (NOP) to advocate for the practices, policies and standards we believe are not only science forward, but also consider the needs of our industry and consumers. The NOP put out a call for comments to inform their upcoming standards development activities and to solicit feedback about specific recommendations received from the National Organic Standards Board (NOSB). Additionally, the NOSB received comments on the upcoming meeting, including the Sunset Review of allowed materials on the National List.
IFPA organics comments were created with expertise from our industry volunteers, members on the organic produce supply chain, and other industry stakeholders. In this case, the newly formed IFPA Organics Committee includes 17 passionate industry professionals. The group represents a variety of organic commodities, operation types and regions.
Here is a brief summary of the recommendations we submitted (the letters can be read in full on the IFPA website).
IFPA comments on the National List for NOSB:
- IFPA recognizes the role of the Sunset process in maintaining inputs and standards that align with organic standards philosophy. However, in recognizing the practical needs of our industry to remain financially viable, we encouraged science-based decision-making when considering sunsetting the materials on this list.
- IFPA recommends not to further restrict the use of Highly Soluble Nitrogen Fertilizers and Carbon Dioxide, which both allow produce growers (including greenhouse growers) to remain competitive and efficient.
- IFPA recommends the continued use of soap-based herbicides, biodegradable biobased mulch film (BBMF), boric acid, soluble boron product and other micronutrients essential to plant life cycles, squid products and more. These products listed in the comments are considered necessary tools for organic producers to address pests, increase soil health, or reduce food waste while maintaining the highest standards of product safety and sustainability of the soil.
- IFPA also recommends, to maintain the trust in NOSB, technical support to the organization should be limited to public agencies and vetted scientists who understand impacts of regulatory actions and are removed from the influence of partisan organizations.
IFPA comments on NOP Public Listening Session:
- IFPA encouraged continued consultation and collaboration with sister agencies such as the U.S. Environmental Protection Agency (EPA), U.S. Food and Drug Administration (FDA) and others to aid in the science-based decision-making process when addressing NOSB proposals.
- IFPA also stressed the need to improve clarity of some aspects of the certification process, to eliminate discrepancies and subjectivity on the part of certifiers when ensuring applicants meet the standards of the organic program.
- IFPA advocated NOP not adopt the NOSB recommended standards for organic mushroom production. The standards would severely limit the availability of organic mushrooms, and do not consider the unique growing needs and benefits of mushrooms.
- IFPA also advocated to maintain the current NOP position on organic seed, recognizing the recommendations are sufficiently addressed and further mandates would decrease the availability of product based on availability of organic seed and the cost.
Clarity is a theme in many of these recommendations and this lack of clarity may reflect the competing philosophies around organics. On one hand, much of the regulation is driven by committed and established organic growers and producers. These parties are most interested in production practices, with many specifically focused on how we treat the soil. On the other hand, our consumers report a differing perspective on what organic means to them when they are purchasing and consuming our products. To our consumers, organics is about health, longevity and peace of mind, so any product that can deliver that need has a role.
It’s clear that organic regulations need to evolve. To some, that evolution is toward a more restrictive and defined seal that limits the tools and types of growing operations. To others, that evolution is to bring the two philosophies of our consumer understanding and industry practices closer together. This would require a combination of consumer education and a clarification of policy to consider a practical application of standards that also support the financial viability of the organics segment. For the organic seal to thrive, innovation must also be cultivated, and a diverse set of organic produce production practices must be embraced.