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Dear Secretary Vilsack :

As former past chairs of the National Organic Standards Board (NOSB), we are writing to you to express our grave concerns regarding recent changes unilaterally enacted by the USDA’s National Organic Program that significantly erode the authority, independence and input of the NOSB.

This is a radical shift away from the collaborative governance of the organic industry that Congress had clearly intended and pioneering organic farming advocates demanded before they threw their support behind the Organic Foods Production Act of 1990.

In particular, we are voicing objections to the following re cent actions : 

> Deputy Administrator Miles McEvoy’s arbitrary announcement on September 13, 2013 dramatically changes the approval process for synthetic and non – organic materials allowed on the National List for use in organic food and agriculture. The changes to the “sunset provision” were made without any consultation with the NOSB (a deviation in precedent and required by law) or with organic stakeholders and the public. T he changes reverse years of accepted procedure employed by the NOSB to evaluate these materials as well as the policy for doing so that was publicly crafted, developed with organic stakeholder input, and effectively used by the NOSB to make decisions since its adoption in 2005.