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Policy Comments

July 14th, 2016
CFS comments to USDA on the proposed rule for organic animal welfare standards
October 8th, 2015
Center for Food Safety Comments to the National Organic Standards Board
July 27th, 2015
CFS Comments to the U.S. Department of Agriculture re: Origin of Livestock Rules in Organic
July 27th, 2015
CFS Comments to the U.S. Environmental Protection Agency to discontinue Critical Use Exemptions for methyl bromide and finally eliminate the use of this hazardous, ozone-­‐depleting chemical (Docket No. EPA-HQ-OAR-2014-0743)
April 7th, 2015
Center for Food Safety comments to the National Organic Standards Board regarding synthetic methionine, "organic" aquaculture, nanotechnology in organics, GE contamination prevention and other issues.
October 7th, 2014
Comments to the National Organic Standards Board (Docket: AMS-NOP-14-0063-0001)
April 8th, 2014
CFS comments to the National Organic Standards Board on presumption of limited synthetics, synthetic material use in aquaculture, synthetic methionine in organic poultry feed, GE contamination prevention and seed purity, the use of streptomycin in organic apple and pear production, and organic research priorities.
March 4th, 2014
CFS comments regarding USDA's Federal Register Notice on "Enhancing Agricultural Coexistence" between organic, conventional and genetically engineered crops.
November 19th, 2013
CFS comments on the Food Safety Modernization Act (FSMA) proposed Produce Rule address the major areas in the draft Rule that would unfairly, and without scientific basis, impinge upon the integrity of organic production systems and pollinator habitat
October 31st, 2013
CFS letter to Farm Bill conferees urging passage of a Farm Bill that protects pollinators, organic farmers and our ability to safeguard public health and the environment
October 21st, 2013
CFS comments to the National Organic Program opposing the inclusion of biodegradable bioplastic mulch on the National List of materials allowed for use in organic farming because research has not conclusively demonstrated that it can biodegrade in the field.
October 1st, 2013
CFS comments to the National Organic Standards Board regarding sunset policy; streptomycin; synthetic methionine in organic poultry feed; aquaculture synthetic materials; conflict of interest; and confidential business information (Docket No. AMS-NOP-13-0049)
June 3rd, 2013
CFS comments to USDA outlining objections to the draft National Organic Program (NOP) Sunset Review Rules (AMS-NOP-11-0003; NOP-10-13PR) and to the improper procedures used to draft the rules.
March 19th, 2013
CFS comments to the National Organic Standards Board regarding antibiotics in apple and pear growing, sugar beet fiber, excluded methods and genetic engineering, among other issues
September 24th, 2012
Center for Food Safety comments to NOSB regarding conflict of interest; public communications; biodegradable bioplastic mulch; inert ingredients; infant formula additives; omnivore diets; biodiversity; and research priorities.
August 23rd, 2012
CFS Comments to the USDA Advisory Committee on Biotechnology and 21st Century Agriculture: Compensation is Not Protection from GE Contamination
May 3rd, 2012
Center for Food Safety comments to the National Organic Standards Board regarding GMO contamination of organic, GMO vaccines, animal welfare, aquaculture, inerts, carrageenan, public participation, and conflict of interest (Docket No. AMS-NOP-12-0017; NOP-12-06).
November 13th, 2011
CFS comments to the National Organic Standards Board regarding contamination of Organic by Genetically Engineered (GE) Organisms, Sulfites in Wine Petition, Aquaculture, Conflict of Interest, Transparency, and Public Participation.
September 30th, 2011
Center for Food Safety comments to the National Organic Program listening session on organic integrity, aquaculture, nanotechnologies and genetically engineered crops.
July 28th, 2011
CFS Comments to USDA on proposed National Leafy Greens Marketing Agreement (NLGMA). CFS believes that food safety is not just about eliminating microbial contamination from farms and processing facilities. It is also about looking at the full spectrum of factors that impinge upon delivering safe, healthy food to consumers across the U.S. and abroad. CFS does not believe that these values and practices that underpin a safe food system can be preserved with the introduction of a NLGMA that is driven by large-
April 10th, 2011
CFS comments to NOSB for April 26-19 meeting in Seattle, re: avoiding conflict of interest in NOSB decisions, prohibiting antibiotics in organic apple & pear growing, clarifying the definition of synthetics, improving animal welfare and slaughter standards and practices, and evaluating accessory nutrients in organic food.
November 19th, 2010
Comments to FDA from the National Organic Coalition opposing the introduction of GE salmon and urging mandatory labeling should the fish be approved.
October 12th, 2010
CFS Comments on National Organic Standards Board (NOSB) Materials Committee: Proposal from Materials Committee to the NOSB on Nanotechnology and Nanomaterials for discussion October 25-28, 2010.
April 12th, 2010
CFS Comments on National Organic Standards Board (NOSB) Materials Committee: Classifying Engineered Nanotech Materials as 'Synthetic' and Prohibiting Nanotechnologies and Materials in Organic.
March 3rd, 2010
Letter to USDA opposing deregulation of GE alfalfa from 300 farmers, organic producers and NGOs
May 4th, 2009
CFS comments to the NOSB regarding biodiversity, peer review and nanotechnology in organics
April 20th, 2009
CFS Comments on National Organic Standards Board (NOSB) Materials Committee: Nanotechnology in Organic Production and Discussion Document
December 22nd, 2008
CFS comments to USDA on proposed pasture standards for organic production
November 3rd, 2008
CFS comments to the National Organic Standards Board urging them to reject misleading proposals for organic aquaculture standards
September 4th, 2008
CFS Comments to the National Organic Standards Board Regarding Development of Organic Feed Standards for Organic Aquaculture
March 20th, 2008
CFS comments to the California Department of Food and Agriculture opposing urban aerial spraying to combat the light brown apple moth (LBAM)
March 3rd, 2008
CFS comments to USDA on proposed Naturally Raised label
February 14th, 2008
NOC letter to House and Senate Farm Bill conferees urging inclusion of the organic conversion program with mandatory access to funding in the 2008 Farm Bill.
February 6th, 2008
NOC letter to House and Senate Farm Bill conferees opposing the specialty crop marketing provision in the House version of the Farm Bill
November 12th, 2007
NOC comments to the National Organic Standards Board regarding organic certification of 'grower-groups' and multi-site operations
October 26th, 2007
COALITION OF MORE THAN 40 GROUPS SIGN LETTER URGING THAT 'USDA ORGANIC' STANDARDS BE UPHELD FOR AQUACULTURE
September 11th, 2007
Letter from CFS and allied organizations to the Certified Organic Associations of British Columbia's regarding their consideration of organic aquaculture standards in British Columbia, Canada.
July 17th, 2007
Letter to Reprentative Kagen supporting his amendment to the 2007 Farm Bill to increase funding for organic research
April 25th, 2007
National Organic Coalition letter to USDA Secretary Johanns regarding grower group certification under USDA organic standards
March 16th, 2007
CFS comments to the NOSB on organic aquaculture standards
March 16th, 2007
CFS comments to the NOSB opposing cloned animals and their offspring from inclusion under the organic standards
December 22nd, 2006
NOC letter to the USDA Agricultural Marketing Service supporting clear, objective, and enforceable pasture standards for organic livestock
October 12th, 2006
CFS urges the National Organic Standards Board to prohibit use of fish meal and open water net pens in organic aquaculture
September 30th, 2006
Statement to the National Organic Standards Board on access to the outdoors in organic poultry production
July 21st, 2006
CFS comments to the National Organic Program on proposed amendments to the National List
June 12th, 2006
CFS comments to USDA on proposed rulemaking regarding access to pasture in organic livestock production in the National Organic Program.
May 12th, 2006
CFS comments on proposed revisions to organic livestock standards, in response to the outcome of Harvey v. Johanns.
April 5th, 2006
CFS comments to the National Organic Standards Board on proposed guidelines for organic aquaculture.
January 20th, 2006
CFS and Consumers Union raise concern over 'consumer' appointments to the National Organic Standards Board.
September 30th, 2005
CFS and coalition of other NGOs issue statement on the Organic Trade Associations's proposed amendments to the Organic Foods Production Act
September 19th, 2005
CFS writes letter to Senators urging them to reject amendments to the Organic Foods Production Act that would negatively impact the integrity of the organic label.
August 19th, 2005
CFS comments to the National Organic Program concerning Sunset Review of Approved Materials on the National List for use in organic agriculture.
May 20th, 2005
NOC letter to the National Organic Standards Board regarding pasture requirements for organic livestock proiduction
June 22nd, 2004
The organic committee of the National Campaign for Sustainable Agriculture submits letter to U.S. Department of Agriculture concerning National Organic Program
March 13th, 2000
CFS Comments on the New Organic Standards
March 1st, 2000
Comparative Analysis of NOSB Recommendations and OTA's American Organic Standards
October 29th, 1999
Letter to Kathleen Merrigan, Director Agriculture Marketing Service, USDA urging the USDA to establish a simple, cost-effective cost-share program for organic small farmers
September 29th, 1998
Memorandum To National Organic Standards Board: RE: Ex Parte Communications
April 30th, 1998
Comments submitted to Docket No. TMD-94-00-2, USDA's [first] Proposed National Organic Program
April 30th, 1998
CFS comments concerning the draft proposal for 'Guideline for determining whether a processing technology shall be reviewed by the National Organic Standards Board.'
April 1st, 1998
Letter to the Secretary of Agriculture, Dan Glickman