Policy Comments


July 12, 2010
NOC Comments to FDA Docket No.Docket No. FDA 2010 N 0085: Preventive Controls for Fresh Produce.
Read NOC Response

NOC Attachments to Comments [Referenced Food Safety Studies] to FDA Docket No.Docket No. FDA 2010 N 0085: Preventive Controls for Fresh Produce.

May 2010
NOC joins over 140 organizations signing on to a letter submitted by Pesticide Action Network North America (PANNA) to make sure that The Global Food Security Act (H.R.3077) remains technologically neutral and does not include a clause mandating research funding for one particular agricultural technology (genetically modified crops).
Read Letter

April 20, 2010
NOC signed on to Consumers Union letter to FDA/USDA about the US position [Codex] on GE/GM labeling
See the Letter

April 19, 2010
NOC Comments on NOP "Access to Pasture Rule" Including NOC proposal for an "Organic Grassfed Label."
Read Comments

March 19, 2010
Press Release - NOC Enthusiastic about USDA/OIG Report on National Organic Program
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March 19, 2010
NOC Testimony to House on FY 2011 Appropriations
Read Testimony

March 17, 2010
NOC's letter to Blanche Lincoln, Chairman; Committee on Agriculture, Nutrition, and Forestry urging to include language in the Child Nutrition Reauthorization bill to remove the barriers of access to organic foods within the WIC program.
View Letter

January 27, 2010
Post-Hearing brief on proposed Leafy Green Marketing Agreement (NOC and FWW)

January 4, 2010
NOC's Comments on Guides to Minimize Microbial Food Safety Hazards

January 4, 2010
Food and Water Watch comments to FDA Guidance on Melons

January 4, 2010
Food and Water Watch comments to FDA Guidance on Leafy Greens

January 4, 2010
Food and Water Watch comments to FDA Guidance on Tomatoes

November 2, 2009
Comments of NOC to the National Organic Standards Board

November 1, 2009
Letter to Senate Finance Committee on the nomination of Mr. Siddiqui to the USTR.

October 28, 2009
OFRF Comments: CSP Interim Final Rule

October 27, 2009
NOC letter to Senator Stabenow regarding the Senator's draft legislation regarding allowable agriculture and forestry offset credits for climate change legislation.
View Letter

September 14, 2009
Sign-on letter of comments regarding the implementation of the Cooperative State Research, Education, and Extension Service (CSREES) Agriculture and Food Research Initiative (AFRI), as authorized by the 2008 Farm Bill.
View Comments

August 11, 2009
NOC Comments to NRCS regarding Conservation Practice Standard
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August 11, 2009
OFRF Substantive Comments to NRCS regarding Conservation Practice Standard to which NOC is a signatory
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August 6, 2009
USDA Seeks Independent Oversight of National Organic Program
NOC press release

July 13, 2009
Letter to Senate Agriculture Committee on Climate Change

July 13, 2009
Letter to Senate environment and Public Works Committee on Climate Change

June 29, 2009
NOC and CFS Sign-on letter (nearly 200 signators) to USDA/APHIS regarding The Proposed Rule and Programmatic Environmental Impact Satement for the Introduction of Genetically Engineered Organisms, APHIS Docket 2008-0023.
View Comments


May 4, 2009
NOC Comments to the National Organic Standards Board on several topics related to the NOSB Agenda.
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April 22, 2009
NOC testimony submitted to the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2010 Appropriations Requests.
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April 20, 2009
NOC Comments to the National Organic Standards Board on the "Peer Review Panel" and NOP compliance with Accreditation standards, ISO 17011 (formerly 61).
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April 16, 2009
NOC Comments on the Organic Conversion Assistance program within the NRCS Environmental Quality Incentives Program, recently passed in the 2008 Farm Bill
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March 6, 2009
NOC comments to the USDA Audit Review and Compliance Branch (ARC) regarding recent changes to its auditing procedures.
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December 22, 2008
NOC comments to USDA NOP on the Proposed Access to Pasture Rule with suggested changes to the Proposed Rule, and support for the line-by-line changes suggested by Federation of Organic Dairy Farmers (FOOD Farmers).
View Comments

November 3, 2008
Food and Water Watch comments to the National Organic Standards Board Livestock Committee's proposed organic aquaculture standards, specifically the recommendations on "Fish Feed and Related Management Issues" and "Net Pens and Related Management Issues"
View Comments

September 24, 2008
NOC comments to CSREES on the Agriculture and Food Research Initiative (AFRI) newly authorized in the 2008 Farm Bill regarding the provisions of the Act which specify conventional plant and animal breeding as a priority area of research within AFRI.
View Comments

September 23, 2008
NOC letter expressing concern about a "Sustainable Agriculture Label" to the members of the Leonardo Academy's "Sustainable Agriculture Draft Standard for Trial Use Standards Committee"
View Letter

September 19, 2008
National Certification Cost Share letter to USDA Agriculture Marketing Service (AMS) from various organizations.
View Letter


May 20, 2008
NOC Comments to the National Organic Standards Board May 2008 meeting regarding materials being reviewed by the board.
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May 20, 2008
NOC Comments to the National Organic Standards Board May 2008 meeting regarding the certification of Grower Groups.
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March 7, 2008
NOC testimony to the Senate Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2009 Appropriations Requests
View Testimony

March 12, 2008
NOC testimony to the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2009 Appropriations Requests
View Testimony

February 14, 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.
View Letter

February 6, 2008
NOC letter to House and Senate Farm Bill conferees opposing the specialty crop marketing provision in the House version of the Farm Bill
View Letter

November 12, 2007
NOC comments to the National Organic Standards Board regarding organic certification of "grower-groups" and multi-site operations
View Comments

July 17, 2007
Letter to Representative Kagen supporting his amendment to the 2007 Farm Bill to increase funding for organic research
View Letter

July 13, 2007
CFS and allied consumer organizations letter supporting mandatory implementation of country of origin labeling (COOL).
View Letter

June 18, 2007
Letter to Chairman of the House Agriculture Committee opposing section 123 of the House Farm Bill
View Letter

April 25, 2007
National Organic Coalition letter to USDA Secretary Johanns regarding grower group certification under USDA organic standards
View Letter

April 24, 2007
NOC Testimony of Kathy Arnold, Twin Oaks Dairy, before the Senate Committee on Agriculture, Nutrition and Forestry addressing the economic challenges and opportunities faced by American agricultural producers
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April 18, 2007
NOC Testimony of Bea James, National Cooperative Grocers Association, before the House Committee on Agriculture, Subcommittee on Specialty Crops and Organic Programs, hearing on Organic Agriculture and Rural Development
View Testimony

March 4, 2007
Testimony of NOC's Legislative Coordinator Steve Etka before the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration and related agencies, regarding the fiscal year 2008 appropriations request
View NOC FY08 Appropriations Request Chart

December 22, 2006
NOC letter to the USDA Agricultural Marketing Service supporting clear, objective, and enforceable pasture standards for organic livestock
View Letter

March 30, 2006
National Organic Coalition comments to Congress on FY 2007 organic agriculture appropriations.
View Testimony

May 20, 2005
NOC letter to the National Organic Standards Board regarding pasture requirements for organic livestock production
View Letter

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