Page 57 - Breeding and regulatory opportunities, Renaud

Seed Regulation in the US

However, in doing so, the recommendations indicated that certiiers might fail

audits by not following the guidance or by not warning growers that two years’

of non-compliance in using available organic seed could result in the revocation

of organic certiication. In addition, the concept of a ‘two-way national database’

maintained by an independent party was included, implying the need to

establish a national database populated with organic seed availability, as well

as organic growers’ varietal needs and quantities.

In 2011, the NOP released its response to the 2008 NOSB inal recommendations

(NOP, 2011) supporting: (1) the role of certiiers in assessing the annual progress

of growers in sourcing organic seed and in ensuring progress by comparing

current source information to previous years, (2) the recommendation that

certiied operations must establish a documented procedure for sourcing

organic seed which includes the identity of the seeds sought, the search methods

used to source organic varieties, and that demonstrates the use of organic seed

or the commercial unavailability of organic seeds, and (3) the recommendation

that growers must demonstrate veriication of sourcing seed from a minimum

of three sources conirming that organic seed cannot be avoided because of

the price of the seed.

The NOP’s response added a section about the criteria and procedures for

securing an exception to organic seed usage. The NOP’s response omitted: (1) the

recommendation that certiiers be required to quantify the percentage increase

in organic seed usage per year and to record varieties for which exceptions were

permitted, (2) the recommendation that commercial purchasers of organic

food crops require that suppliers who were contractually required to grow

selected varieties use organically produced seed to grow those varieties, (3) the

recommendation that growers perform on-farm trials to support exemption

requests, and (4) the requirement for a ‘two-way’ organic seed sourcing

database. A two month public comment period generated requests from several

stakeholders reiterating reincorporation of the omitted content outlined above

(OTA, 2011). On March 4, 2013 the NOP presented its inal guidance on ‘Seeds

Annual Seedlings, and Planting Stock in Organic Crop Production’ (NOP 5029),

and none of the originally omitted sections of the guidance were reinstated

(NOP, 2013).

39