Page 58 - Breeding and regulatory opportunities, Renaud

Chapter 2

2.3.2 Contexts, concerns, and concepts

This section outlines the range of stakeholders’ concerns during the evolving

US organic seed regulatory process, and their associated actions. Table 2.2a

summarizes the various stakeholder categories, their level of inluence and key

concerns at the start of the oicial processes outlined above, while Table 2.2b

indicates the subsequent shifts in stakeholders’concerns which had taken place

by the end of the study in 2013.

What is at stake for organic certiiers?

The initial stakeholder analysis identiied certiiers as the most inluential in

the interpretation of organic seed regulation because they were assigned the

greatest responsibility for enforcement of the evolving regulatory process

- a process that the NOSB emphasised should be uniformly rigorous and

transparent. Their responsibilities included: compelling growers to use organic

seed, verifying grower diligence in organic seed sourcing and on-farm trial

veriication and sanctioning growers who fail to comply. With 49 USDA certiied

organic certiication agencies based in the US, and with each certiier allowed

to deine its own procedure for granting exceptions, inevitably there was from

the start considerable variance in certiier practices, especially in regard to

documentation of exceptions, for which there is inconsistency among certiiers’

standards (Certiier interviews, 2007-2013).

The NOSB recommended that during the inspection process, certiiers request

a list of non-available organic seed varieties from growers. The ACAs’ publicly

responded that certiiers do not have the capacity to document the varietal

needs of growers or to record the gaps in organic seed supply (ACA, 2008).

Interviews with certiiers further revealed that they do not necessarily trust their

own ability to make exceptions because they do not have suicient knowledge

about organic seed availability and varietal performance (e.g. California

Certiied Organic Farmers (CCOF) interview, 2009). Other certiication agencies,

such as the Monterey County Certiied Organics (MCCO), revealed that they

certify organic seed companies and stay informed of their clients’ commercial

certiied organic varietal assortment (2013). The ACAs’ written response to the

NOSB’s recommendations indicated that certiiers in fact did not want to be

responsible for developing a compliance infrastructure for the organic seed

industry through their work, nor did they support a measured percentage

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