NOSB

It is unwise to take the recent Personal Care Recommendation by the NOSB (Nat’l Organic Standards Board, an advisory board to the NOP) out of the context of the whole meeting and even out of the context of the NOSB’s history.
On the NOP web site, there are 10 pages listing the titles of Recommendations (that go back 9 years) by the NOSB to the NOP (this does not include those recommendations that go back to 1994, prior to implementation nor the recommendations passed this latest meeting). Many of these are for materials, which the NOSB does a a really good job at handling. Reportedly, 65 different policy recommendations are still unresolved between the NOSB and the NOP; we still do not have standards for pet foods, textiles, or aquaculture. This is not a criticism, it is an observation about how government works. There are issues of priority, regulatory complexity, expertise within the department to deal with a particular problem that all influence the forward motion of any recommendation.
If you look at the Livestock committee, for example, you see that the first recommendation on pasture access policy was in 2001. I think I read in the “Tweets” that this was finally adopted as policy by the NOP at the meeting last week – but I may be wrong on that. Am sure someone in the know will correct me. Just an example of why you should take the OCA “news” report with more than a grain of salt. It took from 2001 to now to get agreement on “Pasture Access” between all the members of the NOSB and then all of the departments within the USDA. This “high priority” issue took 9 years to get from “Recommendation” to “Policy”. (This is good – it took the FDA 11 years to agree on the legal definition of peanut butter).
We need uniform standards for organic cosmetics. It is also imperative that we continue to support the use of as many organic ingredients in cosmetics as possible. I just don’t think it will happen in the next few years as the result of the NOP. I believe that the NOP’s clear message that personal care is not a priority, as was stated during the meeting:

  1. did not come from the program director but rather, represents the position of the Department of AGRICULTURE,
  2. is a message to the industry to move forward with private standards which will only help any future efforts to write either an FDA or an NOP PC Standard,
  3. is also a message to the cosmetic industry to make some of it’s own progress instead of waiting for the wheels of government to grind down their slow path.

The issues that need to be resolved in the NOP are highly complex and may start with this: that until the NOSB has submitted and the NOP has agreed to final, working definitions of “synthetic”, “non-synthetic”, and “non-agricultural”, we cannot make ANY progress on a standard that depends on synthesis chemistry.
Then we need to define what we are certifying – I realize that NOSB set a proposed definition of “personal care” in their recommendation but it may be in conflict with FDA law – which includes things like brushes, candles, neti pots, nail clippers, and anything else sold for “personal” “care” in their legal view of that phrase.
Of course then there is the issue of safety – I would never use a product preserved with 15% alcohol, not on my body and especially not on a child. We have to deal with this. Alcohol is one of the few things that really can act as a transdermal carrier.
So – yes Mr. Bronner and the folks at OCA, after these and many other issues have been resolved, we may be able to move towards enforcement and standards writing, but this will take years. It is impossible to enforce laws that don’t exist;
In the meantime, we still have do not have retailers requiring any sort of certification (except “Natural – which does us no good). There are years of work facing the NOP and the NOSB needs to decide if animal cruelty, existing standards recommendations, certifier training, bio-diversity and food safety should be prioritized before or after personal care.
Folks – this is not going to happen any time soon. 74% of OTA members in the PC biz are not even certified and many of them would not meet the requirements and probably could not sustain their businesses if they did. And that is only OTA members. So let’s add this question: in the worst recession we have seen since the “Great Depression” (why do they call it “great”?), is the NOP going to tell thousands of small businesses that they cannot do what they have been doing without some sort of long term lead up (like we did with food)?
We need a strategic path to get people into the fold of certification. This was the first volley across the bow by the NOSB and, as they even stated, it is intended to start a conversation, one that will go through the multi-year process of analyzing the industry. There is a lot of work to be done here. And most of us already have jobs. I continue to believe that we are all responsible for creating and enacting a long term strategic plan that will allow people to get certified, develop the necessary supporting infrastructure and do this thoughtfully. Sorry – it just takes a long time. It took organic food 40 years. It does not have to take the cosmetics industry that long but with the continued barriers being thrown up, it may.

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