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Even Government Committees Need to Do Their Homework

Secret Codes: (okay – so they are just acronyms . . .)

NOP = National Organic Program USDA = Untied States Department of AGRICULTURE (Farms!!)

NOSB = the National Organic Standards Board (They are supposed to represent “us” to the NOP).

CACC = The Compliance, Accreditation and Certification Committee (A committee of the NOSB). FDA = Food and Drug Administration
The CACC has made a recommendation to the NOSB that ALL organic personal care products must be certified to the NOP. The recommendation, if implemented the way it is written, would mean that if you have a product that is not certified, you could not call it “organic” – even if it were all organic unless you are certified to a food standard.

So let’s get this straight:
1 – An organization that does not have a single member representing the cosmetic industry on it’s board is making this recommendation.
2 – The CACC has not even discussed that fact that there are THOUSANDS of companies in the US that have high content organic personal care items that are not certified (I confirmed this with the Chair person of the CACC). They have no strategy to addres this issue.
3 – In spite of the fact that they were sensibly asked to form a Task Force by OTA to look at the issue, they refused and just made the recommendation without input from the industry.

The really dumb thing about this is that they have no idea if it can even legally be done. The FDA has authority over cosmetic labels. It is unlikely that the USDA can mandate label authority. Even if the FDA and the USDA agreed to some sort of memorandum of understanding, the necessary regulations will take years to first be agreed upon and then to move through the regulatory process (3 years, 5 year, who knows).
Summary – this does not solve the existing problems:

  • Retailers do not make it a point to carry certified products; where is the incentive?
  • Even if you get certified to a standard, you might be sued by OCA or he who shall remain nameless.
  • There are thousands of people making products, they need to be “brought into the tent” of organic and there needs to be a reasonable strategy that will achieve this. This is not a reasonable strategy.

The NOSB is asking for comments on the recommendation. I am going to write them that they should not waste all of our time without doing the necessary work. NOSB, CACC – do your homework! Don’t spin everyone’s wheels by asking for comments on a completely irresponsible recommendation. We need standards for organic cosmetics, but this is not the way to achieve them. You need to understand who the players are, what the barriers are, and come up with a sane solution. Just writing a law that puts thousands out of business is not a solution, it is a nightmare.

Go to the link below to read the recommendation and comment to the NOSB, then send them a note. http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5079488&acct=nosb
Gay Timmons 09/28/09 Copyright

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