Comments to the Upcoming National Organic Standards Board and National Organic Program

October 24-26, 2018
St. Paul, Minnesota
On behalf of the Organic Farmers’ Agency for Relationship Marketing (OFARM, Inc.)

OFARM first raised the issue of organic imports and fraud in 2015.  It is now almost three years since we began focusing on protecting U.S. organic grain producers’ markets and organic integrity.  So, what has changed?
At that time the response from the NOP was basically that the paper work was all in order and there was no problem.  It was only after the Washington Post article in May 2017 where Investigative Reporter Peter Whoriskey blew the lid off organic grain fraud that OFARM was taken seriously.  Prior to that time, our farmers knew what the problem was.  The last entity to admit there might be a problem was the National Organic Program.
Since that time the NOP and NOSB have had several events such as a panel discussion last fall with agencies involved and in Spring, 2017, a panel, including corrective actions which I participated in.
The NOP has issued several memo’s or guidance documents over the past two years about imported products.
Again, the general attitude has been that quote, “The system is working.”  There is always a report at the NOSB meetings by the NOP about the number of revoked certificates, surrenders and fines levied.
What hasn’t changed is the number of suspected shipments of potentially fraudulent grain.  The NOP has sometimes pointed to reduced shipments from suspected countries of origin but has provided no positive proof that paper memos and the appearance of enforcement is working.  The shipment reductions may in fact be due to crop production variations and time of the marketing year.
As recently as the first week of September 2018 and September 25, OFARM filed complaints over two bulk shiploads of supposed organic grain arriving in the Port of New Orleans.  Both shipments (MV Carolina Bolton and MV Oceanus) listed Serbia as a country of origin with loading out of a Romanian port.  One of the ships with 1000 MT of supposed organic corn left Romania, traveled to a Russian port on the Black Sea to finish loading its cargo then proceeding to New Orleans. This is following reports OFARM has received of shifting to other ports than Turkey to hide under grains coming out of the EU.  On the U.S. side, OFARM received reports that the shippers involved in previous questionable organic imports were switching away from the Port of Stockton, CA because shipments there were coming under too much scrutiny.  
When an NOP employee was asked how much organic corn is grown in Russia, the response was they didn’t know because reliable information is so hard to acquire.  NOP’s response to OFARM’s complaint was to ask us to reveal our confidential sources and what made us think the shipments from Serbia through Romania with further loading in Russia was suspect.  A little math shows the numbers don’t add up.
The average farm size in Serbia is 12-20 acres and over 50% of the corn grown is fed to livestock domestically.  In 2015, there were 334 supposed certified organic farms. (Organic Agriculture in Serbia at a Glance, 2017.)  There was one large farm appearing in the USDA’s Integrity Database in 2018 which could account for one shipment of 7500 MT of organic corn which arrived in the U.S. in June and July.  It does not account for the other two shiploads of grain originating, at least in part in Serbia.
In summary, OFARM has had to work with organic grain producers to develop the means to insure the integrity of the crops they produce because farmers have found out they cannot depend on the USDA and NOP to protect them.
My statement to the NOSB and NOP in November, 2016 still stands over 2 years later. “The result of this has the potential to set back the U.S. organic market due to lack of consumer confidence in USDA’s “organic” seal and creating an environment with even more reliance on imports of organic corn and soybeans because the market signals to producers are to produce less, not more.  Unless immediate steps are taken by the NOP to strengthen organic import protocols to be equivalent to what U.S. producers and the industry face here, in the EU and Canada, this stands to be a major economic train wreck setting back the growth of the industry for years to come. (Statement to the NOSB, St. Louis, MO. November 16, 2016)”
The cost to U.S. organic grain producers now totals almost $500 million with not much end in sight to the current situation.
After three years, what has changed?  Not much. People intending to cheat the system because of over $4 million profits per shipload versus an $11000 fine or about 2 cents a bushel if caught could care less about memos and “all the paper work is in order.”
The NOP is still trying to push most of the blame for the situation on certifiers.  And to a degree certifiers and inspectors have also not done due diligence on these large shipments of grain.
NOP has more authority than it apparently has the will to use.  It is also apparent that the NOP does not have the institutional fortitude or will to stand up to organic fraud.   Secondly, there is no question the NOP is vastly out-numbered and needs additional resources.  OFARM has worked with a lot of other to procure additional resources and authority. We cannot correct an institutional laxness to protect organic integrity.
The Organic Farmers’ Agency for Relationship Marketing, Inc. (OFARM) is incorporated in the State of Minnesota as a cooperative marketing-agency-in-common.  OFARM has six organic grain and livestock marketing cooperatives as members.  OFARM represents organic producers in 19 states from Montana to Texas and Louisiana to Kentucky, Michigan and states in between.  USDA has cited OFARM as the largest farmer-controlled block of organic grain in North America (Rural Cooperatives, January-February 2012)



 OFARM Executive Director
*John Bobbe, is OFARM’s Executive Director.  He holds a Master’s Degree in Agricultural Economics from the University of Missouri-Columbia.  John is the author of “Marketing Organic Grain, A Farmers Guide.” (Levins Publishing, December, 2015)