Although AMS appreciates these comments, they are beyond the scope …

Thus, although the Economic Analysis Report was not itself published until April 23, 2020, AMS believes that commenters had ample opportunity to familiarize themselves with the Final RIA and the Withdrawal RIA and that 30 days was sufficient to review a report analyzing specific flaws in those documents. National Organic Program (NOP) standards, for the use indicated and in keeping with any applicable use restrictions as specified. Section 205.103 requires certified organic and transitioning producers to keep detailed records of all crop production and pest management activities as evidence of compliance. Official Copy of Standard The official standard is contained in the Code of Federal Regulations, 7 CFR 205, and its periodic amendments, and can be accessed through the NOP website at It is meant to provide examples and cover more general, large-scale differences. standard to meet the NOP Crop Rotation practice standard, it is necessary to meet all of the criteria in the standard: reduce soil erosion, maintain or improve soil organic matter content, manage the balance of plant nutrients and manage plant pests (weeds, insects, diseases). Headquarters - The Hall of the States, 444 N. Capitol St. NW, Suite 445-A, Washington, D.C., 20001 • (202) 403-8513 Member Services - 28 Vernon St., Suite 413, Brattleboro VT 05301 • (202) 403-8630 www.OTA.com 1 April 4, 2019 Ms. Michelle Arsenault National Organic Standards Board USDA-AMS-NOP Docket: AMS-NOP-18-0071 RE: Oversight Improvements to Deter Fraud Discussion Document Updated November 18, 2020. Below are brief descriptions of pertinent sections. NOP standards as they pertain to pest management. 6. CATEGORIES Crop Products Crop Fertilizers and Soil Amendments Activated Charcoal 3 COR vs. NOP OMRI 13ORNOPCompariso1.pdf CGSB C Reference NOP NOP Reference AAFCO–American Association of Feed Control Officials NOSB–National Organic Standards Board This table is not an exhaustive list of differences between CGSB and NOP regulations. NOP Certification Standards Manual Posted on January 6, 2017 at 3:21 pm. The USDA NOP derives its regulatory authority to create, implement, modify, and enforce the standard from the Organic Foods Production Act of 1990. Producers should consult with their USDA-accredited certifying body before using any new products. CERT A04 NOP Standards Manual V1, R7 6/01/11 National Organic Program Standards Manual October 2010 Pennsylvania Certified Organic 106 School Street, Suite 201 Spring Mills, PA 16875 (814) 422-0251 (814) 422-0255 fax pco@paorganic.org www.paorganic.org CCOF certifies to the NOP as our primary standard. Written by Morgan Claytor.



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