Johanna Mirenda, OTA - Organic Trade Association - Reply Letter

United States Department of Agriculture
National Agricultural Statistics Service

June 13, 2019
Johanna Mirenda, OTA

Dear Ms. Mirenda,
Thank you for your recent letter concerning the renewal of the Organic Survey. The primary
functions of the National Agricultural Statistics Service (NASS) are to prepare and issue State
and national estimates of crop and livestock production, disposition, and prices and to collect
information on related environmental and economic factors, whole farm characteristics, and
operator demographics. Timely, reliable, and detailed statistics help maintain a stable economic
atmosphere and reduce risk for production, marketing, and distribution operations. NASS is the
primary data collection Agency of the US Dept. of Agriculture.
The content of the Organic Survey has been developed over the years at the request of numerous
data users, including, but not limited to: Risk Management Agency, Federal Crop Insurance
Corporation, Agricultural Marketing Service, Economic Research Service, Natural Resource and
Conservation Service and many others. NASS has been conducting cognitive interviews in the
larger organic producing states looking for ways to improve the questionnaire. NASS is also
looking for ways to streamline the questionnaire to reduce respondent burden and data collection
costs, while still providing data users with the detailed data they need.
Recommendation 1: The Organic Trade Association’s top priority for the 2019 Organic Survey
is to retain the section on “Production Expenses” (Section 12).
Reply: Reply: NASS will be including the following question:
Report production expenses paid by this operation in 2019.

a. Organic certification expense
b. Certified organic feed purchased for livestock and poultry
c. Food safety related expense
d. Hired agricultural labor including contract labor (include wages and benefit
expenses)
e. Seed, annual seedlings, and planting stock
i. Organic seed, annual seedlings, and planting stock purchased
ii. Non-organic seed, annual seedlings, and planting stock purchased

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Recommendation 2: NASS should retain the section on “GMO Presence” in the 2019 Organic
Survey. Furthermore, we strongly urge NASS to expand this section (or add a new section
with identical questions) to address “Inadvertent Pesticide Contamination” of organic crops
(i.e. the presence of residues from prohibited pesticides on an organic crop that are not a
result of the intentional, willful, or direct application of prohibited pesticides by the organic
operator). Inadvertent contamination or crop loss from prohibited pesticides such as
glyphosate or dicamba can adversely impact organic farms on par with GMO contamination.
Collecting data on the economic impact of such contamination is important to understanding
the current state of contamination, and to identify areas where research and other supportive
resources can be directed.
Reply: NASS will be including the following question:
Have you ever experienced economic loss due to unintended GMO or genetic contamination
of a certified organic crop you produced for sale? Check all that apply
[ ] Yes, in 2019
[ ] Yes, in 2018
[ ] Yes, prior to 2018
[ ] No
NASS will also be including the following question:
Have you ever experienced economic loss due to unintended pesticide contamination of a
certified organic crop you produced for sale? Check all that apply.
[ ] Yes, in 2019
[ ] Yes, in 2018
[ ] Yes, prior to 2018
[ ] No

Recommendation 3: Section 13: Organic Production Practices
We suggest adding the following practice to the list of organic production practices:
- Implement crop rotations to maintain or improve soil organic matter content, provide for
pest management, manage plant nutrients, and/or provide erosion control.
Reply: Some of these cropping practices information are already being collected in the
Agricultural Resource Management Surveys (0535-0218). To help minimize respondent
burden, these additional questions will not be included.
Recommendation 4: Section 15: Other Information
Question 5 asks which of the following the respondent would consider the primary challenge
as an organic farmer. The results of the 2014 Production Survey show that 20% of the
responses said “other.” Therefore we suggest adding the following challenges to this list to
address the other possible primary challenges facing organic farmers.

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- Inadvertent contamination by prohibited pesticides or GMOs (leading to loss of market,
price and/or organic certification)
- Lack of technical assistance information and advice (untrained county extension personnel,
lack of knowledgeable farm advisors, lack of information and advice specific to organic,
etc.)
- Lack of research necessary to overcome organic production challenges (weed control, soil
building, no-till, etc.)

Reply: NASS will be including the practices that were itemized in the 2014 survey again this
time.
Once a finalized draft of the questionnaire is ready it will be submitted to OMB along with the
supporting statements, samples of publicity materials, and other documents for the public to
review for 30 days. After that OMB will be able to begin their review of the complete docket
materials. The materials will be available in the Office of Information and Regulatory Affairs
system https://www.reginfo.gov/public/do/PRAMain.
The Organic Survey is extremely important to our data users. Your comments will be provided
as a part of this submission to the Office of Management and Budget.
Please let us know if you have any questions or concerns.
Again, many thanks!
Digitally signed by JOSEPH PARSONS
DN: c=US, o=U.S. Government,
ou=Department of Agriculture,
cn=JOSEPH PARSONS,
0.9.2342.19200300.100.1.1=1200100005
0032
Date: 2019.06.13 15:26:17 -04'00'

Joseph L. Parsons
Chair, Agricultural Statistics Board
U.S. Department of Agriculture
National Agricultural Statistics Service

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