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My guest today is Peggy Miars, Executive Director/CEO of the Organic Materials Review Institute. Founded in 1997, OMRI provides organic certifiers, grower, manufacturers, and suppliers an independent review of products intended for use in certified organic products, handline, and processing. They also prove subscribers and certifiers guidance on the acceptability of various material inputs in general under the National Organic Program. Peggy came to OMRI in 2010 from California Certified Organic Farmers (CCOF), where she served for six years as the Executive Director/CEO. She holds a Bachelor of Business Administration degree from Western Michigan University and completed post-graduate courses in nonprofit management at Regis University in Colorado Springs. Peggy has worked in the organic industry for more than 17 years, previously in marketing and management positions with Earthbound Farm, Whole Foods Market, Granary Market, various nonprofit organizations, and her own marketing consulting business. She completed International Organic Inspector Association training for organic inspectors of crop products in 2007.




“A Behind-the-Scenes Look at What Goes Into Organic Products”

Host: Debra Lynn Dadd
GUEST: Peggy Miars

DATE OF BROADCAST: December 11, 2013

DEBRA: Hi, I’m Debra Lynn Dadd and this is Toxic Free Talk Radio, where we talk about how to thrive in a toxic world and we do that because there are so many toxic chemicals in our consumer products, in the air we breathe, in the water we drink and the food we eat; even in our bodies which they are storing from past exposures and so in order to be healthy we need to do everything that we can do to identify toxic chemicals around us; to make choices to buy products that don’t have toxic chemicals in them; to remove toxic chemicals from our body and on this show we talk about how to do all those things and I interview wonderful guests who are doing these things; who are making these products; who are working behind the scenes; who are working to change regulations, all the things that need to happen in order to have a world without toxics.

Today is Wednesday, December 11, 2013 and I’m here on a beautiful winter day in Florida where the sun is shining and it’s 70 degrees and that’s how it is going to be all winter. Usually it doesn’t rain here. It rains in the summer, it rains all summer but here this is just about what it’s like in Florida, so you can imagine me sitting here at the microphone looking out over my garden with the sun shining.

Today, we are going to talk about something a little different than we usually talk about. We are not going to talk about what happens on the consumer end; we are going to talk about what happens behind the scenes; and my guest today is Peggy Miars. She is the executive Director and Chief Executive Officer (“CEO”) of the Organic Materials Review Institute and what they do, is, they provide organic certifiers, growers, manufacturers and suppliers an independent review of the products and materials intended for use in certified organic products and in the handling of them and processing; and so just like you and I are looking for say, a product that has the United States Department of Agriculture (“USDA”) Certified Organic Seal on it, people who are certifying those people who are doing that certification and the growers, are looking to this organization to tell them what are the products they can use on organic fruits and fibers in the growing process when they are certifying. So if somebody, say a certifier, is looking at a process that a grower is using, he might look and say, well are you using this and this or this chemical and what this organization does is make lists of chemicals, materials, products that can be used in the organic process so that it makes everything easier. Anyway, hello Peggy, thank you for being with me today.

PEGGY MIARS: Hello Debra, thanks for having me.

DEBRA: Ok, well, we have a lot to talk about; this is a big subject. First, tell me about your organization. I know you personally have a long history of working in the organic movement, so tell us about you and the organization and how the two of you came together.

PEGGY MIARS: Sure, I’ll be happy to do that, but first of all the Organic Materials Review Institute or “OMRI” as we call it, is a non-profit organization and we were founded back in 1997. Now some of the first Organic Certifiers started doing their work back in the early 1970s and part of their work, as you said was what OMRI does now. They were having to look at all the inputs, the fertilizers, the pest control products and so forth that the organic farmers were using and the certifier had to look at that and determine whether it was compliant to the organic standards. So in the late 1990s some certifiers got together and said, we are so busy doing this material review that we don’t really have time for our main work, which is organic certification and so they actually pooled their material review programmes and they took their lists that existed at the time and their files and everything and put them all together and created this non-profit organization called OMRI, so that we could do that detailed material review work and allow the certifiers to do the organic certification work that they were intended to do. So, like I said, we’ve been in existence since 1997 and really our main clients are the certifiers who rely on our decisions, and so…..

DEBRA: So it goes, just for the listeners to get the line up straight, so there is you, who you are determining the safety of the materials that are used and then there’s the certifiers and then there’s the growers and the certifiers are saying to the growers, this is ok, and then when the certifier says it’s ok then it becomes a product and it gets sold with the USDA seal on it.

PEGGY MIARS: Correct, that’s right; you got it exactly right there.

I’ve been involved in organics since 1996 when I was working for a small natural food store and we sold primarily organic products. I’ve actually been buying organic myself as a consumer since 1985. That’s when I started looking at labels and understanding where my food came from and so forth, so I’m what you would call a core organic consumer, buying primarily organic.

DEBRA: Me too, that’s about when I started, 1987.

PEGGY MIARS: Ok, good, excellent! great. So that’s my personal passion and I’ve worked in not-profit organizations; I’ve worked in Girl Scouts Council, I’ve worked for a Humane Society, and so non-profit has really been my focus in my career. I’ve been in non-profit for about seventeen (17) years. I’ve been in the organic industry since 1996 and so together my personal interest and my professional experience brought me here to OMRI to be the Executive Director. Before that I was the Executive Director and CEO of California Certified Organic Farmers or “CCOF” which is one of the largest and oldest organic certification agencies in North America.
DEBRA: And I remember them because I used to live in California.

PEGGY MIARS: Oh, alright, we’ve got a lot in common.

DEBRA: So I was always looking for COF (Certified Organic Food).

PEGGY MIARS: Ah, excellent, great!

DEBRA: Yes, yes.

PEGGY MIARS: The other thing too that I’ll mention at this point is, OMRI review and OMRI listing is voluntary. It’s not required for an input manufacturer to be OMRI listed in order for farmers to use their products. However, certifiers really rely on OMRI; the growers look for OMRI listing so the manufacturers know that in order to make it easier for everyone they get the OMRI listing and then it’s good to go.

DEBRA: That’s so great, so you’re the one in charge of the organization that is really defining what goes into organic foods and fibers, Yes?

PEGGY MIARS: Somewhat, yeah. I wouldn’t say that we define it, because that is really up to the USDA National Organic Prorgramme.

DEBRA: True; but you are actually the one that is kind of executing the orders to come up with a practical way to meet those standards.

PEGGY MIARS: Right, executing and also there is some interpretation as well because the standard, the National Organic Standards aren’t overly prescriptive so there are some areas that require interpretation and one of those gray areas really is, material review and so we do have to interpret the National Organic Programme (“NOP”) Standards and we actually create our own standards for areas where it is gray and we’ve interpreted them in our way and so we publish those standards so everyone understands how we are conducting our reviews.

DEBRA: Ok, good. That’s a very important role that you are playing. I have seen this term ISO accreditation, what is that?

PEGGY MIARS: ISO accreditation is something that is well known in the world of certification and what that means is, it’s an international standard and OMRI is ISO accredited. What that means, is that you can receive that accreditation from a number of bodies out there. We receive our accreditation from the USDA not from the NOP but from the USDA and what they do is, they look at the ISO standards. Just like there are organic standards there are ISO standards.

DEBRA: What does ISO* stand for?

PEGGY MIARS: I knew you were going to ask that. It’s one of those international terms where the letters don’t match up with the actual words. International Standard setting, something or the other; but essentially what the USDA does is that we’re audited every year and they review our policies and procedures and they do two (2) things:
1. they ensure that our policies and procedures are in line with the ISO standards and number two; which is really important is;
2. they audit us to make sure that we are doing what we say we’re doing because they don’t want organizations putting something in the policies and then not following them.

*ISO – International Organization for Standardization

DEBRA: Of course.


DEBRA: Ok, so the reason that your organization exists, Peggy is because you are offering a solution to the toxic chemicals that are in our food supply, so tell us about what these toxic inputs are.

PEGGY MIARS: Well, I think probably when people think mostly about toxic inputs they’re thinking about pesticides and that’s something that people look to organic for. It’s less persistent toxic pest control products and fertilizers and so forth. Obviously, with any kind of pest control product there is some toxicity to it just because of its intention to kill pests but in organic they tend to be less toxic, less persistent in the environment. In other words, they don’t hang around as long and there is something called the National List that is maintained by the National Organic Programme and the national list in general, is described as..; let me start over again. In general, non synthetic substances are allowed in organic production unless they are specifically prohibited.

DEBRA: May I interrupt you for a minute? I want to ask a question. This has been on my mind a couple of days since one of my other guests talked about this.


DEBRA: The first thing is that there is synthetic chemicals which are made from petroleum and then there is what we could call natural chemicals that are made from or are just straight out of nature or made with renewable ingredients as the feedsource and the feedsource, for those people who don’t know what that term is; is the original raw source material that is used to make something industrially. So, on this list you would have pest control or other chemicals for other purposes which are both synthetic and natural. Right?


DEBRA: The question I really have, is that, this previous guest said that an organic grower could be using a renewable natural chemical that actually is toxic and so I got a little confused about that and I’m hoping you can clear this up about that there is toxic versus non toxic and there is natural versus synthetic and I’ll just clarify that, just because something is synthetic does not mean it is toxic and just because something is natural doesn’t mean it’s safe. Could you address all that?

PEGGY MIARS: I will try because I’m not a scientist and I’m not a technical expert. There are both synthetic and natural or non synthetic and those terms are used interchangeably. First, I’ll clarify that non synthetic materials are allowed in organic production unless they are specifically prohibited and in general, synthetic substances are prohibited unless they are specifically allowed, so right there the national list is intended to primarily be natural materials. However, there are synthetics that are reviewed and looked at and allowed. So in terms of toxicity in organics (I’m not a scientist) what I can tell you for example, one thing that I’ve heard of; for example, pyrethrum which comes from natural plants; it’s a botanical extract and so I’m looking here, for example, that is a non synthetic material because it is plant based. It is allowed in organic production; there are some restrictions, for example, they are saying liquid formulations that have a prohibited inert ingredient are not allowed but otherwise those are allowed. Now pyrethroids which I understand are also plant based are somehow synthetic in the way that they are processed and so in that case it’s prohibited; so that would be an example of something that would be natural. It comes from the environment but in one case it’s allowed but in another case it’s prohibited and it has to do with the way it’s manufactured. So I would agree that there are some natural products that are pretty non toxic, for example, garlic. Garlic can be used as a pest control product, that’s clearly a natural product that is non toxic but yet there are other natural products that can be toxic primarily because of the way they are combined with other chemicals, because of the way they are manufactured and that sort of thing.

DEBRA: So they would then be an exception on the national list? I mean, can we assume, as consumers that there is not going to be toxic chemicals on our organic food or fibers and if they are certified there is not going to be toxic ingredients there, whether they’re natural or synthetic?

PEGGY MIARS: Well that’s something that’s being worked on right now, because in the past; this is something that people don’t realize; that organic certification is a process certification. In other words, the certifiers look at, how is that food grown and processed. What they don’t necessarily do, they do not certify the end product even though it looks like they do; even though the seal is there on the product; what they are certifying is the process. But what has been happening over the last year is that the National Organic Programme has told certifiers, you must test a certain amount; I think, maybe five percent (5%) of the products that you certify. You must randomly test them to see what kind of residues there are and so this is something that the NOP is starting to get into; looking more at the end product and what sort of residues may exist at that time.

DEBRA: I’m so glad they’re doing that. This is fascinating. This is exactly what we need to be knowing.


DEBRA: Peggy, we were talking before the break about synthetic compounds that are allowed and I know that those are reviewed and evaluated by the National Organic Standards Board. Can you tell us more about that?

PEGGY MIARS: Sure, I would love to tell you. The National Organic Standards Board or the “NOSB” is a Federal Advisory Committee to the National Organic Programme, so nothing can be added to, removed from or changed on the national list without the NOSB first making a recommendation. The NOSB is a fifteen (15) member voluntary board. They are appointed by the US Secretary of Agriculture and these people represent different aspects of the organic industry; for example, there are certain environmentalist seats, there is a scientist seat, there are seats for farmers and processors, there is a retailer seat, so the idea is that these people are supposed to represent these different groups within the organic industry and so really, the main reason for the NOSB is to review materials for consideration to be added to or removed from or changed on the national list. So there is quite a process that is gone through before anything is changed on the national list. For example, if someone wanted to add a material to the national list, they could submit a petition and there is a humongous and a lengthy process to do this. In fact, it takes about two (2) years for the whole process to go through, from the time the petition is submitted until a decision is made and within that timeframe there are no less than two (2) opportunities for public comment on that material and there are some consumer groups who definitely take advantage of that; who notify their members and supporters when issues come up, like toxic synthetic materials are being proposed for addition on the list.

So, the NOSB looks at the petition, they usually have a technical report that’s been provided that goes into great detail about the material, its toxicity, its persistence in the environment, the impact on the environment and human health and so forth; so there is very much a lengthy process, like I said, that includes public comments before anything is changed on the national list.

The other thing I’ll say is that your listeners, anyone, can make comments. The National Organic Standards Board meets twice a year, once in the Fall, usually October and once in the Spring, usually, April and their Agenda is published, their recommendations are published and so anyone can submit a comment, saying, I agree, or I disagree with this recommendation for these reasons and the NOSB really listens to those public comments. I’ve actually seen them change their recommendations based on the comments that they receive.

DEBRA: Yeah, I’m very happy to hear that.

PEGGY MIARS: Let me tell you a quick story. Back in 1997 when the first organic standards were proposed and drafted and they included what we now call the Big Three, GMO, Sewage/Sludge and Radiation and at that point in time the USDA received more than two hundred and seventy five thousand (275,000) comments in opposition to those three and to this day that remains the largest number of comments the USDA has received on any topic, and so, public comment is very important and it can make big changes.

DEBRA: Good! Good! Good! Good! I’m glad to know that we have some power and that’s a very good story; a very good example.
So tell us how the organic certification system works? Where does OMRI fit in and give us the whole process so that we know when we buy organic, what has happened.

PEGGY MIARS: Ok. Well that sounds fun and feel free to interrupt at any point, otherwise I’ll just keep talking.

I would say that OMRI and seeds are the basis of organics. Clearly, seeds need to be organic or non treated as much as possible and so that’s the beginning of where our foods come from and then the inputs that are used to grow the foods are very important as well and as we said that’s what OMRI looks at; pest control products, fertilizing products, sanitizers used in processing facilities, detergents used in processing facilities and that sort of thing.

DEBRA: So, you are not looking at the seeds themselves?

PEGGY MIARS: We are not looking at the seeds. The certifiers look at the seeds and organic seed is always preferred and if a farmer does not use organic seeds, he needs to prove to his certifier that he tried to find the organic seeds in the quantity and form that they need. Price cannot be a consideration. A farmer cannot say he didn’t buy organic seeds because they are too expensive; that will not fly, that’s not allowed. So the certifier is definitely looking at the seeds, OMRI is looking at the input materials to determine whether they are compliant and so I am going to say farmer, just for this example, even though we know there are processed products as well; but a farmer would want to become organic and the first step there, would be to apply to an organic certification agency and some certifiers are non profit; some are for profits and some are government agencies so they all operate a little differently; they have different fees and procedures and so forth but they all follow the National Organic Standards.

The first thing that the Certifier is going to want from the farmer would be an Organic System Plan (“OSP”). I like to call that their organic business plan; what are you going to grow, what inputs are you going to use, where are you going to source these inputs, where are you going to source your seeds, what crop rotation are you going to use, how are you going to harvest and so forth. The Certifier needs to have a written document of what the farmer’s plan is and so they do their initial review of that and based on that Plan they can determine whether it looks like the farmer can achieve certification or not. If there is a problem they will go back to the Certifier or to the farmer and say, we are missing this information or we need more detail on this particular item.

Once the Certifier is satisfied that they have all the documentation they need then they schedule an inspection of the farm or the processing facility and an Inspector does go out. It is an announced inspection because they want to make sure that the Manager is there and that they got the documentation and so forth. The Certifier sends out an inspector who is for all intents and purposes really the face of the Certifier; they’re the ones that are seen out in the farms and the processing facilities.
For the visit the Inspector takes the Organic System Plan, confirms that this was submitted by the farmer then requests that the farmer explains how the plan is being followed. The farmer is asked to show his records of where he bought the seeds and where he bought his inputs. The farm is closely inspected to make sure that everything works and then the Inspector submits a report back to the Certifier telling them what they found. The Certifier then reviews the inspection report along with the documentation and determines whether the farmer meets certification and if so, they issue a certificate that the farmer can then show as proof of their certification.



DEBRA: I guess we are not talking about the products, we are talking about the ingredients that go into products. The products themselves don’t actually get certified; right?

PEGGY MIARS: Right, it’s a process certification so the certifier looks at how the product is made.

DEBRA: Right and so there are other organizations like, for example, the Global Organic Textile Standards (“GOTS”) that certifies an end product but they are not certifying the process, like how the cotton is grown and so there are different certifiers along the way. A lot is going on.

Here’s the next question; what does your organization look at and verify when making final decisions about a product and product, meaning, those products that are used in the growing and handling and processing of organic foods and fibers?

PEGGY MIARS: Well, our process is actually very similar to the organic certification process in that we require first, documentation from the manufacturer of the input product and it’s important for people to know that we really look in great detail at these products. We require the total ingredients list of the product; everything that’s in it; not only ingredients but also ingredients within ingredients because some ingredients are formulated themselves. We also require the complete manufacturing process explained to us, from the beginning to the end so that we can determine if it is synthetic (that’s one way we can determine if something is synthetic, it may start out natural but then something may be added or something done to it in the manufacturing process that renders it synthetic). We look at that as well.

We also require record keeping. When we do inspections it’s very similar to a certifier’s inspection in that we look at purchase records, you know, where did you buy your ingredients and show us your sales records as well, something that certifiers do and that OMRI does. When we conduct an inspection there is something called an in/out balance; we look at what they bought, the ingredients that they bought, determine from that what their output should be and we look at their output. This is a way to prevent fraud because someone who is dishonest could show records that, oh, I bought these inputs and then on the side buy some more and then mix them together but that would be discovered at the end because they would come out with way more products than what would be feasible based on what they showed in their records.

I hope that makes sense but it’s definitely a way to reduce fraud and to find out when people are dishonest. In some cases we do require a Lab analysis mainly for crop fertilizing products. We look at the label, what they say their nitrogen, phosphorous and potassium levels are and we check those. Another important area that we look at when it comes to fertilizers and soil amendments; we look at heavy metals and we require tests of heavy metals to ensure that those are not excessive as well.

It is important to note that not one individual makes a decision. Decisions at OMRI are always made by a review panel that includes a minimum of three (3) individuals who have to agree on a decision; so it’s a group process. It’s very detailed; the people who do this work for OMRI are brilliant individuals. They are much more knowledgeable than I am about chemistry and science and that sort of thing and so it’s a very detailed process and I would say that consumers could rely on the work that OMRI does and that certifiers do as well.

DEBRA: Wow, it’s a big job. You know, as consumers we don’t always understand. One of the reasons I really wanted to have you on the show was because when I heard about your organizations, I thought, wow! this is all the stuff consumers don’t know. I’ve actually been doing a lot of thinking about this myself, having been a consumer advocate for thirty (30) years and have been talking about how we can eliminate toxic chemicals from our lives. Not being a scientist, not being a doctor not being any one of those kinds of chemists or anything, I’m just looking at it from the consumer view point and what can I find out as a consumer that can help me make that decision and I hear a lot from consumers. How do they know who to trust and can we trust people and all the information. I actually drew a little picture. I‘ve studied a lot of this stuff, like, life cycle analysis and a lot of these things that you talk about and I understand about a system and an input and all those things which most consumers don’t, but I do, because I’ve studied it and so I try to draw pictures and flow charts. I’m trying to figure out what’s going on.

While you were talking I’m making this little flow chart, NSOB, NOP, OMRI and so I’m really trying to understand this and then communicate it to consumers and what I ended up with the other day was that I drew a thick black line and on top of the black line I put ingredients and I had just made up some ingredients, like flour and cotton and I put those above the black line and those were the ingredients that are on the label and then below the black line are all these other things that you were talking about; like the process and the other sub ingredients that go in during the process and the fact that some of those sub ingredients are ingredients themselves which have ingredients and so we have this whole thing.

Consumers; it’s called the supply chain and so that’s all the things that go into each of the ingredients and at the end of the line all you have above that black line which is what we can see as consumers on the surface, so to speak, is like, I think of it like the earth, you know there’s the crust of the earth and you can only see the top and underneath there are all these incredible processes that are going on, the molten core and all this stuff and it’s like manufacturing is all that stuff and all we get to see is the surface. We see the end product and you get this little list that says this ingredient contains this and this and this and you never know what’s going on behind the scenes and yet organizations like yours and others that I’m aware of, you’re looking at the whole supply chain. You’re saying we can’t say that something is toxic or not toxic unless we look at the whole supply chain and yet this is an entirely new concept to consumers.

PEGGY MIARS: You’re right. When I’m out in the community or when I’m out on business trips or whatever and I’m chatting with people who ask, what do you do? and I tell them, people are amazed and excited that there is someone doing this and watching out for their interest and I’m happy to tell people what we do because they are always excited to hear about it.

DEBRA: Well we need this for every single product, not just organic food. There needs to be a structure set up so that every product gets analyzed. It’s like as a consumer advocate I actually feel….; I am going to give myself a pat on the back here, because I’ve been doing a pretty good job for over thirty years, finding and identifying products that don’t have toxic chemicals in them, enough, to make a difference in my own health and that I can see that if I don’t use this product that I can identify has this toxic chemical in it and I use something safer but the only thing I know about it is to say that it has organic tomatoes in it, you know, that’s all I know. That’s the only information I have to make that decision; but even just using that small amount of information I’ve been able to find products that are less toxic. Imagine what it would be like if there was a system all set up so that all the manufacturers would be doing what a certified organic farmer has to do for every single product.

PEGGY MIARS: Ooh my gosh, that would be so exciting! Yes, because people don’t realize that organic farmers are much more regulated and have someone looking over their shoulder much more than the non organic farmers do.

DEBRA: Yes! What you’ve described today, because I’ve been thinking about this, I’ve been watching this, I’ve been looking , I’ve been researching and everything that you’ve said is like exactly my plan of what should be happening. I mean I’ve already been drawing this all out and writing it all out and everything and I’m going, why isn’t this happening? and now you’re telling me, this is happening and we just need to take what you are doing, what that whole process is in organic farming and we need to apply it to every other product in the world.

PEGGY MIARS: Yes, I agree with that completely and I want to say one thing before we run out of time for all your listeners because we’ve been talking about certified organic production which is really why OMRI exists but I want your listeners to know that they can go to our website, and there is a free search function there. You can search for brand name products, you can search for generic products like your feather meal and that sort of thing that’s used in organic production to see what’s allowed and, I think, more importantly for your listeners, there are OMRI listed products in your home and garden stores, you know, your big box stores like Lowe’s and Home Depot and also your local independent garden stores. You can go in and find OMRI listed products there.

DEBRA: Oh, so you can go to OMRI and you are talking about OMRI listed products for growing organic?

PEGGY MIARS: For your home garden. You can find them because a lot of manufacturers have different packaging, the big bulk for the farmers and then they have consumer packaging that you will find in your local stores.

DEBRA: Thank you so much. We are going to be done with the show in about two seconds so I thank you for coming.

PEGGY MIARS: Thank you! very much.

DEBRA: Thank you; you are listening to Toxic Free Talk Radio. I’m Debra Lynn Dadd and Wow! What a show!!


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