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Analysis of the National Organic Program Proposed Rule

DOCUMENT #1

NOSB letter and legal memorandum
March 25, 1998

Kathleen Merrigan was appointed Chairperson of the NOSB Ad-Hoc Committee on the Role of the NOSB. Working with several lawyers, Kathleen had the following document prepared on behalf of the Board. During the NOSB meeting in Ontario, California (March 16-19, 1998), this document was discussed, refined and approved by the Board. The attached cover letter to the Secretary was drafted and signed by 13 of the 14 NOSB members. On March 26, Kathleen delivered this document to Secretary Glickman as well as several other political appointees and staff at the Department. It was also submitted as an official response to the December 16, 1997 Federal Register Proposed Rules.

View the NOSB letter and legal memorandum.


 

DOCUMENT #2

Beyond the "Big Three"
A comprehensive analysis of the proposed
National Organic Program


Docket #TMD-94-00-2
April 30, 1998

On April 30, 1998, Mark Keating and Kathleen Merrigan completed drafting comments to submit to the Docket on behalf of the Wallace Institute. If you have concerns or comments on the draft, please feel free to email us at: merrigan@access.digex.net.

View Beyond the "Big Three".