Managing Conflicts of Interest in the National Organic Program

[grulla]

Ann Ross
January 25, 2019

Many federal and state laws, professional bodies, and associations establish policies that recognize conflicts of interest and take steps to mitigate those conflicts. Federal employees in the executive branch of government are restricted from performing certain post-employment activities, like advising foreign political governments and parties. Similarly, there are restrictions on former congressional members, imposing “cooling off” periods before they can lobby Congress.
Lawyers are governed by strict rules of professional conduct specifically addressing potential conflicts of interest. Lawyers must obtain consent from a former client before representing a new client in matters that are averse to the interests of former clients.

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[Mr. Wizard]

Cornucopia's recommendation to address the "revolving door" between USDA certifiers and National Organic Program (NOP) employees does not go far enough. The revolving door is inevitable, but in addition to fully disclosing their former employment, these individuals should also be required to recuse themselves from dealing with their former operation for a minimum of 3 yrs. This 3 yr. period would chisel away at many of the connections and insider information, thus dampening the advantages derived from their previous employment. Full disclosure is a good start, but recusal for 3 yrs. takes it to an even higher level of integrity.