(Beyond Pesticides, December 19, 2011) The National Organic Program (NOP) of the United States Department of Agriculture (USDA) has released a comprehensive list of the expiration dates for all materials currently allowed for use in organic production and handling. These materials, which are collectively referred to as the National List of Allowed and Prohibited Substances (National List), must be reviewed by the National Organic Standards Board (NOSB) every five years. Since materials have been added to the National List on an irregular schedule, a unique subset of them comes up for reconsideration each year in a process commonly referred to as “sunset review.” The NOSB is then responsible for recommending whether to renew, remove, or restrict the use conditions for each material after which the public is invited to express its opinion through public comment proceedings. The sunset review process is separate from the NOSB’s additional responsibility to review petitions for new materials under consideration for addition to the National List. While the Secretary of Agriculture has final authority for adding materials to the National List, only those materials positively recommended by the NOSB — whether through the sunset process or new petition review – may be added.
The National List is divided into several subcategories, the most commonly known being the synthetic materials allowed in organic crop and livestock operations. It also contains numerous natural materials which are prohibited for use in organic crop and livestock production because of their adverse environmental and/or toxicological impacts. With regards to handling (processing) operations, the National List identifies all nonagricultural substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic” ingredients. Finally, the National List specifies which nonorganically produced agricultural products are allowed as ingredients in or on processed products labeled as “organic” due to the provision for commercial availability.
The allowance for materials used in organic crop, livestock and handling operations has become a heavily debated issue at recent NOSB meetings. A number of Board members have increasingly expressed the opinion that, since the allowance for synthetic materials is recognized as an exception to a system of organic production, the National List should be kept short and materials removed when they are no longer essential. Other NOSB members have adopted an approach based on deference to earlier Board decisions that recognized the material as essential at that time. Disputes have arisen over how changes in production practices and new information about the material’s environmental impact should be weighed during the sunset review. For its part, the NOP has enforced the statutory provisions for material evaluation, review and rulemaking but has stressed repeatedly that there is no inherent reason to minimize the size of the National List. For more information on key material review decisions as they arise, please visit Beyond Pesticides’ Keep Organic Strong webpage.
The next meeting of the NOSB will be held in Albuquerque, NM between May 21 and 24, 2012. More information about this meeting will be posted as it becomes available.
Source: The NOP Organic Insider
All unattributed positions and opinions in this piece are those of Beyond Pesticides.