(Beyond Pesticides, April 20, 2012) The public comment period on proposals from the National Organic Standards Board (NOSB) regarding updates to standards governing organic food and farming remain open until then end of Thursday May 3, 2012. Beyond Pesticides has updated our Keeping Organic Strong web page with information on a number of issues that the board will consider at its meeting in Albuquerque, NM May 22-25, 2012. We have included links to the NOSB proposals which will be voted on and provided our perspective on these issues. We urge you to take a moment to voice your opinion on these proposals. You are welcome to use our suggestions to formulate your comments on each issue or to make them entirely original. Targeted comments on specific issues will be more effective than general comments regarding organic food as a whole.
Public participation is vital to the development of organic standards, as we are all stakeholders in ensuring a safe and sustainable food supply. The public comment process represents the best opportunity for consumers, as well as farmers and processors, to have a voice as these standards are debated and adopted by the NOSB. Many of the proposed recommendations are available on our website. To read all of the recommendations from the various NOSB committees, go to this page and select each committee from the drop down menu. The proposed recommendations are then sorted by date. You can also view the tentative agenda for the full spring 2012 meeting.
Some of the issues that will be debated can be found below. To find information on other issues as well as details on how to submit your comments, visit our Keeping Organic Strong page.
Issues Before the NOSB for Spring 2012
Beyond Pesticides urges public comments on the issues listed below. We will continue to update this page with more information and resources as they become available. All these issues and use of substances have direct bearing on organic integrity, so it is critical to have public input into the NOSB decision making process. As you write your comments, you may want to refer to the Principles of Organic Production and Handling adopted by the NOSB. Submit your comments before May 3.
We support the committee proposal to address and review inert ingredients as individual materials, as any and all synthetics used in organic production must be reviewed. Inert ingredients previously categorized by the EPA as “List 3,” meaning that they were of unknown toxicity, have until this point been categorically allowed in pheromone dispensers. However, this allowance is out of sync with the National List review process and was never intended to be a long-term solution. The current proposal would rectify this by ensuring that the board reviews the small handful of ingredients that had been allowed as part of the List 3 classification. We urge the board to adopt this proposal and ensure that these materials, like any synthetics in organic production, are safe and appropriate for use.
Though it is not part of the current proposal, we also urge the board to review the allowance of inert ingredients that had been classified by EPA as “List 4” reduced risk inerts. As we know, “inert” ingredients in pesticides are in no way inert. They are simply not the claimed active ingredients in the pesticide products, and may have negative impacts on human health and ecological systems. The Organic Foods Production Act does not make any mention of a special allowance or exception for inert ingredients in the review of materials. All synthetic materials used in organic production must be subject to individual review by the NOSB. We urge the board to adopt a policy which would implement this practice.
Regardless of the strategy for addressing the former List 4 materials, the three or four former List 3 chemicals must be addressed immediately with a full review as required by the Organic Foods Production Act. These chemicals never should have been listed without review, and their listing cannot be justified by any rationale applied to the former List 4 materials. Submit comments.
We urge the NOSB to reject the proposal from the Livestock Committee to allow the use of GMO vaccines without review in emergency situations. Of the approximately 73 registered animal vaccines, 13 are produced using genetically modified organisms (GMOs, also known as “excluded methods” in organic rules). GMO vaccines are not legally allowed in organic production. This recommendation proposes a change which will allow GMO vaccines only in a declared emergency without losing organic status of livestock.
The Livestock Committee does not dispute the fact that the categorical approval of GMO vaccines fails the NOSB’s criteria regarding need, impacts on humans and the environment, and compatibility with organic principles. The recommendation would allow unreviewed GMO vaccines to be used in organic production under certain prescribed “emergency” conditions. We are concerned with the possibility for abuse of such an emergency allowance, in part because we have seen how emergency exemptions for pesticide use have been misused, in spite of every effort to tightly define an “emergency.” Submit comments.
We urge the NOSB to reject the recommendation of the Handling Committee and to remove carrageenan from the National List. Carrageenan is extracted from certain red seaweeds and is used as a bulking agent, carrier, emulsifier, gelling agent, glazing agent, humectant, stabilizer, or thickener in a variety of foods. The Handling Committee is recommending that carrageenan be reclassified as a synthetic material. However, the technical review of material shows severe health effects from carrageenan, including “induction or promotion of gastrointestinal tract inflammation, ulcerations and/or neoplasms.” It also documents serious ecological impacts from both harvesting of wild seaweeds as well as culture of certain species for carrageenan production. Furthermore, carrageenan is unnecessary. The USDA technical review on the material lists a number of substitutes that “may be substituted for carrageenan to achieve a similar functionality when used either alone or in combinations.” The Cornucopia Institute has surveyed organic products, and found that every product made with carrageenan can be made without it. Some people prefer food that has none of these materials. Submit Comments.