(Beyond Pesticides, September 30, 2016) Stand up for organic! The public comment period has opened on the National Organic Standards Board (NOSB) proposed recommendations affecting organic standards, materials and policy. The fall 2016 meeting dates have been announced and public comments are due by October 26, 2016. Your comments and participation are critical to the integrity of the organic label. Make your voice heard before the comment period closes. We’ve made tremendous progress in creating an organic food production system. Let’s not let USDA turn back the clock.
Beyond Pesticides has begun to analyze the numerous recommendations and are providing you with our positions that we hope you will use as the basis for your comments. We will provide positions on additional topics in the near future. Please feel free to develop your own comments or cut and paste ours. If you cut and paste our comments into regulations.gov, please first put a personal note of concern in order to reflect the importance if these issues to you as an organic consumer, farmer or other concerned party.
Some of the major issues before the fall 2016 National Organic Standards Board include:
- Chlorine Dioxide Gas: Beyond Pesticides is appalled that the NOSB Handling Subcommittee (HS) would propose adding chlorine dioxide gas to the National List and we maintain that the petition should be rejected because it fails to meet all Organic Foods Production Act (OFPA) criteria. The petitioned product has a conditional registration from the Environmental Protection Agneyc (EPA), meaning that not all essential data have been submitted. It is not labeled for this use. The necessary tolerances or exemptions from tolerances do not exist. It is a hazardous chemical used to take the place of care in handling and less hazardous materials. Because the petitioner created confusion around the petitioned substance, important information about the hazards of chlorine dioxide gas and its regulation by EPA were hidden from the HS in its deliberations. The NOSB should not approve more sanitizers —particularly chlorine-based sanitizers””until performing a comprehensive review of sanitizers’ adverse effects to health and the environment and their need (essentiality) in organic production.
- Carrageenan: Beyond Pesticides opposes the relisting of carrageenan on §205.605(a) and believes that the substance should be removed from the National List. Carrageenan should be reclassified as a synthetic. The NOSB must take a precautionary approach when assessing the studies that refute findings of health effects as they were performed by the same group of industry-supported scientists. Even giving equal weight to industry-supported and independent research, the NOSB must accept the existence of science pointing to serious health consequences associated with the consumption of carrageenan and act to protect organic consumers. The evidence summarized by the 2015 Technical Review came up with a verdict of mixed results on virtually every issue regarding food grade (high molecular weight) carrageenan. However, there is widespread agreement that poligeenan, which contaminates food grade carrageenan at unknown and uncontrollable levels, does cause adverse effects, including cancer. The production causes adverse environmental impacts. And it is not necessary —organic processors have been moving away from the use of carrageen because of consumer pressure since it was last considered for sunset.
- Hydroponics: Beyond Pesticides supports the view of the majority of the Crops Subcommittee to recommend that hydroponics, aeroponics, bioponics and aquaponics methods should not be considered eligible for organic certification. Organic production depends upon the “Law of Return,” which together with the rule “Feed the soil, not the plant,” and the promotion of biodiversity, provide the ecological basis for organic systems. Hydroponic/aeroponic/bioponic/aquaponics systems are not consistent with these principles in organic production. Somewhere along the continuum between in-ground production and bioponics is a line separating those methods of production that can be certified organic from those that cannot. We can say that the line is somewhere along that continuum —in-ground production can be certified organic, while hydroponics/aeroponics/bioponics/aquaponics cannot.
- EPA List 3 — Inerts of Unknown Toxicity: The NOSB must take the sunset review of List 3 “inerts” seriously. Although List 3 “inerts” are included in the annotation change approved at the fall 2015 NOSB meeting, it may be several years before that annotation takes effect. The NOSB has identified the three List 3 “inerts” in use in organic production, and should review them according to OFPA criteria as required by law rather than simply waiting for the annotation change to take effect. The former “List 3 inerts,” which were approved for use only in passive pheromone dispensers, have received special treatment —the law did not intend for “inerts” on List 3 to be allowed in organic production. The definition of “passive polymeric dispenser products” that was included in the spring 2012 NOSB recommendation was refused by the National Organic Program NOP. Therefore, this small group of chemicals has questionable status. From Beyond Pesticides’review of these chemicals, we think it quite likely that at least some will be found to be acceptable when reviewed by the NOSB, but the existence of such an exceptional listing does not support the integrity.
Please go to Beyond Pesticides’ Keeping Organic Strong webpage to learn more about these and other substantive issues, and to provide a unique public comment to the NOSB.
Thank you for helping to protect and uphold organic integrity!
All unattributed positions and opinions in this piece are those of Beyond Pesticides.