(Beyond Pesticides, March 17, 2017) Make your voice heard and submit comments NOW on allowed materials in organic production! The National Organic Standards Board (NOSB) meeting dates for spring 2017 have been announced and public comments are due by March 30, 2017. As usual, there are many important issues that are under NOSB consideration, which you can view by clicking here. Your comments and participation are critical to the integrity of the organic label.
The NOSB is not immune to delays experienced by agencies throughout the federal government. NOSB proposals were scheduled to be made available to the public on March 1, allowing 30 days for the public to formulate responses before the comment period closes. As of this writing, the proposals have still not been published, but much can be inferred from Subcommittee notes, petition materials, and past experience. Many of the issues before the NOSB are materials due to sunset off the National List of Allowed and Prohibited Substances (National List) in 2017. Some others are perennial issues of special concern for us –such as “inerts” (undisclosed ingredients) and chlorine-based sanitizers. So, we have written what we can, and we encourage you to make use of our efforts –and we will let you know if and when the proposals are published.
Our positions, which we hope you will use as the basis for your comments, can be found here. 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.
As mentioned above, some of the major issues before the spring 2017 National Organic Standards Board include:
There continues to be an unconscionable delay in implementing NOSB recommendations for replacing the obsolete references to EPA List 3 and List 4 “inert” ingredients on the National List with listings of actual approved ingredients in pesticide products that are not labeled active (those that target the pest). These ingredients frequently compose as much as 99% of pesticide products, and due to NOSB scrutiny of active ingredients, they may be the most hazardous ingredients in pesticide products used in organic production. The NOSB must insist that NOP move forward with implementing the NOSB recommendations on “inert” ingredients, beginning with the Memorandum of Understanding between USDA and EPA that establishes the responsibilities of the National Organic Program (NOP), EPA, and the NOSB.
This includes calcium hypochlorite, chlorine dioxide, and sodium hypochlorite for crops; acidified sodium chlorite, calcium hypochlorite, chlorine dioxide, and sodium hypochlorite for handling; and calcium hypochlorite, chlorine dioxide, and sodium hypchlorite for livestock.
To the extent possible, organic should be chlorine-free. Chlorine is hazardous in its production, transportation, storage, use, and disposal. EPA’s Design for the Environment has identified safer viable alternatives for some or all uses, including other materials on the National List. It is time for the NOSB to update its thinking and approach to cleaners and disinfectants. Several steps need to be taken:
- The Organic Foods Production Act (OFPA) requires that materials on the National List are itemized “by specific use or application.” Justification for the listing of chlorine materials requires that the NOSB identify the uses for which they are needed. Needs for cleaners, sanitizers, disinfectants, and sterilants must be distinguished.
- Freedom from microbes is not always good. Not only is sterility often unnecessary, but it is also sometimes counterproductive because eliminating benign microbes can make room for spoilage organisms or pathogens.
- Establishing the need for a “sanitizer” requires a demonstration that a certain degree of freedom from microbes is required. The NOSB must establish when microbes should be removed from what and the degree to which they must be removed.
- Alternative practices and materials must be considered, such as those identified by technical reviews and EPA’s Safer Choice Program.
- NOSB must examine the need for these materials in light of alternatives and hazards.
- Chlorine compounds have long been identified as hazardous to humans and the environment. The NOSB, in reviewing the listings of these materials, must delve into the needs, alternatives, and hazards.
The plan to address contaminated inputs in organic production –last addressed by the NOSB two years ago– is needed more urgently than ever. The problem of contaminated water resources only adds to the problems already identified, including antibiotics in manure, pesticides in lawn wastes, and others. We urge the NOSB to devote resources to furthering the plan and its implementation, including the development of a discussion document on water contaminated by oil and gas production.
NOSB Meeting Details:
Wednesday, April 19, 2017 – 8:30am to Friday, April 21, 2017 – 5:00pm
Sheraton Denver Downtown Hotel, 1550 Court Place, Denver, CO 80202
- Thursday, April 13, 2017, 1:00pm-4:00pm ET via webinar; 3 minute comment slot
- Wednesday/Thursday, April 19 and 20, 2017 during the face-to-face meeting; 3 minute comment slot
Oral commenters may only sign up for one comment slot, and the sign-up deadline is March 30, 2017 at 11:59pm. Again, you can reserve an oral comment slot by clicking here.
We ask that you submit comments on as many issues and materials as you can by the 11:59pm, March 30, 2017 deadline. For help crafting your comments, view Beyond Pesticides’ commenting guide. For all other questions, please go to Beyond Pesticides’ Keeping Organic Strong webpage to learn more about these and other substantive issues and provide a unique public comment.
Thank you for helping to protect and uphold organic integrity!
All unattributed positions and opinions in this piece are those of Beyond Pesticides.