25
Sep
Take Action: Organic Integrity on the Agenda of Upcoming USDA Meeting
(Beyond Pesticides, September 25, 2023) It happens twice a year. The transparent process of a stakeholder board of farmers, consumers, environmentalists, a scientist, retailer, and certifier get together as members of the National Organic Standards Board (NOSB) and vote on allowable materials and standards in organic agriculture. This Congressionally mandated board has authorities not often given to people outside of government—authorities to determine what should be allowed in organic food production, under assessments of synthetic and natural substances. And the underlying law that makes this happen, the Organic Foods Production Act (OFPA), stipulates that the Secretary of Agriculture may not allow synthetic and prohibited natural materials unless they are recommended by the NOSB.
The values and principles embedded in OFPA far exceed the standards of health and environmental protection of any other health and environmental laws, which establish risk mitigation measures to determine allowable harm, under a set of guiding standards that require the board to (i) protect health (from production of inputs to their disposal), (ii) ensure compatibility with organic systems (with determinations that inputs do not hurt biodiversity of the soil and the ecosystem), and (iii) determine essentiality (is the substance under review necessary given the availability of other materials). Also unique to OFPA implementation is a public participation process that establishes a twice-yearly mechanism for public input to the NOSB and a uniquely efficient process for responding to those comments. As can be seen from Beyond Pesticides comments to the NOSB (see Keeping Organic Strong), there is always room for improvement and updating based on new scientific studies and new materials coming on line, ensuring that the board is always involved in an interactive process of continuous improvement.
The public comment period, which ends on September 28, precedes the upcoming public comment webinar on October 17 and 19 and deliberative hearing October 24-26—concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov. by 11:59 pm EDT, September 28. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October. The public’s personal concern in upholding the integrity of organic standards is critical, given the pressure from some in the food and chemical industry to weaken organic standards. Public input is important because the success of the organic market is totally dependent on public trust in the USDA certified organic label. Organic is not just important for the individual health of consumers, but has wide ranging benefits for improving  environmental protection, stopping biodiversity collapse, and drawing down atmospheric carbon to reverse the climate emergency. The holistic benefits of organic land management offer a solution to these existential crises that threaten the sustainability of life.
The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and the Fall 2023 issues page. See Keeping Organic Strong and the Fall 2023 issues page. Â
Some important issues that need your comments:
- “Inert†ingredients used in organic agriculture must be evaluated individually.“Inert†ingredients are not necessarily biologically or chemically inert—in almost every category of harm, there are more harmful “inerts†than active substances used in organic production. OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application†based on a recommendation by the NOSB, following procedures in OFPA. The NOSB has repeatedly passed recommendations telling NOP to evaluate individual “inerts.â€
- Plastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Organic should lead the way. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging.
- Nonorganic ingredients should be eliminated from processed foods under the NOSB review (or sunset) process. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?†The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.
Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste language from the comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)Â
Thank you for keeping organic strong!Â
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September 26th, 2023 at 5:39 am“Inert†ingredients used in organic agriculture must be evaluated individually.“Inert†ingredients are not necessarily biologically or chemically inert—in almost every category of harm, there are more harmful “inerts†than active substances used in organic production. OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application†based on a recommendation by the NOSB, following procedures in OFPA. The NOSB has repeatedly passed recommendations telling NOP to evaluate individual “inerts.â€
September 27th, 2023 at 6:35 pmPlastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Organic should lead the way. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging.
Nonorganic ingredients should be eliminated from processed foods under the NOSB review (or sunset) process. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?†The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.
THEY ARE NO LONGER ACCEPTING ANY COMMENTS!!
September 27th, 2023 at 6:43 pmThe National Environmental Policy Act (NEPA) was passed over 50 years ago and remains relevant for communities across the country today. This policy has long ensured that environmental impact is a consideration for actions taken by the government. Not only this, but because of NEPA we all get a voice in the process, deciding what is best for our health, the local environment, and our communities.
The White House Council on Environmental Quality (CEQ) is seeking comments on proposed revisions to NEPA after it was stripped of many of its best attributes by the previous administration. The proposal rights the wrongs of those changes while acknowledging the climate crisis we face and the need for environmental justice for all.
September 28th, 2023 at 12:54 am“Inert†ingredients used in organic agriculture must be evaluated individually.“Inert†ingredients are not necessarily biologically or chemically inert—in almost every category of harm, there are more harmful “inerts†than active substances used in organic production. OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application†based on a recommendation by the NOSB, following procedures in OFPA. The NOSB has repeatedly passed recommendations telling NOP to evaluate individual “inerts.â€
September 28th, 2023 at 12:05 pmPlastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Organic should lead the way. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging.
Nonorganic ingredients should be eliminated from processed foods under the NOSB review (or sunset) process. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?†The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials
“Inert†ingredients used in organic agriculture must be evaluated individually.“Inert†ingredients are not necessarily biologically or chemically inert—in almost every category of harm, there are more harmful “inerts†than active substances used in organic production. OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application†based on a recommendation by the NOSB, following procedures in OFPA. The NOSB has repeatedly passed recommendations telling NOP to evaluate individual “inerts.â€
September 28th, 2023 at 1:01 pmPlastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Organic should lead the way. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging.
Nonorganic ingredients should be eliminated from processed foods under the NOSB review (or sunset) process. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?†The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.
We were better at one time. Through the years, everything has been done quicker, easier, cheaper, at the cost of the environment. We need to think of ways to reverse this trend, & help the earth & thus everyone else in the long run.
Don’t forget about cutting back our carbon footprint. (and all that entails, including reduce, refuse, reuse, recycle, compost—when you can safely, & living as simply as possible, cutting back on excess, downsizing, etc . . .).
I’m trying, but I think we could do more to encourage others around the world. Including setting a good example ourselves. I’m not sure Trump did the wrong thing. I was not in favor of the Paris Agreement for my own reasons, and I am a tree hugger. I also love this planet & all in it. but the nuclear option could blow it for all of us. (making it worse than it could ever get—because nuclear energy is very dangerous) I sometimes wonder about people who are pushing for the nuclear option. Do they just not know the past mishaps? do they have too much trust in humanity? do they not think of terrorism or other such deeds? Not to mention natural disasters?, etc . . . I think that was a mistake. It, nuclear energy, should not have been included in the answer to our problems. & I worry that this is buried in this Green New Deal as well.
Re a Climate Emergency, another problem is that Haste Makes Waste & many times in our urgency to do good we move too fast for our own good & the good of others. Someone/many may suffer as a result & there may be no quick remedies before much suffering by many. So we need to take it slow by testing small areas first & then progressing, realizing that some things will not show up right away. But the first steps above could start earlier. And what about hybrids? Solar/Electric regular/electric, etc . . ? They are a great way to start transitioning. Not to mention we all need to cut down on our energy consumption. Where is Carter? Can anyone help out in that matter? But in any case we need to realize that we may need to make changes for the best of all.
This is the best time to realize that all people, animals, beings/creatures, spirits, etc . . . dwell in the same space: Earth. We are the past, present, & future. We are all above, below, on and or in the earth. It is the home of us all & we all need each other whether we know it or not. We should make all plans keeping the future of all in mind. We are all connected, so what we do in one part of the world will eventually get to another.
& I hope you will join me in praying for the president & that he & his team will realize our wishes & understand they are for his benefit as well as the benefit for everyone else in the long run.
If you’d like, you could pass on my wishes to him as well.
I share a variety of perspectives. no matter who we are or where we came from, we can thank God that we are here & that we do have a lot to be thankful for.
Maybe not as much as some. But a lot more than others. yes, there are times when I feel worse than others, that happens to all of us, no matter who we are. But thank God we are here. We can also agree to disagree on many issues. That’s life.
The whole point is that we are all here, thank God, & we all have life,
& we all are together.
Happy Fall; Stay safe & Take care & God Bless All . . .
p.s. do not forget Indian wisdom, “you cannot eat, drink, or breathe moneyâ€. The earth is the home of us all. We need to take care of it/her so that it/she may take care of us.
September 29th, 2023 at 1:29 pm