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Spring 2015 key issues

Keeping Organic Strong: Changes in organic regulations and farming practices
National Organic Standards Board

 
Spring 2015 NOSB Meeting
Comment by April 7, 2015!

When: April 27 - 30, 2015
Where: San Diego Marriott La Jolla 4240 La Jolla Village Drive, La Jolla, CA 92037

Thespring 2015 meeting dateshave been announced, and public comments are due by April 7, 2015.Your comments and participation are critical to the integrity of the organic label.

 

To truly make an impact in the future of organic, Beyond Pesticides encourages you to:

About the Board

The 15 member board, consisting of 4 farmers, 3 environmentalists, 3 consumers, 2 food processors, and one retailer, scientist and certifying agent, votes to allow or prohibit substances and practices in certified organic food and farming. The NOSB acts as a life-line from government to the organic community as it considers input from you, the public - the concerned citizens upon whom organic integrity depends. That is why your participation is vital to the development of organic standards. Rest assured, if you submit a public comment either in person or online, your concerns will be considered by the Board.Remember that the NOSB can't take serious action to protect organic integrity without your input!

Issues Before the NOSB for Spring 2015

Materials in the list below are either the subject of petitions or the subject of sunset review. Petitioned materials must have evidence summarized in the proposals that they meet the OFPA requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices. Sunset items are already on the National List, and being considered for delisting. They are subject to the same criteria, but are being considered under NOP’s new rules.

The NOSB will vote on those materials subject to “2016 Sunset Review,” but any substantive comments on them now will be considered “untimely.” We have some procedural comments on them. Although the NOSB will not vote on those materials listed under “2017 Sunset Summaries” at this meeting, comments received after the spring meeting will be considered untimely. The subcommittees have not published summaries of evidence concerning all of the 2017 sunset materials.

There are also some very important issues in discussion documents dealing with defining and prevention of contamination by genetically engineered organisms ("excluded methods" in NOP terminology) and prevention of contamination in organic farm inputs. Discussion documents are not up for a vote, but form the basis for future proposals; this is a valuable opportunity to give input.

Issues Featured in Action Alert (See Rest of Issues Below)

 

Table of Contents/Navigation to Beyond Pesticides' Comments and Summaries

Crops Subcommittee

Materials/GMO ad hoc Subcommittees

Compliance, Accreditation, and Certification Subcommittee

Handling Subcommittee

Livestock Subcommittee

Policy Development Subcommittee

Cross-Cutting Issues
 


NOSB Quick Links!

 

See Full Meeting Agenda

 

Take Action at Regulations.gov!
(Comments Due April, 7 2015!)

 

See All Meeting Materials and Issues

 

The Organic Foods Production Act

 

Crops Subcommittee
Proposals on Petitions
  • Exhaust Gas – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Releases of exhaust gas contribute to a number of environmental problems. According to the Technical Review (TR), “Specifically, exhaust gas emissions contribute to air pollution, and four of its components (particulate matter, carbon monoxide, nitrogen oxides and sulfur dioxide) are criteria pollutants according to US EPA.” More importantly, other organisms inhabit the burrows made by rodents. The use of exhaust gas is unnecessary due to the availability of alternatives like traps, barriers, natural predation, and other physical control methods. Additionally, because exhaust gas does not belong in any of the categories of allowed synthetic inputs in OFPA, the use of this substance as a rodenticide is incompatible with organic practices.
  • Calcium Sulfate – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Calcium sulfate fails the OFPA criteria for necessity and compatibility. In addition, testing would be required to determine whether a particular batch of gypsum contains toxic contaminants such as heavy metals. Calcium sulfate is not only incompatible with organic practices, but synthetic calcium sulfate is not necessary due to the abundance of nonsynthetic gypsum, as well as other sources of calcium and sulfur.
  • 3-decene-2-one – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: 3-decen-2-one is a synthetic potato sprout inhibitor. It fails the OFPA criteria for necessity and compatibility. In addition, its manufacture requires the use of hazardous raw materials. The material is also a synthetic preservative and may pose hazards to workers via its manufacturing process, in which the raw materials, acetone and hepaldehyde, which are volatile, flammable, and toxic, are used.

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Discussion Document
  • Contamination Issues in Farm Inputs
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Unfortunately, organic production is embedded in a world that is increasingly polluted, and many of the pollutants persist much longer than we would like. We can’t just do the right thing without knowing what others are doing. We support research into all of the contaminants and pathways mentioned in this report. We support research into means of preventing the contamination, which we believe must include restrictions on the way other people use many of those materials. Organic farmers are good neighbors —they take care of other people’s waste, and they create buffer zones and havens of biodiversity that help their non-organic neighbors. Protecting organic farms from outside contamination will require a gatekeeper looking over what comes onto the farm, but it should also require more responsibility for those who use potentially dangerous materials. It all starts with gathering information, and we are happy to see that the NOSB is taking the first steps. We support the approach of addressing contaminants based on feedstocks and pathways and urge the CS to begin as soon as possible with the first ones identified.

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Crops 2016 Sunset Reviews 205.601 (Synthetic Materials Allowed in Organic Crop Production): PDF

  • Ferric Phosphate
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Ferric phosphate is used as a molluscicide for of slugs and snails. Although harmless to molluscs and earthworms alone as it naturally occurs in soil, ferric phosphate is allowed be combined with chelating agents such as EDTA or EDDS, synergists that make it toxic to snails and slugs, but also earthworms and beneficial soil life.
  • Hydrogen Chloride
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Hydrogen chloride, the gaseous form of hydrochloric acid, is extremely corrosive, and very harmful to human health, especially in the occupational setting where hydrogen chloride is used and high levels of exposure can occur. Hydrogen chloride also has the potential to cause damage to the soil and other organisms in the case of a spill. Hydrogen chloride is not compatible with organic and sustainable agriculture. The use of hydrogen chloride supports the chlorine chemical industry, which is responsible for pollution by some of the most toxic chemicals known, including dioxins and PCBs. However, organic cotton growers can only obtain seeds treated with hydrogen chloride, so removing it from the National List would not prevent its use.

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Crops 2017 Sunset Summaries 205.601 (Synthetic Materials Allowed in Organic Crop Production): PDF

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Crops 2017 Sunset Summaries 205.602 (Natural Materials Prohibited in Organic Crop Production): PDF

  • SEE BEYOND PESTICIDES' COMMENT ON PROHIBITED NATURAL MATERIALS HERE
  • SUBMIT YOUR COMMENT HERE
  • Background: Natural (nonsynthetic) materials that are prohibited in organic crop production are listed on §205.602. Although some of the materials on §602 are prohibited from use in organic production directly by OFPA, and others, it appears, are listed based on common sense, good government requires that regulations be backed up by reference to legal criteria. Therefore, we were pleased to see that several of the materials on §602 have been supported by checklists. We hope that before the next meeting, such justification is produced for the remaining materials. Finally, although tobacco dust/nicotine sulfate is no longer available for sale in the United States, it should remain on §602 to discourage use of homemade tobacco dust.
  • Ash from manure burning
  • Arsenic
  • Lead salts
  • Potassium chloride
  • Sodium fluoaluminate
  • Strychnine
  • Tobacco dust (nicotine sulfate)

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Materials/GMO ad hoc Subcommittees
Discussion Documents

NOP Nanotech Policy

Workplan

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Compliance, Accreditation, and Certification Subcommittee
Proposal

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Handling Subcommittee
Proposals on Petitions
  • Glycerin – petitioned for removal
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: The issues raised by this petition are complex, and the approach to listing glycerin needs to recognize this. Glycerin made by hydrolysis of fats and oil and glycerin made by fermentation should be listed separately. In addition, some of the issues raised by this petition are beyond the purview of the Handling Subcommittee and we request that the Materials/GMO Subcommittee add them to its workplan.
  • Whole Algal Flour – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Whole algal flour is not essential or compatible with organic production and handling. We believe that there is too much confidential business information to determine that it meets criteria under the Organic Foods Production Act (OFPA). It would replace natural foods including cream, milk, eggs and egg yolks, and butter or shortening. All of these natural foods contribute nutrients to the diet, and it is not clear what whole algal flour contributes to the diet.
  • Ammonium Hydroxide – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Ammonium hydroxide should be delisted. It is a serious irritant, toxic by all routes of exposure, known to pollute air and water, contributes to the greenhouse effect, and is toxic to fish and other aquatic species. It is not essential because there are other boiler additives on the National List that can be used for the same purpose, and there are practices that can be used in place of boiler additives. As an unnecessary hazardous substance, it is not consistent with organic production practices.
  • PGME – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: We support the subcommittee’s proposal to deny the petition for the use of PGME in boiler water in the manufacture of organic feed pellets. Although the petition portrays PGME as innocuous, and the Technical Review indicates that only the lowest molecular weight (MW) forms are toxic, the scientific literature and test results submitted to EPA indicate otherwise.
  • Ancillary Substances for Microorganisms
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: The process for reviewing ancillary substances in microorganisms does not live up to the standards of the procedure established by the NOSB. The NOSB must: (1) review each ancillary substance for impacts on human health and the environment rather than microbial products containing them, with a finding that the substance “would not be harmful to human health or the environment,” rather than a statement that no literature was found; (2) provide a list of alternative materials and methods for each ancillary substance, or a reason that none is available; (3) review each ancillary substance for consistency and compatibility, including whether genetically engineered organisms were used in its production; (4) consider past actions of the NOSB relating to the substances, and (5) distinguish between synthetic and nonsynthetic ancillary substances.

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Handling 2016 Sunset Reviews 205.605 (Nonsynthetic Nonorganic Nonagricultural Materials Allowed in Organic Processing and Handling): PDF

 

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Handling 2017 Sunset Summaries 205.605(a) (Synthetic Nonorganic Nonagricultural Materials Allowed in Organic Processing and Handling): PDF

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Handling 2017 Sunset Summaries 205.605(b) (Synthetic Nonorganic Nonagricultural Materials Allowed in Organic Processing and Handling): PDF

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Handling 2017 Sunset Summaries 205.606 (Nonorganic Agricultural Materials Allowed in Organic Processing and Handling): PDF
  • SEE BEYOND PESTICIDES' COMMENT HERE
  • SUBMIT YOUR COMMENT HERE
  • Background: Nonorganic agricultural materials allowed in organic processing and handling are listed as §205.606. Nonorganic Agricultural Ingredients in organic products should be eliminated based on health and environmental impacts and the ability to produce them organically. Many of these materials have never been subject to a technical review. In many cases, the NOSB gave no documentation for decisions, with reviews uniformly ignoring environmental and health impacts of their chemical-intensive agricultural production, including the use of pesticides. Additionally, organic agriculture can now supply most, if not all, of these materials.
  • Casings
  • Celery powder
  • Chia (Salvia hispanica L.)
  • Colors: Various
  • Dillweed oil
  • Fish oil
  • Fructooligosaccharides
  • Galangal, frozen
  • Gelatin
  • Gums: Arabic, Carob bean, Guar, Locust bean
  • Inulin-oligofructose enriched
  • Kelp
  • Konjac flour
  • Lecithin—de-oiled
  • Lemongrass-frozen
  • Orange pulp, dried
  • Orange Shellac - unbleached
  • Pectin (non-amidated forms only)
  • Peppers (Chipotle chile)
  • Seaweed, Pacific kombu
  • Starches, Cornstarch (native), Sweet potato
  • Turkish bay leaves
  • Wakame seaweed (Undaria pinnatifida)
  • Whey protein concentrate

     

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Workplan

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Livestock Subcommittee
Proposals on Petitions
  • Methionine (MET) – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Synthetic methionine should be phased out of organic poultry feed as the NOSB originally decided. Methionine is an amino acid that acts as a growth promoter (comparable to the synthetic growth promoter rGBH used in dairy cows). The Livestock Subcommittee (LS) proposal would increase use of synthetic methionine above currently allowed levels without any scientific support. Synthetic methionine is not necessary for animal welfare, but is needed to sustain the factory model of egg and broiler production. Neither synthetic amino acids nor synthetic growth promoters are compatible with organic practices. While the LS proposes a resolution to phase out the use of synthetic methionine, it failed to consider including an expiration date –for which the proposal was sent back to the subcommittee and without which the phase out cannot be accomplished.
  • Zinc Sulfate – petitioned
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: A petition has been received to allow zinc sulfate to be used as a footbath for control of foot rot in livestock, particularly dairy sheep, which are poisoned by the copper sulfate used for cattle. The main issue is disposal of waste, which is also an issue with copper sulfate. If the NOSB approves zinc sulfate, it should annotate it, “must be used and disposed of in a manner that minimizes accumulation in the soil, as shown by routine soil testing.”

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Discussion Document

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Livestock 2017 Sunset Summaries 205.603 (Synthetic Materials Allowed in Organic Livestock Production) and 205.604 (Natural Materials Prohibited in Organic Livestock Production): PDF
  • EPA List 4 - Inerts of Minimal Concern
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: So-called “inert” ingredients in pesticide products are neither chemically nor biologically inert. They are designed to enhance the pesticidal activity of pesticide products and can have toxic properties that do not meet the standards of the Organic Foods Production Act (OFPA). Active ingredients in pesticide products used in organic production have been carefully screened to ensure that they meet the requirements of OFPA, thus presenting little hazard to people and ecosystems, from their manufacture through their use and disposal. So-called “inert” ingredients, on the other hand, have not received the same level of scrutiny to ensure that they meet OFPA standards. Reliance on the registration of pesticide products with inert ingredients by the U.S. Environmental Protection Agency does not ensure that the standards of OFPA are met, given that the reviews and use allowances under the agency’s authorizing legislation (the Federal Insecticide, Fungicide and Rodenticide Act) are based on different and often incompatible standards. In addition, many pesticide product formulations are composed of mostly “inert” ingredients. As a result, the most hazardous part of pesticide products used in organic production may actually be the so-called “inert” ingredients. The NOSB should (1) Tell NOP to implement the review plan approved unanimously by the board in 2012, (2) amend the listing to remove toxic nonylphenol ethoxylates (NPEs), and (3) amend the list with expiration dates for the remaining classes of “inerts.”
  • Methionine
    • SEE BEYOND PESTICIDES' COMMENT HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Synthetic methionine should be phased out of organic poultry feed as the NOSB originally decided. Methionine is an amino acid that acts as a growth promoter (comparable to the synthetic growth promoter rGBH used in dairy cows). The Livestock Subcommittee (LS) proposal would increase use of synthetic methionine above currently allowed levels without any scientific support. Synthetic methionine is not necessary for animal welfare, but is needed to sustain the factory model of egg and broiler production. Neither synthetic amino acids nor synthetic growth promoters are compatible with organic practices. While the LS proposes a resolution to phase out the use of synthetic methionine, it failed to consider including an expiration date –for which the proposal was sent back to the subcommittee and without which the phase out cannot be accomplished.
  • Chlorine Materials: Calcium hypochlorite, Chlorine dioxide, Sodium hypochlorite
    • SEE BEYOND PESTICIDES' COMMENTS ON SANITIZERS HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: 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.
  • Alcohols: Ethanol, Isopropanol
  • Hydrogen peroxide
    • SEE BEYOND PESTICIDES' COMMENTS ON SANITIZERS HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Hydrogen peroxide is relatively nontoxic in low concentrations, though it is a powerful oxidizer and may damage soil biota. Repeated exposure to vapor is harmful. It breaks down quickly to oxygen and water, and therefore does not have a residual effect. When the NOSB reviews needs for sanitizers, it should ask whether concentrated hydrogen peroxide is needed.
  • Iodine
    • SEE BEYOND PESTICIDES' COMMENTS ON SANITIZERS HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Iodine is frequently formulated as iodophors –with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs) are strong endocrine disruptors with impacts on many species, including gender changes. Organic alternatives and natural alternatives exist for some uses. The iodine listings should not permit iodophors containing APs and APEs. Since the listings cannot be annotated at sunset, iodine should be removed from the National List.
  • Peroxyacetic/Peracetic acid
    • SEE BEYOND PESTICIDES' COMMENTS ON SANITIZERS HERE
    • SUBMIT YOUR COMMENT HERE
    • Background: Peracetic acid is another powerful oxidizer, but it breaks down to harmless materials, unlike chlorine. Peracetic acid is an irritant of the skin, eyes, mucous membranes, and respiratory tract. When the NOSB reviews needs for sanitizers, it should ask whether peracetic acid is needed.
  • Copper sulfate
  • Sucrose octanoate esters
  • Excipients
  • Formic Acid
  • Tolazoline
  • Xylazine
  • Butorphanol
  • Aspirin
  • Atropine
  • Biologics, Vaccines
  • Chlorhexidine
  • Electrolytes
  • Flunixin
  • Furosemide
  • Glucose
  • Glycerin
  • Magnesium hydroxide
  • Magnesium sulfate
  • Oxytocin
  • Parasiticides: Fenbendazole, Ivermectin, Moxidectin
  • Phosphoric acid
  • Poloxalene
  • Iodine (Teat Dip)
  • Lidocaine
  • Lime, hydrated
  • Mineral oil
  • Procaine
  • Trace minerals
  • Vitamins

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Policy Development Subcommittee

Update on Status of PDS and Fall 2013 Documents

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Cross-Cutting Issues

NOP Nanotech Policy

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Sanitizers

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Soaps

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