• Take Action
• Keep Organic Strong Through Continuous Improvement!

The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by 11:59 PM EDT on September 30, 2024. This precedes the upcoming public comment webinar on October 15 and 17 and a deliberative board hearing on October 22-24—concerning how organic food is produced.

• • Sign up to speak at the webinar by 11:59 pm EDT on September 30. (Speaking slots are generally filled early.)
  • Written comments can be submitted via our form or directly through Regulations.gov.
  • Links to the virtual comment webinars and public meeting will be posted on this page in early October. 

The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials (substances) allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health. 

>> Click here to submit your comments to the National Organic Standard Board by September 30.

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 stay tuned for updates to our Fall 2024 issues page! 

Some priority issues for Beyond Pesticides at this meeting are: 

“Inert” ingredients used in organic production. USDA's National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection Agency (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA.  

The Materials Subcommittee has proposed two options for addressing this problem.  

• • The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling. 
     
  • The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food and not adverse effects to the environment and workers, falling short of the holistic assessment required by the organic law. 

Compost regulations. The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. Beyond Pesticides supports the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a 'de minimis' doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.” 

Meloxicam in organic livestock. The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes to list the drug without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.”  

Beyond Pesticides opposes the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.  

We urge you to submit comments to the docket on the above issues and to add a sentence or two at the beginning of the comments explaining why organic is important to you! For those who prefer to copy and paste comments directly to Regulations.gov, please see a copy of our comments included below.

>> Click here to submit your comments to the National Organic Standard Board by September 30.

The target for this Action is the U.S. National Organic Standards Board, a federal advisory board of dedicated public volunteers from across the organic community under the U.S. Department of Agriculture's Agricultural Marketing Service.

Comments to the NOSB: Add a sentence introducing yourself and share why organic is important to you!

To the members of the NOSB, 

Please consider the following: 

“Inert” ingredients used in organic production. USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA.   

The Materials Subcommittee has proposed two options for addressing this problem.   

*The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling.  

*The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food and not adverse effects to the environment and workers, falling short of the holistic assessment required by the organic law.  

Compost regulations. The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. I support the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a ‘de minimis‘ doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.”  

Meloxicam in organic livestock. The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes to list the drug without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.”   

I oppose the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.   

Thank you for your consideration of my comments.