Last Chance This Fall To Tell the NOSB To Uphold Organic Integrity
Comments are due by 11:59 PM EDT on September 30, 2024.
Due to updates to the Regulations website, we are now able to offer a click-and-submit form
to the Regulations docket!
The National Organic Standards Board (NOSB) is receiving written comments from the public on key issues, which must be submitted by 11:59 PM EDT on September 30, 2024. Written comments can be submitted via our form below.
This precedes the upcoming public comment webinar on October 15 and 17 and the deliberative hearing from October 22-24—concerning how organic food is produced and processed. Sign up for a 3-minute comment at the webinar by 11:59 PM EDT on September 30 to let U.S. Department of Agriculture (USDA) know how important organic is! Oral comment sign-ups fill up fast! Links to the virtual comment webinars will be provided on this webpage in early October, approximately one week before the meeting.
As a means of taking on the challenges of health threats, biodiversity collapse, and the climate emergency, the review and updating of organic standards requires public involvement in the current public comment period. This is required to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But we will only keep organic strong and growing stronger if we participate in voicing our position on key issues to the stakeholder advisory board, the National Organic Standards Board (NOSB). We have identified key issues for the meeting below.
>> Click here to submit your comments to the NOSB by 11:59 PM EDT on Sept 30, 2024.
The NOSB is responsible for guiding USDA in its administration of the Organic Foods Production Act (OFPA), including the materials 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.
The NOSB plays an important role in bringing the views of organic consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Fall. ➡️ For a complete discussion, please see the Keeping Organic Strong page and review the UPDATED Fall 2024 issues!
Some of our high priority issues for the upcoming NOSB meeting (see others here):
1. Make elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling.
Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.
Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products.
The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics, of which 90 percent are at the nanoscale, 90% of which are not identifiable, but the number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans.
Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta.
2. Eliminate nonorganic ingredients in processed organic foods as a part of NOSB's sunset review. 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) only 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?” Materials on §205.606 up for sunset review this year made from agricultural products that can be supplied organically should be taken off the National List of allowed materials.
The majority of the Handling Subcommittee voted to remove dried orange pulp from §205.606 because organic dried orange pulp is now available. This should be supported.
Cultured celery powder is a way of adding "natural" nitrites. The quotation marks are appropriate since it is not possible to achieve the high levels of nitrate desired through organic celery production. Rather, the celery must be grown in chemical-intensive production where it takes up nitrates from synthetic fertilizers. Given the known health effects of nitrates, we do not believe there is a good reason for keeping celery powder on the National List. The Agency for Toxic Disease Registry (ATSDR)/Centers for Disease Control and Prevention (CDC) lists, for example, methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer, among others.
In addition, there are 62 pesticides with allowed residues (tolerances) for celery, 27 are acutely toxic and create a hazardous environment for farmworkers, 57 are linked to chronic health problems (such as cancer), 15 contaminate streams or groundwater, and 56 are poisonous to wildlife. Celery powder should be removed from the National List.
3. All segments of organic production and regulation should cooperate in ensuring that organic products are produced using organic seed and starts. Processors should not require organic growers to produce varieties if the seeds or starts for those varieties are not available organically. Processors who sell products with the organic seal benefit from certification and should share the responsibility for continuous improvement.
Organic cotton growers find it very difficult to source organic seed due to the small size of the industry. Most growers must use conventional, untreated, non-GMO seed. Given current seed regulations, the delinting process used on conventional seeds (sulfuric acid) is allowed since the seeds themselves are untreated and non-GMO. Also, due to the consolidation of seed companies, organic growers have an increasingly hard time finding their desired varieties that have been available in the past. The push for genetically modified cotton varieties has also made seed sourcing for organic growers even more difficult. The NOSB and NOP should make the availability of organic seed a priority.
>> Click here to submit your comments to the NOSB by 11:59 PM EDT on Sept 30, 2024.
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 our comments included on our Fall issues page.
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.
Thank you for your active participation and engagement in keeping organic strong! The Action is a multi-step process, so please click submit below to proceed to step two, where you will be able to personalize comments before final submission.
Comments to the NOSB:
Please consider the following key issues to uphold organic integrity:
1. Eliminate plastic in organic production. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well-documented. We need research into ways to replace all forms of plastic in organic production and handling. Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic).
Microplastics are of increasing concern because they can cause harmful effects to humans and other organisms, act as carriers of toxic chemicals, and increase the spread of antibiotic resistance genes in water and sediments. Microplastic particles been found in human carotid artery plaque, lungs, blood, feces, breast milk, and placenta. Cod eggs, embryos, and larvae exposed to water containing microplastics, exhibited toxic effects reminiscent of scoliosis in humans.
Highly hazardous PFAS (per- and polyfluoroalkyl substances) leach out of plastic containers and contaminate food products. The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics. A study analyzing 50 items in common use finds many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases.
2. Eliminate nonorganic ingredients in processed organic foods as a part of NOSB’s sunset review. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. Nonorganic materials should not be allowed if they can be supplied organically, and we can now grow virtually anything organically. The NOSB needs to ask potential suppliers, “Could you supply the need if the organic form is required?” Materials on §205.606 up for sunset review made from agricultural products that can be supplied organically should be taken off the National List of allowed materials.
I support the vote of the Handling Subcommittee to remove dried orange pulp from §205.606 because organic dried orange pulp is now available.
Cultured celery powder is a way of adding "natural" nitrates. The quotation marks are appropriate since celery takes up the high level of nitrates desired from synthetic fertilizers in chemical-intensive production. Nitrates have known health effects of nitrates, including methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer. In addition, of 62 pesticides with allowed residues (tolerances) for celery, 27 are acutely toxic and create a hazardous environment for farmworkers, 57 are linked to chronic health problems (such as cancer), 15 contaminate streams or groundwater, and 56 are poisonous to wildlife. Celery powder should be removed from the National List.
3. All segments of organic production and regulation should cooperate in ensuring that organic products are produced using organic seed and starts. Processors should not require organic growers to produce varieties if the seeds or starts for those varieties are not available organically. Processors who sell products with the organic seal benefit from certification and should share the responsibility for continuous improvement.
Organic cotton growers find it very difficult to source organic seed. Most must use conventional, untreated, non-GMO seed. Also, due to the consolidation of seed companies, organic growers have an increasingly hard time finding their desired varieties that have been available in the past. The NOSB and NOP should make the availability of organic seed a priority.
Thank you for considering these comments.