02
Apr
Last Chance to Comment on Issues for National Organic Standards Board Spring Meeting
(Beyond Pesticides, April 2, 2018) The comment period closes Wednesday, April 4 at 11:59 pm for the Spring 2018 National Organic Standards Board (NOSB) Meeting.
Decisions governing the substances allowed in organic food production are subject to public input twice a year. Public participation in this process is critical to the quality of the decisions and meeting both consumer and farmer expectations. In this context, Beyond Pesticides analyzes the proposals before the NOSB, shares its analysis and comments with the public, and urges people to engage the process and make their views known to decision makers. Details are provided below.
In addition to the other priorities in our previous alert (preventing fraud in organic, removing incentives to convert native ecosystems to organic crop production, and the use of bisphenol A [BPA] and other chemicals in organic packaging), we focus attention here on some genetic engineering (GE) issues, contaminated inputs, and “inert” ingredients.
New to Regulations.gov? See our two-minute tutorial.
Beyond Pesticides provides you with our positions, which you can use as the basis for your comments. If you have limited time, you can use the sample comments on priority issues, below. If you have more time, please use the information on our website to develop your own comments. If you paste our comments into regulations.gov, please first put a personal note of concern in order to reflect the importance of these issues to you as an organic consumer, farmer, or other concerned party.
Some major issues at the Spring NOSB meeting are:
Non-GMO Organic Seed Integrity (Seed Purity from GMOs)
The issue of protecting the genetic integrity of seed grown on organic land is related to two others that are not on the agenda –strengthening and clarifying the requirements for the use of organic seed, and excluded methods terminology. Addressing these two issues adequately would help to ensure that the presence of plants growing from GE seeds is greatly reduced on organic farms.
The issue of protecting the genetic integrity of seed grown on organic land is concerned with those instances when organic producers plant nonorganic seed, so any efforts to strengthen the requirements for organic seed would tend to eliminate the problem. Strengthening and clarifying the requirements for the use of organic seed should remain on the agenda to eliminate inconsistencies in the enforcement of the National Organic Program’s (NOP’s) broad exemption that allows the use of conventionally produced seed in certified organic. A rule change to the seed practice standard is needed to require a demonstrable improvement over time until 100% organic seed use is achieved.
Excluded methods terminology should be maintained on the NOSB agenda to keep up with a fast-moving biotechnology industry. Organic regulations prohibit the use of genetic engineering, but the NOP needs to define terms in order to ensure that those regulations are enforceable.
Efforts to quantify the extent of GE contamination and provide transparency in GE content of non-organic seeds should not further burden organic growers.
Contaminated Inputs
It is important for the NOSB to maintain a focus on the problem of contaminated inputs, which threatens the quality of organic products and soil on organic farms. However, the NOSB last addressed the issue in a report in Spring 2015. The report offered an approach for addressing this complex issue through examining feedstocks and pathways. We support the approach in that report. In the intervening three years, the NOSB has not made progress, but another source of contamination has risen in importance — use of water contaminated by oil and gas production. If “organic” is to maintain its meaning, we must prevent the unintended contamination that can occur when organic matter is recycled from off-farm sources, or when outside forces contaminate water supplies.
“Inert” Ingredients
“Inert” ingredients frequently comprise as much as 99% of pesticide products. So-called “inert” ingredients are not inert, and are not disclosed to users or others who may be exposed. Given NOSB scrutiny of active ingredients, “inert” ingredients may be the most hazardous ingredients in pesticide products used in organic production. We urge the NOSB to insist that NOP move forward quickly with implementation of the NOSB recommendations on “inert” ingredients. Allowing the current lack of movement to persist raises serious compliance issues and threatens the integrity of the USDA organic label.
