01
Apr
Protect the Integrity of Organic Food Production and Continuous Improvement
(Beyond Pesticides, April 1, 2019) National Organic Standards Board (NOSB) meets next month in Seattle, Washington to debate issues concerning what goes into your organic food. Written comments are due April 4. The format for messaging the NOSB requires copying and pasting comments into regulations.gov, so we apologize that this is not a “single click” action. Please add a personal message about why this is important to you at the top of your comments, if possible.
From the very beginning, with the passage of the Organic Foods Production Act (OFPA) in 1990, “organic” has meant “continuous improvement ” in organic food production. The primary mechanism for this is the high level of public involvement that comes from twice-annual meetings of the stakeholder board and decisions related to the allowance of substances/materials used in organic production.
The second mechanism is the sunset process, which helps move synthetic substances out of organic production as we learn more about hazards and alternatives. Those substances allowed in organic production must be placed on the National List of Allowed and Prohibited Substances and may be re-listed every five years after a mandatory rigorous assessment of their adverse effects from cradle-to-grave, and a determination of their necessity, given alternative practices and products. Imagine what could happen if pesticide registrations went through a rigorous reevaluation and relisting process like this every five years!
Items on the NOSB agenda include voting on materials allowed in organic production and policies, as well as discussion of policies and sunset materials on which the NOSB will vote in the Fall. We have identified some priority issues of both kinds. Starred issues are voting issues.
To comment on these priority issues, highlight the entirety of the comments below (including headers) and hit “copy”
Then click here to go to Regulations.gov and paste into the comment field.
Add a personal message about why this is important to you at the top!
PRIORITY COMMENTS:
Reject Petition to Allow Silver Dihydrogen Citrate* [HS]
Silver dihydrogen citrate poses health and environmental risks, particularly the risk of increasing resistance to antibiotics and silver-based medications. Both ionic silver and nanosilver are toxic not only to microbes, but to other species as well. The petition for SDC must be denied to protect human health and the environment and ensure the effectiveness of remaining antimicrobial medications.
Reject Petition to Allow Allyl Isothiocyanate (AITC)* [CS]
Allyl isothiocyanate (AITC) must not be included on the National List because it does not meet any of the criteria in OFPA for allowing an exemption. It poses environmental and health hazards, is not essential for organic production, and is not compatible with organic practices. It would be difficult to find a practice less compatible with organic production than soil fumigation with a “broad-spectrum antimicrobial compound that effectively kills both plant pathogens and beneficial soil microorganisms.” Organic production uses practices that feed soil organisms who feed crop plants. It creates healthy soil food webs. Using a toxic chemical to wipe out soil biology is the antithesis of organic practices.
Reject Petition to Allow Collagen Gel Casings* [HS]
Collagen gel casings should not be added to the list of allowed nonorganic agricultural materials because collagen gel casings are synthetic, the listing discourages the development of organic collagen gel casings, and the contamination from nonorganic feedlots and other practices poses environmental and health hazards.
Non-organic collagen gel casings derived from animals raised in concentrated animal feeding operations (CAFOs) contaminate organic products with toxic pesticides and other chemicals widely recognized as hazardous to farmworkers, the environment, and consumers.
Any agricultural commodity can be produced organically, so listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Instead of petitioning for the use of casings made from meat contaminated with pesticides and antibiotics, processors should devote their efforts to eliminating practical obstacles to sourcing organic collagen.
Protect Marine Environment by Limiting Marine Materials [MS]
We must set enforceable, protective rules for the use of marine algae in organic production. Enforceability implies rules that are verified by on-site inspection and that will stand up to legal challenge. Rules must protect the marine ecosystem and biological communities.
An annotation is the most effective way to introduce enforceable, protective rules for marine algae. Annotations are not subject to discretionary alteration without a decisive vote of the NOSB. On the other hand, because the listings are reviewed on a five-year cycle, they can be updated when needed.
Evaluating Sanitizers [MS]
The Materials Subcommittee has outlined many of the issues that should be covered regarding sanitizers, but they need to be addressed within a framework that first identifies the needs for cleaning and sanitizing materials in organic production and handling.
Such a review should start with the questions:
- For what purposes are cleaning and sanitizing materials needed?
- Are specific cleaning and sanitizing materials required by law?
Both in terms of a strict reading of OFPA and common sense, all cleansers and antimicrobials used in organic production and handling should be on the National List.
Stop Methionine [LS]
The NOSB should delist synthetic methionine (an alternative to natural amino acids) or add an expiration date to force serious reconsideration. The current listing of methionine is based on inadequate support for a regulatory decision that reverses a previous NOSB decision to phase out methionine and incentivize alternative approaches to managing poultry.
The listing of synthetic methionine must be considered in the context of an organic management system. The “need” for synthetic methionine is a result of choices regarding poultry flock breeds, stocking rates (both density and group size), and outdoor access. Increasingly, consumers are turning to eggs and meat produced in pastured poultry systems, which require fewer synthetic inputs. In the time since the last consideration of synthetic methionine by the NOSB, there have been advances in the use of insects — specifically black soldier fly larvae — as a source of natural methionine. However, organic poultry producers and the NOSB should not limit their consideration to one source.
Synthetic methionine is not necessary for animal welfare. Studies show that reduced stocking rates (both density and group size), outdoor access, and slower-growing birds (who use the outdoors more effectively), but not synthetic methionine and cysteine, have a positive impact on the welfare of poultry.
Go organic!
April 2nd, 2019 at 12:32 pmPure organic food please…no synthetics, no HS silver, no collagen casings, no AITC-CS. We need pure food not chemically treated fresh foods! This discussion has been a hot topic for years! Get it right please! Organic, TRUE ORGANIC benefitS EVERY LIVING BEING and the EARTH.
April 2nd, 2020 at 5:50 pm