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Sep
Fall 2019 National Organic Standards Board Meeting: Last Chance to Comment
(Beyond Pesticides, September 30, 2019) A warm thank you to all who have sent in comments for the Fall 2019 National Organic Standards Board (NOSB) meeting. We are sending out a second reminder so that those who have not commented can take this opportunity to do so. If you have already submitted, we encourage you to make a second round of comments to make sure your voice is heard!
Public comments are due by October 3, 2019. Your comments and participation are critical to the integrity of the organic label. Written comments may be submitted through Regulations.gov until 11:59 pm ET October 3, 2010. Reservations for in-person and webinar comments close at the same time.
The proposals of the NOSB, as a part of its ongoing review of practices and materials, are published for public comment. Beyond Pesticides/OrganicEye is providing the public with a listing and analysis of the issues under consideration by the Board when it meets in Pittsburgh, PA on October 23 – 25, 2019. You can view USDA’s announcement of the NOSB’s meeting and proposals here.
Issues before the NOSB include materials allowed in organic production as well as some policy issues. Materials are either being considered for initial use in organics or the subject of a five-year Sunset Review. To be allowed, materials must have evidence demonstrating that they meet Organic Foods Production Act (OFPA) requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices.
Major issues before the NOSB at the Fall 2019 meeting
(Please feel free to copy and paste the language below with your own, personalized introduction to regulations.gov.)
Take nitrates out of organic meat!
The Organic Foods Production Act (OFPA) prohibits the addition of nitrates to organic food because of the known health effects, but producers of organic processed meat products, along with producers of nonorganic “nitrate free” meats, have found a way around that prohibition –celery powder. The high levels of nitrate fertilizer allowed in nonorganic production concentrate in some vegetables, including celery, but organically grown celery does not contain high enough levels of nitrate to be used in curing meat. Celery powder has been listed as an allowed nonorganic agricultural ingredient since 2007.
Nitrates are prohibited in organic food because of their impacts on human health, which include methemoglobinemia, hypotension, risk of pregnancy complications, a number of reproductive effects, and cancer. In addition, the Beyond Pesticides Eating with a Conscience database identifies impacts of pesticides used in producing nonorganic celery, including farmworker poisonings, contamination of water, wildlife poisoning, and pollinator impacts. The NOSB must deny the relisting of celery powder.
Keep genetic engineering out of organic!
The NOSB continually updates its assessment of which methods meet the criteria for “excluded methods” in organic production—that is, genetic engineering. At this meeting, the Materials Subcommittee proposes to add induced mutagenesis developed via use of in vitro nucleic acid techniques to the list of excluded methods and embryo transfer, or embryo rescue, in livestock, without use of hormones in recipient animals, is proposed to be listed as “not excluded.” We support these recommendations, except that there should be no use of hormones in either donor or recipient.
The U.S. Department of Agriculture (USDA) appears to have forgotten the lesson learned 20 years ago when it was forced to ban genetic engineering (GE) in organic regulations. At a July 17 hearing called by the U.S. House Agriculture Subcommittee on Biotechnology, Horticulture, and Research on “Assessing the Effectiveness of the National Organic Program,” Greg Ibach, the USDA’s Under Secretary for Marketing and Regulatory Programs, stated, “There is the opportunity to open the discussion to consider whether it is appropriate for some of these new technologies, including gene editing, to be eligible to be used to enhance organic production.” In view of this statement, we believe it is important to stress that gene editing, like other forms of genetic engineering, is unacceptable in organic production.
Stop supporting organic CAFOs!
The addition of synthetic methionine to organic poultry rations has a long and controversial history –not because of direct health effects on organic consumers, but because it facilitates industrial-style production of poultry.
Poultry production in concentrated animal feeding operations (CAFOs) needs synthetic methionine because of the lack of outdoor access and the choice of fast-growing breeds.
The “need” for synthetic methionine is a result of choices regarding 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. There have also been advances in the use of insects –specifically black soldier fly larvae—as a source of natural methionine.
The European Union does not allow the use of synthetic methionine in organic poultry, but does require more space per bird, fewer birds per house, and more access to the outdoors. Significantly, the EU also requires that poultry be of slow-growing breeds or be slaughtered at an older age. All these factors contribute to the welfare of poultry.
Research shows that methionine acts as a growth promoter above and beyond its role as a protein building block. Manipulating methionine in the diet through additions of synthetic methionine is effectively using a synthetic growth promoter and is comparable to the use of rBGH to enhance milk production.
Sunset gives the NOSB the opportunity to reconsider past decisions and reinstitute a process of continuous improvement. The NOSB should delist synthetic methionine or add an expiration date to force serious reconsideration.
Written comments may be submitted through Regulations.gov until 11:59 pm ET October 3, 2019.
Not sure how to use our suggested language to comment? Follow these simple steps:
- Select the text in our comments (place your cursor before the first word in the text, then press and hold down the left mouse button and, without releasing the button, move the cursor to the end of the comments).
- Copy the selected text by selecting the Ctrl and C keys simultaneously.
- Click on this link to open a new tab and in that tab, place your cursor in the “Comment” box.
- Paste the comments you copied by selecting the Ctrl and V keys simultaneously.
- Personalize your comments before entering your contact information and selecting “Continue”.
Please go to Beyond Pesticides’ Keeping Organic Strong (KOS) webpage to learn more about these and other substantive issues, and to provide a unique public comment to the NOSB. We will continue to update the KOS page in advance of the public comment deadline on October 3.
Again, thank you for helping to protect and uphold organic integrity!
