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Daily News Blog

01
Apr

Help Ensure that Organic Production Meets the Standard You Expect to Protect Health and the Environment; Comments due April 3

(Beyond Pesticides, April 1, 2020) Your comments are due by Friday, April 3, end of day.

The National Organic Standards Board (NOSB) meets April 29-30 online to debate issues concerning what goes into your organic food.

Lend your voice to continuous improvement by learning about issues and submitting comments.

From the very beginning, with the passage of the Organic Foods Production Act in 1990, “organic” has meant “continuous improvement.” The primary mechanism for continuous improvement in organic production is the high level of public involvement that comes from twice-annual meetings of the stakeholder board.

The second mechanism is the sunset process, which helps move synthetic substances out of organic production as the market invests in growing organic inputs and ingredients. Despite USDA’s efforts to weaken the sunset process, the 5-year cycle of review of every synthetic substance currently used in organic production and processing, offers us an opportunity to keep organic strong and strengthen any weaknesses.

Items on the NOSB agenda in April include materials allowed in organic production, 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. The only voting issue on the NOSB agenda for this meeting is a petition that would allow the use of paper pots made of virgin paper as a planting aid.

To comment on these priority issues, you may click here to go to Regulations.gov and copy these comments into the comment field. Please personalize your comments.

Paper Pots
The use of paper pots as petitioned—hemp kraft paper, with hemp fibers for strength, and with the petitioned additives poses no more hazard to the soil or to organic consumers than the allowed use of recycled paper, which contains many more additives. However, this decision should not be based on a comparison with the allowed use of recycled paper, but on compliance with OFPA criteria. Although the use of the paper pots does not appear to pose any health threat, more data is needed on the biodegradability of the adhesives. The Crops Subcommittee should develop a proposal that contains an annotation clarifying the materials and manufacturing processes that will be allowed, and pots made from virgin wood pulp should not be allowed. Finally, since there will be other products that incorporate other additives, the NOSB should hold the line on allowed materials in the pots, while remaining open to amendments in the future.

Sanitizers
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. A comprehensive review of sanitizers should begin with identifying the needs of organic producers and handlers for cleaning and sanitizing materials.

Such a review should start with the questions:

  1. For what purposes are cleaning and sanitizing materials needed?
  2. Are specific (e.g., chlorine-based) 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 evaluated for National List listing, regardless of subsequent rinsing.

“Inert” Ingredients
Active ingredients in pesticide products used in organic production have been carefully screened to ensure that they meet the requirements of OFPA and present little hazard to people and ecosystems, from their manufacture through their use and disposal. So-called “inert” ingredients have not received the same level of scrutiny. In addition, “inert” ingredients make of the largest part of many pesticide product formulations. As a result, the most hazardous part of pesticide products used in organic production is often these ingredients.

EPA stopped supporting the National Organic Program allowance of List 4 “inert” ingredients (which EPA classified as not of toxicological concern) 14 years ago. Since then, the NOSB has repeatedly passed recommendations to take action that would allow the NOSB to review so-called “inerts” on the same five-year schedule as other synthetic materials used in organic production in accordance with OFPA standards. The NOP has not even taken the first step of verifying the list of “inerts” that are actually used in organic-approved products. Tell the NOSB to refuse to relist List 4 “inerts” unless the NOP initiates steps to require examination of every “inert” ingredient.

Fenbendazole
The NOSB cannot rely on the 2015 Technical Review covering parasiticides used in mammalian livestock to support a decision to allow the use of fenbendazole (for parasites) in poultry. Such use does not meet OFPA criteria—it may harm the environment, allow residues in organic eggs that are not compatible with organic practices, and is not necessary for organic poultry production. The definition of emergency proposed by the Livestock Subcommittee is inadequate to protect organic consumers from fraudulent use. The NOSB should reject the use of fenbendazole in poultry.

Marine Materials
The protection of marine ecosystems is urgently important and, since marine plants are crucial to those ecosystems, it is important for all of us, as organic producers, consumers, certifiers, and regulators, to find a way to move this process forward. 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. Protective rules must address not only the sustainability of the target marine algae and fish, but also the marine ecosystem and biological communities in which they live.

The NOSB has failed to move forward with overarching policy on marine materials, but faces sunset decisions on use of fish oil and kelp in processing and fish extracts in crop production. These marine products should not be relisted unless the NOSB can place restrictions that protect the marine environment.

Lend your voice to continuous improvement by learning about issues and submitting comments.

Not sure how to use our suggested language to comment? Follow these simple steps:

  1. 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).
  2. Copy the selected text by selecting the Ctrl and C keys simultaneously.
  3. Click on this link to to open a new tab and in that tab, place your cursor in the “Comment” box.
  4. Paste the comments you copied by selecting the Ctrl and V keys simultaneously.
  5. Personalize your comments before entering your contact information and selecting “Continue.”
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One Response to “Help Ensure that Organic Production Meets the Standard You Expect to Protect Health and the Environment; Comments due April 3”

  1. 1
    Blaine Malquist Says:

    Organic protections should have the highest purity standards free of chemicals.

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