21
Sep
Please Submit Comments: Organic Can Prevent Ecological Collapse with Our Help
(Beyond Pesticides, September 21, 2020) The National Organic Standards Board (NOSB) meets online October 28-30 to debate issues—after hearing public comment October 20 and 22—concerning how organic food is produced. Written comments are due October 1. They must be submitted through Regulations.gov.
Everywhere we look, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, organisms large and small entangled in plastic, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. As we focus on one of the most blatant examples of environmental abuse—the dispersal of toxic chemicals across the landscape—it is important to seek a solution. Organic can be a big part of the solution, but only if it doesn’t stray from its core values and practices.
Tell the National Organic Standards Board to support core organic values.
From its very beginnings, the organic sector has been driven by an alliance of farmers and consumers who defined the organic standards as a holistic approach to protecting health and the environment, with a deep conviction that food production could operate in sync with nature and be mindful of its interrelationship with the natural world—protecting and enhancing the quality of air, water, land, and food. Organic is not just an alternative for people seeking better food—though it is that—or a more profitable way of farming—though we hope it is that, too. It is a path to prevention of total ecological collapse. We constantly return to the foundations of organic for inspiration and guidance. When we comment on NOSB proposals, we are not interested in what is less harmful. We feel an urgency to prevent ecological disaster.
As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong, our Fall 2020 NOSB web page which will be up within the week. Comment on all issues that interest you.
We especially encourage comments on the topics below, keeping in mind this definition from the organic regulations:
“Organic production. A production system that is managed in accordance with the [Organic Foods Production] Act and regulations…to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” Meeting these goals, essential to a sustainable future, requires strong adherence to these organic standards. To adopt practices and materials that weaken organic, undermines the future. In this spirit, we urge the following:
- Do Not Allow Virgin Paper in Organic Crop Production Aids. The Crops Subcommittee proposes to allow planting aids—including paper pots, seed tape, and plant collars—made from virgin paper. To date, the National Organic Program has allowed only recycled paper to be used in crop production (as mulch and in compost). Virgin paper—especially virgin paper from wood pulp—results in much greater environmental impacts than recycled paper and does not foster cycling of resources. Use of virgin paper made from hemp reduces some of these impacts but adds the impacts of agricultural hemp production. Virgin paper from wood pulp should not be allowed as a crop input in organic production.
- Get Plastic Out of Organic. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size—on a wide range of organisms. Although concerns were first raised about microplastics in the marine environment, impacts on terrestrial organisms are increasingly documented. Microplastics can cause harmful effects to humans and other organisms through physical entanglement and physical impacts of ingestion. They also act as carriers of toxic chemicals that are adsorbed to their surface. Biodegradable biobased mulch film (BBMF) has been allowed in organic production since 2014, but no products meeting the requirements set by the NOSB are produced, so the NOSB is considering loosening the requirements (annotation). Furthermore, use of BBMF results in bits of microplastic that are not fully degraded. Synthetic mulches should not replace natural mulches like hay, straw, and wood chips. The annotation of BBMF should not loosen up restrictions on the bioplastic film.
- Protect Marine Life. Seaweeds (marine algae) and fish byproducts are used as inputs into organic crop production, but there is concern about the impacts of overharvesting and destructive harvesting methods, so the Materials Subcommittee proposes to allow marine algae to be used only when the harvest meets specific conditions. These requirements should be adopted by the NOSB, along with strong enforcement provisions. Separate action on fish products proposed by the Crops Subcommittee is too weak because it is unenforceable and allows the commercial use of bycatch. Only fish byproducts from postconsumer waste should be allowed as soil inputs.
- Tell the National Organic Program to Finally Take Action on “Inert” Ingredients. After years of NOSB action and NOP inaction on “inerts,” the Crops Subcommittee proposes the only action it can to stimulate NOP into action—it proposes to remove List 4 from the National List. According to the Organic Foods Production Act, NOP cannot allow the use of synthetic materials that are not supported by the NOSB. “Inert” ingredients are neither chemically nor biologically inert. They make up the bulk of pesticide products—sometimes as much as 99%–and have not been subjected to the scrutiny by the NOSB that has been applied to the few active pesticidal ingredients allowed in organic production. The NOSB must approve the Crops Subcommittee motion to remove the listing of List 4 “Inerts” and implement prior NOSB recommendations.
Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the four comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.)
organically grown food is not only healthier for consumption, but for the vitality of the earth. Instead of depleting the soil of vital nutriments and leaving toxic residues which stay in the soil but also pollute our groundwater and oceans, we should use not only the most healthy approach to agriculture, but the safest. Many pesticides rely on fossil fuels also, which we should not use to reduce our carbon footprint.
September 23rd, 2020 at 12:32 pmFarming without the use of toxic pesticides does not only produce heathier foods, but a healthy, self-sustaining soil as well. It keeps our underground waters safe. It diminishes our need for fossil fuel since many toxic pesticides are used with petroleum substances
September 23rd, 2020 at 1:57 pmI do not support the changes to the organic rules listed above. Those of us who spend the extra dollars to buy organic food for our families are concerned about more than just the use of organic fertilizers instead of chemical ones. We are very concerned about the sustainability of all habitats on Earth and use Earth friendly products in all areas of our lives. We want to preserve and wisely use Earth’s resources as much as possible. We are against the use of virgin timber for paper particularly paper that cannot be recycled, stripping ecosystems of needed food sources for animals like ocean seaweed, the use of plastics of any kind , and the use of unidentified “inert” chemicals in products which are often more toxic than the identified chemicals.
September 24th, 2020 at 12:09 am