(Beyond Pesticides, September 12, 2021) Comments are due by 11:59 pm EDT September 29. The National Organic Standards Board (NOSB) is receiving written comments from the public through September. This precedes the upcoming public comment webinar on October 18 and 20 and deliberative hearing October 25-27â€”concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov. by 11:59 pm EDT September 29. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October.
The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health
The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Fall 2022 issues page. Here are some high priority issues for us:
Organic Agriculture is Climate-Smart Agriculture. The NOSB draft letter to Secretary of Agriculture Vilsack is an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to promote conversion to organic farming. More important to addressing the climate crisis than the questions posed by NOP are questions concerning how USDA programs can assist organic producers and those seeking to convert to organic. The draft letter addresses these as well. It also points out the resiliency of organic agriculture: â€śOrganic is the solution to mitigating climate change and responding to it.â€ťIn view of the climate benefits of organic and the incentives inherent in organic marketing, the real question is whether USDA will abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry in favor of whole-hearted support for organic agricultureâ€”because despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should make adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs.
Biodegradable Biobased (Bioplastic) Mulch Film (BBMF) is under consideration for sunset this year. This is part of a larger issue of the use of plastic in organic production and handling. Awareness is growing about the impacts of plasticâ€”and the microplastic particles to which it degradesâ€”on human health and the environment. BBMF should not be relisted. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic production and handlingâ€”including packaging.
The NOSB should use the sunset process to eliminate non-organic ingredients in processed organic foods. Materials listed in Â§205.606 in the organic regulations are nonorganic agricultural ingredients that are allowed to be used as ingredients as part of the 5% of organic processed foods that is not required to be organic. Materials should not remain on Â§205.606 if they can be supplied organically, and anything that can be grown can be grown organically. The Handling Subcommittee needs to ask the question of potential suppliers, â€śCould you supply the need if the organic form is required?â€ť Two materials on Â§205.606 are up for sunset this yearâ€”pectin and casings. Both are made from agricultural products that can be supplied organically and thus should be sunsetted.
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 three 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.)
Thank you for keeping organic strong!