Strong Organic Standards Require Continuing Public Involvement; Comments Are Due 11:59pmEDT April 5
(Beyond Pesticides, March 20, 2023) As a means of taking on the challenges of health threats, biodiversity collapse, and the climate emergency, the review and updating of organic standards requires the public involvement in the current public comment period. This is required to keep organic strong and continually improving.
The National Organic Standards Board (NOSB) is receiving written comments from the public through April 5, 2023. This precedes the upcoming public comment webinar on April 18 and 20 and deliberative hearing April 25-27â€”concerning how organic food is produced. Sign up for a 3-minute comment to let U.S. Department of Agriculture (USDA) know how important organic is at the webinar by April 5. Written comments must be submitted through Regulations.gov. by 11:59 pm EDT April 5. Links to the virtual comment webinars will be provided approximately one week before the webinars.
The NOSB is responsible for guiding 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 consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2023 Beyond Pesticidesâ€™ issues webpage. Here are some of our high priority issues for the upcoming meeting:
Prohibit the Routine Allowance of Ingredients Processed with Ion Exchange. Because the ion exchange process is a chemical process, all organic ingredients processed in this manner must be subject to review by the NOSB. Ion exchange creates synthetic ingredients through chemical changeâ€”removing some components and substituting other chemicalsâ€”that are used in processed food. It is not simply filtration. Chemicals in the ion exchange resins may leak into the food product. Yet, the Handling Subcommittee of the NOSB is proposing to allow any and all resins without review. To maintain the integrity of the organic label, resins must be subject to full National List (National List of Allowed and Prohibited Substances) review to determine whether these ingredients meet organic standards, rather than establishing a blanket allowance of ion exchange in organic processing.
Organic Agriculture is Climate-Smart Agriculture. In a draft letter to Secretary of Agriculture Tom Vilsack, the NOSB has written an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to dramatically increase support for converting chemical-intensive agriculture to organic. It is critical that the National Organic Program ask, â€śWhat more should USDA be doing to advance organic?â€ť As the Board states, the resiliency of organic is established: â€śOrganic is the solution to mitigating climate change and responding to it.â€ť However, despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should require the adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs and abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry.
Plastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plasticâ€”and the microplastic particles resulting from its useâ€”on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging.
The NOSB should use the review (or sunset) process to eliminate nonorganic ingredients in processed organic foods. Materials listed in Â§205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on Â§205.606 if they can be supplied organically, and we can now grow virtually anything 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 The materials on Â§205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.
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!
Visit Beyond Pesticides’ Keeping Organic Strong webpage, where we post background and Beyond Pesticides’ comments on all the issues before the National Organic Standards Board this session.