07
Apr
Compost Rules and Other Critical Issues before the National Organic Standards Board; Call for Action
(Beyond Pesticides, April 7, 2025) Throughout the year and historically, the science and policy deficiencies captured by the Daily News paint a dramatic picture of the issues that support the need for strong organic standards on a range of issues, some of which will be under consideration by the National Organic Standards Board (NOSB) when it receives public comments through Monday, April 28. Organic advocates are gearing up to participate in the hearing process and the semi-annual meeting of the NOSB to protect and enhance the integrity of defined, certified, and enforceable organic standards as an alternative to harmful chemical-intensive practices.
Because of USDA’s delay in scheduling the NOSB meeting, board members will not have time to review public comments unless they are submitted as soon as possible before the start of the board meeting on April 29. So, Beyond Pesticides is encouraging members of the public to comment early.
There are public comment webinars on April 22 and 24 and a deliberative hearing from April 29 through May 1, that concern how organic food is produced. A draft meeting agenda is available here; a more detailed agenda with proposals is available here.
- Sign up for a 3-minute oral public comment timeslot to let the U.S. Department of Agriculture (USDA) know how important organic is by Wednesday, April 9! Remember, oral comment sign-ups fill up fast! Links to the virtual comment webinars will be provided approximately one week before the webinars.Â
 - Written comments must be submitted through our “click and submit” form or via Regulations.gov by 11:59 pm EDT on Monday, April 28, but please get them in as early as possible!
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 organic land management protects the ecosystem, mitigates climate change, and enhances health.Â
Click here to submit your comments to the National Organic Standards Board by Monday, April 28!
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 the Keeping Organic Strong and the Spring 2025 Beyond Pesticides’ issues webpages.
Here are some of Beyond Pesticides’ high-priority issues for the upcoming meeting:Â
- Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks†that might include, for example, “compostable†food containers. Â
Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.†Biosolids—fortunately never allowed in organic production—should be a lesson to remember. The NOSB must protect organic production by denying the petition to allow synthetic “compostable materials.â€Â
 - The NOSB is considering a proposal to eliminate nonylphenol ethoxylates (NPEs) in iodine products used in livestock. Iodine is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors may contain nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), as well as other alkylphenols (APs) and alkylphenol ethoxylates (APEs), which are endocrine disruptors with impacts on many species, including gender changes. Breakdown of certain APEs may lead to toxic effects in treated livestock and applicators. Organic alternatives include ethanol or essential oils for some uses. Other natural alternatives identified by the TR include udder washes containing essential oils, vinegar, natural acids, nisin for teat dips, and natural ethanol. Other substitutes include chlorhexidine, alcohols, hydrogen peroxide, essential oils, and other chlorine materials. EPA has approved the following for use in Design for the Environment disinfectant products: citric acid, hydrogen peroxide, l-lactic acid, ethanol, and isopropanol. Some disinfectant TRs identify some alternative practices for some uses–steam sterilization and UV radiation. The iodine TR says, “The risk of mastitis incidents is significantly reduced when producers maintain a clean and dry environment for the animals. Frequently changing the animal’s bedding material and/or using inorganic bedding (i.e., sand) may also reduce environmental contamination with these bacteria. In addition, providing a healthy, balanced diet to the animal and ensuring the cleanliness of milking implements are important steps for maintaining healthy udders.â€Â Â
The Livestock Subcommittee (LS) has scaled back its original proposal to prohibit APEs to one that prohibits only NPEs. We believe it is important to add an annotation to prohibit the use of APEs and APs in organic production; APEs are suspected endocrine disruptors and proven aquatic toxins. As described by the Danish Environmental Protection Agency, “[A]lkylphenols are a group of chemicals comprising a substantial number of substances ranging from cresol (C1-alkylphenol) to phenols with up to four linear or branched constituent groups of varying chain lengths. However, the ethoxylated versions of alkylphenols of any commercial significance (detergents, emulsifiers) are in reality limited to C8-, C9- and C12-compounds [octyl-, nonyl-, and dodecylphenols]. . .† The National List should restrict iodine materials to those “without octylphenol, nonylphenol, dodecylphenol, octylphenol ethoxylate, nonylphenol ethoxylate, or dodecylphenol ethoxylate.â€
 - The NOSB should use the review (or sunset) process to eliminate nonorganic ingredients in processed organic foods. Materials listed in §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 §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, “Could you supply the need if the organic form is required?â€Â The materials on §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.Â
 - Finally, no issue is more urgent than the need for the NOSB to evaluate so-called “inert†ingredients in the products used in organic production to ensure that they meet the criteria in OFPA. The NOSB, which is responsible for giving direction to the National Organic Program (NOP) at USDA, has passed repeated recommendations instructing NOP, to replace the generic listings for EPA Lists 3, 4A, and 4B “inertsâ€Â with specific substances approved for the use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert†ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.Â
- OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active†ingredients, but not to “inert†ingredients, which make up the largest part of pesticide products—up to 90% or more.Â
A comparison of the hazards posed by active and “inert†ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts†than actives pose the hazard. The NOSB and NOP must act on “inerts†NOW and refuse a blanket relisting of List 4 “inerts.â€
Submit a comment at Regulations.gov OR use click-and-submit form linked below!Â
Click here to submit your comments to the National Organic Standards Board by Monday, April 28.Â
Comment to NOSB:
Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks†that might include, for example, “compostable†food containers.
Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.†Biosolids—fortunately never allowed in organic production—should be a lesson to remember. The NOSB must protect organic production by prohibiting synthetic “compostable materials.â€
The NOSB is considering a proposal to eliminate nonylphenol ethoxylates (NPEs) in iodine products used in livestock. Iodine is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors may contain nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), as well as other alkylphenols (APs) and alkylphenol ethoxylates (APEs), which are endocrine disruptors with impacts on many species, including gender changes. There are many organic, natural, and allowed alternatives. In addition, providing a healthy, balanced diet to the animal and ensuring the cleanliness of milking implements are important steps for maintaining health udders.â€
The original proposal has been scaled back to prohibit only NPEs. It is important that the annotation prohibit the use of C8-, C9- and C12-APEs and APs in organic production. They are suspected endocrine disruptors and proven aquatic toxins. The National List should restrict iodine materials to those “without octylphenol, nonylphenol, dodecylphenol, octylphenol ethoxylate, nonylphenol ethoxylate, or dodecylphenol ethoxylate.â€
The NOSB should use the review (or sunset) process to eliminate nonorganic ingredients in processed organic foods. Materials listed in §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 §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The NOSB needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?†The materials on §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.
Finally, no issue is more urgent than the need for the NOSB to evaluate so-called “inert†ingredients in the products used in organic production to ensure that they meet the criteria in OFPA. The NOSB has passed repeated recommendations telling NOP to replace the generic listings for EPA Lists 3, 4A, and 4B “inerts†with specific substances approved for the use. The law provides stringent criteria for allowing synthetic materials to be used in organic production:  that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active†ingredients, but not to “inert†ingredients, which make up the largest and often most toxic part of pesticide products.
The NOSB must refuse a blanket relisting of List 4 “inerts.â€
Thank you.
