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Last Chance to Protect Organic this Fall—Submit Comments by September 30!
(Beyond Pesticides, September 27, 2021) The National Organic Standards Board (NOSB) is receiving written comments from the public through September 30. This precedes the upcoming public comment webinar on October 13-14 and online meeting October 19-21—in which the NOSB deliberates on issues concerning how organic food is produced. Written comments must be submitted through Regulations.gov.
As always, there are many important issues on the NOSB agenda this Fall. For a complete discussion, see Keeping Organic Strong (KOS) and the Fall 2021 issues page. In the spirit of “continuous improvement,” we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system.
The Organic Foods Production Act (OFPA) requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. Among the issues up for consideration at this meeting is a material that the National Organic Program (NOP) has taken off the NOSB’s sunset agenda for several years—sodium nitrate. There are also issues affecting organic integrity that need to be addressed—systemic fraud and plastic—as well as decisions about other materials that are described on the Fall 2021 issues page. We earlier conducted an action on priority issues. The issues below add to the earlier list, if you have the time.
Sodium nitrate (aka Chilean nitrate) is a mined mineral that is used as a highly soluble nitrogen source in agriculture. In recognition of the fact that its high solubility makes it inconsistent with organic production, which “feeds the soil, not the plant,” it was added to the National List of Allowed and Prohibited Materials, originally with the annotation as prohibited “unless use is restricted to no more than 20 percent of the crop’s total nitrogen requirement.” In 2011, the NOSB voted to remove the annotation, thus making sodium nitrate a prohibited natural. NOP never acted on this recommendation, nor did it allow the NOSB to vote on the listing during five-year sunset evaluations. OFPA requires that all synthetic materials used in organic production be approved by the NOSB, included on the National List, and reassessed every five years. It also requires that the National List be “based on” recommendations of the NOSB. The NOSB is considering whether to back down on its 2011 recommendation. It must stand firm and tell NOP to follow the recommendation that the board made 10 years ago.
Preventing Fraud. The NOSB is asking for comments on proposals to “modernize supply chain traceability” in order to reduce fraud in organic production. While improved technology can contribute to increased compliance, the most important barriers to organic integrity are systemic. We offer as an example the plight of organic dairy farmers who have been left high and dry after being abandoned by their main processor, Danone/Horizon, which has announced that it is terminating its contracts with 89 small-to-medium-sized organic dairy producers in the Northeast as of August 2022. At that point, all of Horizon’s contracted organic dairy farms in Vermont, New Hampshire, Maine, and northern New York may well have no buyers for their milk and will likely face a very uncertain future. Why is Danone cancelling contracts as organic milk production in the Northeast is increasing? In Danone’s words, the company “will be supporting new partners that better align with our manufacturing footprint.” In other words, the company doesn’t need to depend on local fresh milk suppliers when low cost, ultra-pasteurized milk that is easily transported and warehoused has become a staple on the organic shelf. More importantly for the future of organic dairy is the expectation that USDA will promulgate a weak regulation on origin of livestock—that will allow the massive loophole of being able to sell or transfer transitioned animals as certified organic. Such a regulation, in combination with the continued failure to enforce rules requiring organic livestock to have access to pasture, makes it profitable to produce “organic” milk in industrial concentrated animal feeding operations (CAFOs), where cows are fed cheap imported “organic” grain instead of pasture. Organic consumers do not want CAFO milk, but many will have no other choice without strong regulations. In other words, this serious problem of fraud in organic grain and dairy is not due to a lack of “tools” available to certifiers and inspectors, but to the systematic problems—caused by a system that creates incentives to replace pasture with imported grain. Better enforcement tools can assist in returning integrity to organic dairy, but only if NOP and certifiers enforce access to pasture and promulgate a strong regulation on origin of livestock that closes the loophole allowing dairies to sell or transfer transitioned animals as certified organic.
Plastic is increasingly identified as a source of environmental and health problems, and therefore, should be eliminated in organic production and packaging. 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. Some studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Soil organisms and edible plants have been shown to ingest microplastic particles. Earthworms can move microplastics through the soil, and microplastics can move through the food chain to human food. Microplastics can have a wide range of negative impacts on the soil, which are only beginning to be studied, but include reduction in growth and reproduction of soil microfauna. Microplastics can serve as hotspots of gene exchange between phylogenetically different microorganisms by introducing additional surface, thus having a potential to increase the spread of antibiotic resistance gene] and antibiotic resistant pathogens in water and sediments. Plastic mulches, including those called Biodegradable Biobased Mulch Film (which do not fully degrade), should be replaced with natural mulches such as straw, hay, wood chips, and cover crops that add organic matter to the soil. Replacement of plastic in packaging should be a research priority.
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.)
We have to stop putting toxins into our environment immediately! NOW!
September 29th, 2021 at 4:47 pmSeedless fruit and veggies are not organic – fix it now
September 29th, 2021 at 10:55 pmIn what world is the standard for “organic quote not required to rigorously support nontoxic farming techniques etc.? Real is real! The very popular “organic quote designation is popular for a reason! The public wishes to consume food that is not poisoned. Please respect that and guarantee that the organic designation means what it is supposed to mean!!!
September 30th, 2021 at 5:22 pmWe need our air, food, and water to be free of pollution and pesticides.
October 1st, 2021 at 5:20 pm