{"id":20245,"date":"2017-03-17T00:00:22","date_gmt":"2017-03-17T04:00:22","guid":{"rendered":"http:\/\/beyondpesticides.org\/dailynewsblog\/?p=20245"},"modified":"2017-03-17T13:15:00","modified_gmt":"2017-03-17T17:15:00","slug":"protect-organic-integrity-comments-due-march-30","status":"publish","type":"post","link":"https:\/\/beyondpesticides.org\/dailynewsblog\/2017\/03\/protect-organic-integrity-comments-due-march-30\/","title":{"rendered":"Protect Organic Integrity; Comments Due March 30!"},"content":{"rendered":"

(Beyond Pesticides<\/em>, March 17, 2017) Make your voice heard and submit comments NOW<\/a> on allowed materials in organic production! <\/strong>The National Organic Standards Board (NOSB) meeting dates for spring 2017 have been announced<\/a> and public comments are due by March 30, 2017<\/strong>. As usual, there are many important issues that are under NOSB consideration, which you can view by clicking here<\/a>. Your comments and participation are critical to the integrity of the organic label.<\/span><\/p>\n

The NOSB is not immune to delays experienced by agencies throughout the federal government. NOSB proposals were scheduled to be made available to the public on March 1, allowing 30 days for the public to formulate responses before the comment period closes. As of this writing, the proposals have still not been published, but much can be inferred from Subcommittee notes<\/a>, petition materials<\/a>, and past experience. Many of the issues before the NOSB are materials due to sunset off the National List of Allowed and Prohibited Substances (National List) in 2017. Some others are perennial issues of special concern for us \u2013such as \u201cinerts\u201d (undisclosed ingredients) and chlorine-based sanitizers. So, we have written what we can, and we encourage you to make use of our efforts \u2013and we will let you know if and when the proposals are published.<\/span><\/p>\n

Our positions, which we hope you will use as the basis for your comments, can be found here<\/a>. We will provide positions on additional topics in the near future. Please feel free to develop your own comments<\/a> or cut and paste ours. If you cut and paste our comments into regulations.gov<\/a>, please first put a personal note of concern<\/u><\/strong> in order to reflect the importance if these issues to you as an organic consumer, farmer, or other concerned party.<\/span><\/p>\n

As mentioned above, some of the major issues before the spring 2017 National Organic Standards Board include:<\/span><\/p>\n

\u201cInerts\u201d<\/strong><\/span><\/p>\n

There continues to be an unconscionable delay in implementing NOSB recommendations for replacing the obsolete references to EPA List 3 and List 4 \u201cinert\u201d ingredients on the National List with listings of actual approved ingredients in pesticide products that are not labeled active (those that target the pest). These ingredients frequently compose as much as 99% of pesticide products, and due to NOSB scrutiny of active ingredients, they may be the most hazardous ingredients in pesticide products used in organic production. The NOSB must insist that NOP move forward with implementing the NOSB recommendations on \u201cinert\u201d ingredients, beginning with the Memorandum of Understanding between USDA and EPA that establishes the responsibilities of the National Organic Program (NOP), EPA, and the NOSB.<\/span><\/p>\n

Sanitizers<\/strong><\/span><\/p>\n

This includes calcium hypochlorite, chlorine dioxide, and sodium hypochlorite for crops; acidified sodium chlorite, calcium hypochlorite, chlorine dioxide, and sodium hypochlorite for handling; and calcium hypochlorite, chlorine dioxide, and sodium hypchlorite for livestock.<\/em><\/span><\/p>\n

To the extent possible, organic should be chlorine-free. Chlorine is hazardous in its production, transportation, storage, use, and disposal. EPA’s Design for the Environment has identified safer viable alternatives for some or all uses, including other materials on the National List. It is time for the NOSB to update its thinking and approach to cleaners and disinfectants. Several steps need to be taken:<\/span><\/p>\n

    \n
  1. The Organic Foods Production Act (OFPA) requires that materials on the National List are itemized \u201cby specific use or application.\u201d Justification for the listing of chlorine materials requires that the NOSB identify the uses for which they are needed. Needs for cleaners, sanitizers, disinfectants, and sterilants must be distinguished.<\/span><\/li>\n
  2. Freedom from microbes is not always good. Not only is sterility often unnecessary, but it is also sometimes counterproductive because eliminating benign microbes can make room for spoilage organisms or pathogens.<\/span><\/li>\n
  3. Establishing the need for a \u201csanitizer\u201d requires a demonstration that a certain degree of freedom from microbes is required. The NOSB must establish when microbes should be removed from what and the degree to which they must be removed.<\/span><\/li>\n
  4. Alternative practices and materials must be considered, such as those identified by technical reviews and EPA\u2019s Safer Choice Program.<\/span><\/li>\n
  5. NOSB must examine the need for these materials in light of alternatives and hazards.<\/span><\/li>\n
  6. Chlorine compounds have long been identified as hazardous to humans and the environment. The NOSB, in reviewing the listings of these materials, must delve into the needs, alternatives, and hazards.<\/span><\/li>\n<\/ol>\n

    Contaminated Inputs<\/strong><\/span><\/p>\n

    The plan to address contaminated inputs in organic production \u2013last addressed by the NOSB two years ago\u2013 is needed more urgently than ever. The problem of contaminated water resources only adds to the problems already identified, including antibiotics in manure, pesticides in lawn wastes, and others. We urge the NOSB to devote resources to furthering the plan and its implementation, including the development of a discussion document on water contaminated by oil and gas production.<\/span><\/p>\n

    NOSB Meeting \u00a0Details:<\/strong><\/span><\/p>\n

    Wednesday, April 19, 2017 \u2013 8:30am to Friday, April 21, 2017 \u2013 5:00pm<\/span>
    \n Sheraton Denver Downtown Hotel, 1550 Court Place, Denver, CO 80202<\/span><\/p>\n

    If you plan on attending the meeting<\/a> and want to provide oral comments, you must reserve an oral comment slot<\/a>. Oral public comments are scheduled in two blocks:<\/span><\/p>\n