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Fall 2020 NOSB Meeting

National Organic Standards Board

Fall 2020 NOSB Meeting
Comment by October 1, 2020!

Priority Issues

For more detailed analysis, scroll down to the description and links. For quick copy and paste, use the text below to comment at Regulations.gov. Add a personal message about why this is important to you at the top, if possible.

  • Do Not Allow Virgin Paper in Organic Crop Production Aids. The Crops Subcommittee proposes to allow planting aids—including paper pots, seed tape, and plant collars—made from virgin paper. To date, the National Organic Program has allowed only recycled paper to be used in crop production (as mulch and in compost). Virgin paper—especially virgin paper from wood pulp—results in much greater environmental impacts than recycled paper and does not foster cycling of resources. Use of virgin paper made from hemp reduces some of these impacts, but adds the impacts of agricultural hemp production. Virgin paper from wood pulp should not be allowed as a crop input in organic production.
  • Get Plastic Out of Organic. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size in size—on a wide range of organisms. Although concerns were first raised about microplastics in the marine environment, impacts on terrestrial organisms are increasingly documented. 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. Biodegradable biobased mulch film (BBMF) has been allowed in organic production since 2014, but no products meeting the requirements set by the NOSB are produced, so the NOSB is considering loosening the requirements (annotation). Furthermore, use of BBMF results in bits of microplastic that are not fully degraded. Synthetic mulches should not replace natural mulches like hay, straw, and wood chips. The annotation of BBMF should not loosen up restrictions on the bioplastic film.
  • Protect Marine Life. Seaweeds (marine algae) and fish byproducts are used as inputs into organic crop production, but there is concern about the impacts of overharvesting and destructive harvesting methods, so the Materials Subcommittee proposes to allow marine algae to be used only when the harvest meets specific conditions. These requirements should be adopted by the NOSB, along with strong enforcement provisions. Separate action on fish products proposed by the Crops Subcommittee is too weak because it is unenforceable and allows the commercial use of bycatch. Only fish byproducts from postconsumer waste should be allowed as soil inputs.
  • Tell the National Organic Program to Finally Take Action on “Inert” Ingredients. After years of NOSB action and NOP inaction on “inerts,” the Crops Subcommittee proposes the only action it can to stimulate NOP into action—it proposes to remove List 4 from the National List. According to the Organic Foods Production Act, NOP cannot allow the use of synthetic materials that are not supported by the NOSB. “Inert” ingredients are neither chemically nor biologically inert. They make up the bulk of pesticide products—sometimes as much as 99%--and have not been subjected to the scrutiny by the NOSB that has been applied to the few active pesticidal ingredients allowed in organic production. The NOSB must approve the Crops Subcommittee motion to remove the listing of List 4 “Inerts” and implement prior NOSB recommendations.

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Fall 2020 NOSB Meeting

The Fall 2019 NOSB meeting dates have been announced and public comments are due by October 1, 2020. Your comments and participation are critical to the integrity of the organic label.

Meeting dates are:

  • Public Comment Webinar Day 1: Tuesday, October 20 from Noon - 5:00 pm Eastern
  • Public Comment Webinar Day 2: Thursday, October 22 from Noon - 5:00 pm Eastern
  • NOSB Public Meeting Day 1: Wednesday, October 28: from Noon - 5:00 pm Eastern
  • NOSB Public Meeting Day 2: Thursday, October 29 from Noon - 5:00 pm Eastern
  • NOSB Public Meeting Day 3: Friday, October 30 from Noon - 5:00 pm Eastern

Where? The NOSB Fall Meeting 2020 will be held live online, instead of in-person.  Meeting access information is here.

Written comments may be submitted through Regulations.gov  until 11:59 pm ET October 1, 2020. Reservations for in-person and webinar comments close at the same time.

The proposals of the National Organic Standards Board (NOSB), as a part of its ongoing review of practices and materials, are published for public comment. The public comment period will end October 3, 2019. On this page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board when it meets in Pittsburgh, PA on October 23 - 25, 2019. Please see Beyond Pesticides' analysis below (and more coming soon).

Issues Before the NOSB for Fall 2020

Materials in the list below are either the subject of petitions or the subject of sunset review. Petitioned materials must have evidence summarized in the proposals that they meet the OFPA requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices. Sunset items are already on the National List, and being considered for delisting. They are subject to the same criteria, but are being considered under NOP's new rules.

The NOSB will vote on materials subject to "2022 sunset review" at this meeting.

To truly make an impact in the future of organic, Beyond Pesticides encourages you to:

**On certain browsers, it may be necessary to download a PDF version of Beyond Pesticides' comments in order to view the navigation pane**

Crops Subcommittee

Handling Subcommittee

Livestock Subcommittee

Materials Subcommittee

Policy Development Subcommittee

 

Draft Meeting Agenda

 

 

Take Action at Regulations.gov!
(Comments Due October 1, 2020!)

 

See All Comments So Far

 

See Beyond Pesticides' Commenting Guidelines

 

See All Meeting Materials and Issues

 

The Organic Foods Production Act

 

Petitions

    • Paper Planting Aids
      • Beyond Pesticides’ comments
      • Submit your own comments here
      • Background: Do Not Allow Virgin Paper in Organic Crop Production Aids. The Crops Subcommittee proposes to allow planting aids—including paper pots, seed tape, and plant collars—made from virgin paper. To date, the National Organic Program has allowed only recycled paper to be used in crop production (as mulch and in compost). Virgin paper—especially virgin paper from wood pulp—results in much greater environmental impacts than recycled paper and does not foster cycling of resources. Use of virgin paper made from hemp reduces some of these impacts, but adds the impacts of agricultural hemp production. Virgin paper from wood pulp should not be allowed as a crop input in organic production.
    • Sodium Carbonate lignin
      • Beyond Pesticides' comments
      • Submit your own comments here
      • Background: Sodium carbonate lignin is not eligible to be included on the National List because it does not belong to any of the allowed categories in the Organic Foods Production Act (OFPA), and allowing its use would be inconsistent with organic farming and handling. It is not necessary, and the petition does not present a justification for its necessity for organic production.

Discussion Documents

    • Biodegradable biobased mulch annotation change
      • Beyond Pesticides' comments
      • Submit your own comments here
      • Background: Get Plastic Out of Organic. Scientists are increasingly concerned about the impacts of microplastics—plastic fragments less than 5 mm in size in size—on a wide range of organisms. Although concerns were first raised about microplastics in the marine environment, impacts on terrestrial organisms are increasingly documented. 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. Biodegradable biobased mulch film (BBMF) has been allowed in organic production since 2014, but no products meeting the requirements set by the NOSB are produced, so the NOSB is considering loosening the requirements (annotation). Furthermore, use of BBMF results in bits of microplastic that are not fully degraded. Synthetic mulches should not replace natural mulches like hay, straw, and wood chips. The annotation of BBMF should not loosen up restrictions on the bioplastic film.
    • Ammonia Extracts
      • Beyond Pesticides’ comments
      • Submit your own comments here.
      • Background: Highly soluble fertilizers—whether synthetic or nonsynthetic—are not consistent with organic principles, particularly, “Feed the soil, not the plant.” In addition, ammonia extracts are toxic to soil organisms and unnecessary in an organic system that depends on feeding soil organisms with manures, compost, and other organic materials.

Sunset

Other Issues

  • Wild, Native Fish for Liquid Fish Products
    • Beyond Pesticides’ comments
    • Submit your own comments here
    • Background: Prohibiting the use of wild, native fish in liquid fish products used for fertility in organic crop production is not only a good idea, but is required to be consistent with organic principles. However, although well-intended, the attempt to avoid impacts on marine ecology by distinguishing wild, native fish from others, which might be acceptable for use in liquid fish products, is doomed because it is unenforceable and cannot prevent damage to marine ecosystems.

Back to the table of contents

 

Petition

  • Low acyl gellan gum
    • Beyond Pesticides’ comments
    • Submit your own comment here.
    • Background: Low acyl gellan gum should not be allowed by listing on §205.605(b) because it is a synthetic additive that is not necessary for organic food production. The Organic Foods Production Act (OFPA) establishes criteria for listing materials that may be used in organic production and handling that are “otherwise prohibited.” Synthetic materials are prohibited unless specifically allowed. The criteria for allowing such “otherwise prohibited” substances to be allowed in organic production and handling include that the substance “is necessary to the production or handling of the agricultural product because of the unavailability of wholly natural substitute products” and that it “is consistent with organic farming and handling.” In addition, the NOP regulations (§205.600(b)(6)) require that “any synthetic substance used as a processing aid or adjuvant” must be “essential for the handling of organically produced agricultural products.” Low acyl gellan gum does not meet these requirements.

Discussion Documents

  • Whey Protein Concentrate Petition to Delist
      • Beyond Pesticides’ comments
      • Submit your own comment here.
      • Background: In Fall 2015, the NOSB voted unanimously to remove whey protein concentrate from the National List. After five years, it has not been removed. Meanwhile, the Organic Integrity Database lists 32 suppliers of organic whey protein concentrate. As pointed out by the Handling Subcommittee (HS), organic producers can more than meet the demand. It should be removed and taken off the NOSB agenda

Sunset

Other

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Petition

  • Fenbendazole
      • Beyond Pesticides' comments
      • Submit your own comment here
      • Background: Research shows use of fenbendazole in poultry does not meet OFPA criteria—that it may harm the environment, allow residues in organic eggs that are not compatible with organic practices, and is not necessary for organic poultry production. “Emergency” has not yet been defined in the regulations.

Sunset

Other Issues

Back to the table of contents

  • Marine materials
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: The definition of “organic production” in the organic regulations requires the conservation of biodiversity. The proposal by the Materials Subcommittee goes a long way towards protect marine habitats from removal of organisms to use as inputs in organic crop production. The NOSB should give thought to making it more enforceable and ensuring that it protects marine communities as well as targeted seaweeds.
  • Excluded Methods
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Since 2016, the NOSB has clarified in unanimous recommendations that the following eleven methods are excluded in organic: Targeted genetic modification, gene silencing, accelerated plant breeding techniques, synthetic biology, cloned animals and offspring, plastid transformation, cisgenesis, intragenesis, agro-infiltration, transposons developed via use of in vitro nucleic acid techniques, and induced mutagenesis through in vitro techniques. NOP should codify the prohibition in organic for these eleven methods by publishing a guidance document for the NOP handbook to ensure clarity for all stakeholder groups. The NOSB should move forward in evaluating the remaining technologies that have not yet been determined—using a transparent process that solicits input from key stakeholder groups and ensures that excluded methods are kept out of organic production.
  • Research Priorities
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Research priorities should address needs of producers and not sales. A few of the identified priorities seem to be directed towards the issue of establishing organic food as a valid and valuable option in the marketplace. While this research is useful, it can be encouraged by organizations like the Organic Trade Association, leaving public resources available to address needs of organic producers. Pesticide development is an inappropriate organic research priority. Therefore, we suggest eliminating the research priority, “Side-by-side trials of organic synthetic materials, natural materials, and cultural methods, with a request for collaboration with the IR-4 project.” The IR-4 Project is self-described as “the primary entity in the United States to facilitate registrations of conventional pesticides and biopesticides on Specialty Food crops (fruits, vegetables, nuts, herbs, spices) and non-food Environmental Horticulture crops.” Research is needed into packaging materials. Research into alternatives to BPA has been identified as a research priority, but the need is greater than that. Some BPA “alternatives” are just as problematic as BPA. In addition, the proliferation of plastic in packaging is reflected in its presence in the environment. Organic producers and (especially) processors should be seeking ways to eliminate plastic.
  • Sanitizers
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Both in terms of a strict reading of OFPA and common sense, it is clear that all cleansers and antimicrobials used in organic production and handling should be on the National List, regardless of the intervening steps. The comprehensive review of these materials should start with an identification of the needs in organic production and handling.

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  • Consent Agenda
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: There are several prerequisites that have been generally accepted for placing business items on a consent agenda (or consent calendar). As noted in Robert’s Rules, they are generally routine or noncontroversial issues. Some have offered the examples of minutes, committee reports, routine correspondence, and final approval of proposals or reports that have been fully discussed and vetted at past meetings. The use of a consent agenda by the NOSB does not meet those criteria and would eliminate much transparency, which is necessary for the NOSB to function as an avenue for advising USDA about organic production.

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