Fall 2022 NOSB Meeting
National Organic Standards Board
Fall 2022 NOSB Meeting
Comment by September 29th, 2022!
The NOSB Fall Meeting 2022 will be held in-person Tuesday October 26th through Thursday October 27th, 2022 in Sacramento CA. The meeting information for remote access will be posted in early October and can be found here.
From the very beginning, with the passage of the Organic Foods Production Act in 1990, “organic” has meant “continuous improvement.” The primary mechanism for continuous improvement in organic production is the high level of public involvement that comes from twice-annual meetings of the stakeholder board.
The second mechanism is the sunset process, which helps move synthetic substances out of organic production as the market invests in growing organic inputs and ingredients. Despite USDA’s efforts to weaken the sunset process, the 5-year cycle of review of every synthetic substance currently used in organic production and processing, offers us an opportunity to keep organic strong and strengthen any weaknesses.
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.
Organic Agriculture is Climate-Smart Agriculture. The NOSB draft letter to Secretary of Agriculture Vilsack is an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to promote conversion to organic farming. More important to addressing the climate crisis than the questions posed by NOP are questions concerning how USDA programs can assist organic producers and those seeking to convert to organic. The draft letter addresses these as well. It also points out the resiliency of organic agriculture: “Organic is the solution to mitigating climate change and responding to it.”In view of the climate benefits of organic and the incentives inherent in organic marketing, the real question is whether USDA will abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry in favor of whole-hearted support for organic agriculture—because despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should make adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs.
Biodegradable Biobased (Bioplastic) Mulch Film (BBMF) is under consideration for sunset this year. This is part of a larger issue of the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles to which it degrades—on human health and the environment. BBMF should not be relisted. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic production and handling—including packaging.
The NOSB should use the sunset process to eliminate non-organic ingredients in processed organic foods Materials listed in §205.606 in the organic regulations are non-organic agricultural ingredients that are allowed to be used as ingredients as part of the 5% of organic processed foods that is not required to be organic. Materials should not remain on §205.606 if they can be supplied organically, and anything that can be grown can be grown organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” Two materials on §205.606 are up for sunset this year—pectin and casings. Both are made from agricultural products that can be supplied organically and thus should be sunsetted.
The NOSB must take a precautionary approach in view of the unknown. Peroxylactic acid (POLA) is petitioned as an antimicrobial agent to be used in processing meat. While a comprehensive review of the needs for sanitizers and disinfectants in organic processing may reveal a need for additional materials, the existing data concerning POLA is incomplete, depending mainly on patents rather than peer-reviewed research. The petition should not be allowed.
In its examination of ion exchange, the NOSB has learned that its application results in chemical change. Therefore, organic foods, such as apple juice or sugar, that have been processed with ion exchange are synthetic. Such synthetic “foods” must only be allowed if the NOSB has reviewed them and placed them on the National List.
Genetic engineering is considered an “excluded method” according to organic regulations. The NOSB should continue to catalog excluded methods, and their use should be excluded at all levels of production—from crop production through inputs in processing.
(Beyond Pesticides will be populating this page over the next several weeks with draft comments on all the other issues)
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Fall 2022 NOSB Meeting
The Spring 2022 NOSB meeting dates have been announced and public comments are due by September 29th 2022. Your comments and participation are critical to the integrity of the organic label.
Where: The meeting will be held in person in Sacramento, CA and online meeting access information will be available here in October.
When: Tuesday October 25, Wednesday October 26, and Thursday October 27, 2022
Written comments may be submitted through Regulations.gov until 11:59 pm ET September 29th, 2022. Reservations for oral webinar comments can be made here. Keep in mind they fill up fast and the deadline is also by 11:59pm ET September 29th, 2022. The online webinar for comments will take place on October 18th and 19th.
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 September 29th, 2022. On this page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board on our website pages. You can view USDA's announcement of the NOSB's meeting and proposals here. Please see Beyond Pesticides' analysis below (and more coming soon).
Issues Before the NOSB for Fall 2022
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 sunset review at the Fall 2020 meeting.
To truly make an impact in the future of organic, Beyond Pesticides encourages you to:
- Become familiar with the issues below;
- See previous comments submitted;
- Submit a public comment by September 29th, 2022 (click here for guidelines!); and
- Register by September 29th to give Oral Comments via the on-line webinars October 18th and 20th, 2022.
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Table of Contents/Navigation to Beyond Pesticides' Comments and Summaries
Compliance, Accreditation, and Certification Subcommittee
Policy Development Subcommittee
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