Fall 2021 NOSB Meeting
National Organic Standards Board
Fall 2021 NOSB Meeting
Comment by September 30th, 2021!
The National Organic Standards Board (NOSB) meets October 19-21 online to debate issues concerning what goes into your organic food.
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.
Items on the NOSB agenda in April include materials allowed in organic production, as well as discussion of policies and materials (petitions and sunsets) on which the NOSB will vote in the Fall. We have identified some priority issues of both kinds. The only voting issue on the NOSB agenda for this meeting is a petition that would allow the use of paper pots made of virgin paper as a planting aid. Discussion topics provide a good opportunity for the public to have input into framing the issues.
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.
Beyond Pesticides will be populating this page over the next several weeks with draft comments on all the other issues.
Kasugamycin: Antibiotics should not be used in organic production. The National Organic Standards Board (NOSB) is considering a petition to allow the antibiotic Kasugamycin to be used in organic apple and pear production. Earlier NOSB members struggled long and hard to erase the stigma of antibiotic use in organic fruit production—something that was left over from the transition of so many chemical-intensive fruit orchards after the Alar “scare” in which apple and apple products were contaminated with the cancer-causing plant growth regulator daminozide. Do we now want to step on that treadmill again? The reasons for rejecting the kasugamycin petition are the same as the reasons for eliminating the antibiotics streptomycin and tetracycline in crop production.
Now that we have learned what a pandemic looks and feels like, with the astounding levels of infection, hospitalization, and death from COVID-19, we must take serious steps to prevent another pandemic on the horizon—this one tied to bacterial resistance to antibiotics. An important article in The Lancet points to a “looming potential pandemic” resulting from a “rise in multidrug-resistant bacterial infections that are undetected, underdiagnosed, and increasingly untreatable, [which] threatens the health of people in the USA and globally.”
When streptomycin and tetracycline were presented for their final votes by the Crops Subcommittee, the committee was unanimous that the antibiotics needed to go—the question was how fast. How fast could growers of these crops get over their dependence on these antibiotics that pose threats to human health and the environment and are unpopular with organic consumers? Streptomycin and tetracycline are gone, and we do not need another antibiotic.
Copper Sulfate: Copper sulfate should be sunsetted from organic production. The annotation—which recognizes the toxicity of copper in the soil—is one indicator that copper sulfate should not remain on the National List forever. Even more important are the data on ecotoxicity. The toxic effects on the aquatic and semi-aquatic organisms who inhabit rice paddies as a substitute for natural wetlands make copper sulfate incompatible with organic production and unacceptable to organic consumers. It is time to phase out this toxic chemical from organic production.
Carrageenan: Carrageenan should be removed from the National List. The evidence summarized by the 2015 Technical Review came up with a verdict of mixed results on virtually every issue regarding food grade (high molecular weight) carrageenan. However, there is widespread agreement that poligeenan, which contaminates food grade carrageenan at unknown and uncontrollable levels, does cause adverse effects, including cancer. The production causes adverse environmental impacts. And it is not necessary –organic processors have been moving away from the use of carrageen because of consumer pressure since it was last considered for sunset. This is made more urgent by the fact that the National Organic Program ignored the recommendation of the NOSB in spring of 2012 to remove carrageenan from infant foods. Background: One of the most egregious failures of NOP has been its repeated lack of action on so-called “inert” ingredients. Because of that failure, every sunset brings a new NOSB a listing that has not been changed in response to over a decade of NOSB recommendations. EPA has long since (2006) stopped updating the “inerts” lists. The NOSB, which has been demanding since 2007 to review individual “inert” ingredients, has instead been given the option of relisting the outdated lists. List 3 “inerts” should not be relisted again. The identities of the former list 3 “inerts” used in organic production are known, and they should be examined in accordance with OFPA criteria. The NOSB has already recommended an expiration date for these chemicals. In the spring of 2012, the NOSB passed a motion to change the listing to: Inert ingredients exempt from the requirement of a tolerance under 40 CFR 180.1122 that were formerly on EPA List 3 in passive polymeric dispenser products may be used until December 31, 2015, after which point they are subject to individual review under 205.601, unless already covered by a policy adopted by the NOP for all other inert ingredients. NOP refused to codify this recommendation. In doing so, NOP has violated OFPA §6517(d) (2) “No additions. The Secretary may not include exemptions for the use of specific synthetic substances in the National List other than those exemptions contained in the Proposed National List or Proposed Amendments to the National List.”
EPA List 3 - Inerts of Unknown Toxicity: All substances in organic production must be evaluated. One of the most egregious failures of NOP has been its repeated lack of action on so-called “inert” ingredients. Because of that failure, every sunset brings a new NOSB a listing that has not been changed in response to over a decade of NOSB recommendations. EPA has long since (2006) stopped updating the “inerts” lists. The NOSB, which has been demanding since 2007 to review individual “inert” ingredients, has instead been given the option of relisting the outdated lists. List 3 “inerts” should not be relisted again. The identities of the former list 3 “inerts” used in organic production are known, and they should be examined in accordance with OFPA criteria. The NOSB has already recommended an expiration date for these chemicals. In the spring of 2012, the NOSB passed a motion to change the listing to: Inert ingredients exempt from the requirement of a tolerance under 40 CFR 180.1122 that were formerly on EPA List 3 in passive polymeric dispenser products may be used until December 31, 2015, after which point they are subject to individual review under 205.601, unless already covered by a policy adopted by the NOP for all other inert ingredients. NOP refused to codify this recommendation. In doing so, NOP has violated OFPA §6517(d) (2) “No additions. The Secretary may not include exemptions for the use of specific synthetic substances in the National List other than those exemptions contained in the Proposed National List or Proposed Amendments to the National List.”
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Fall 2021 NOSB Meeting
The Fall 2021 NOSB meeting dates have been announced and public comments are due by September 30, 2021. Your comments and participation are critical to the integrity of the organic label.
When: Tuesday October 19, Wednesday October 20, and Thursday October 21st, 2021.
Where: The meeting will be held online on and meeting access information is available here.
Webinars: Comments may be submitted at Webinars on April 20th and 2nnd, 2021. More information about accessing the webinars is available on the NOSB website.
Written comments may be submitted through Regulations.gov until 11:59 pm ET September 30th, 2021. Reservations for oral 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 April 3, 2020. 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 2021
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 30, 2021 (click here for guidelines!); and
- Comment via the on-line webinar October 13 & 14, 2021.
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Table of Contents/Navigation to Beyond Pesticides' Comments and Summaries
Compliance, Accreditation, and Certification Subcommittee
Public Discussion Subcommittee
NOSB Quick Links!
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