Spring 2023 NOSB Meeting

Proposals

• Organic Is Climate-Smart Agriculture

• Beyond Pesticides' comments
• Submit your own comment here
• Background: With the announcement of the Partnerships for Climate-Smart Commodities, the organic community engaged in a celebration of the forward-thinking funding and policy goals embracing our collective concern for a resilient farming future. The certified organic community has been involved in 20 years of consensus-making in a public-private partnership with the United States Department of Agriculture (USDA) National Organic Program (NOP) and the National Organic Standards Board (NOSB). The NOSB process represents countless hours of research, stewarding innumerable acts implementing a voluntary regulatory program through which producers are paid a premium for their systems-based approach (collection of climate-smart practices), by which consumers can be assured of climate-smart decision making with transparency and the force of law.

Discussion Documents

• Climate Induced Farming Risk and Crop Insurance

  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: As USDA begins the process of implementing the Transition to Organic Partnership Program (TOPP), there is heightened urgency to help transitioning and existing organic farmers manage their risk. Transitioning farmers face challenges regarding farming methods, yields, on-farm production practices, and marketing. Existing organic farmers face increasing risk as climate change creates on-farm problems such as flooding, drought, and hail. As USDA enters a new era, promoting climate-smart practices, the NOSB notes that the best climate-smart production system is one that is certified organic. 

• Oversight Improvements to Deter Fraud, Consistent Location Identification

  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The location of certified organic operations, including fields is inconsistently recorded and managed across certifiers. This challenges the industry, leading to a gap in certifiers' ability to accurately crosscheck the operations and fields they certify with other certifiers. Furthermore, some certifiers cannot conduct independent verification or unannounced inspections of fields because they don’t have mapping capabilities of all field locations.

The new Strengthening Organic Enforcement (SOE) rule will make supply chain tracebacks and mass
balances mandatory. Complete supply chain tracebacks will require many certifiers to work bidirectionally up and down the supply chain in cooperation with other certifying bodies.

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Discussion Documents

• Potassium Sorbate

  • Beyond Pesticides’ comments
  • Submit your own comment here
  • Background: Potassium sorbate, referred to as KS throughout the report, is being petitioned for use as an active ingredient for plant disease and insect control/suppression in field and greenhouse applications. The petition states that potassium sorbate will be an effective tool in a crop disease-resistance program with its contact mode of action, and that it is not suspected to contribute to the phytotoxicity of crops.
    

Sunset

• • 2025 Sunset Substances Review

    • Beyond Pesticides' comments: Sunset 601
    • Submit your own comment here

    Alcohols: Ethanol

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Ethanol is used in organic crop production as an algicide, disinfectant, and sanitizer, including irrigation system cleaning. The Crops Subcommittee noted there is little to no environmental or human health impacts associated with the use of ethanol. In the 2017 sunset review, the NOSB voted unanimously to keep ethanol on the National List. Public comments during 2017 were mainly in favor of keeping ethanol on the National List, but one commenter
      did suggest that organic ethanol sources should be investigated

Alcohols:Isopropanol

• • • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Isopropanol is used for a variety of industrial and consumer uses. In organic crop production, isopropanol can be used as an algicide, disinfectant, and sanitizer. Isopropanol has broad-spectrum antimicrobial activity against vegetative bacteria, viruses, and fungi. The Crops Subcommittee reviewed the use, manufacturing, and environmental concerns of isopropanol,
      and previous NOSB reviews. When isopropanol was reviewed for the 2017 sunset, the vote by the NOSB was unanimous in retaining it on the National List. Public comments from stakeholders were mainly in favor of keeping it on the National List as an example of why multiple sanitizers and disinfectants are needed and listed for organic use

Sodium carbonate peroxhydrate

• • • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: According to the 2014 TR and previous reviews by the Board, sodium carbonate peroxyhydrate has been used in organic production as an algaecide in rice fields, ponds, ditches, and irrigation lines. It was added to the National List in 2007 as an alternative to materials such as copper and chlorine; it has been registered for use in rice since 2010. In wider legal uses of the substance, “In its primary registration by the US Environmental Protection Agency (EPA) as a biopesticide, use sites for sodium carbonate peroxyhydrate include ornamental plants, turf grasses, terrestrial landscapes, commercial greenhouses, garden centers, nurseries, and storage areas. Target pests included algae, moss, liverworts, slime molds and their spores. There was no food use authorized.” (TR 104-107)

Newpaper or other recycled paper, without glossy or colored inks

• • • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Newspaper and other recycled paper is commonly used in organic agriculture as a non-chemical means of weed management and soil moisture retention, soil temperature moderation, and boosts to soil organic matter. It is also used to shade out plant growth; it then degrades into the soil. It is also used in organic agriculture as a compost feedstock. Effectively, the newspaper or recycled paper is a carbon source – or food -- for active compost processing.

Plastic mulch and covers

• • • Beyond Pesticides’ comments
    • Beyond Pesticides' comments addendum
    • Submit your own comment here
    • Background: Plastic mulches and covers provide multiple functions in organic production including, but not limited to,weed barrier, soil, nutrient and water retention, soil warming, soil solarizing, high and low tunnels, and  reflective barriers for insect pests.

Aqueous potassium silicate

• • • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Aqueous potassium silicate is used as an insecticide for insects and mites. Formulations of aqueous potassium silicate are either sprayed on the foliage of plants or incorporated in the soil with the goal of plant uptake across root and leaf boundaries. The silica tetrahedra are purported to be incorporated in boundary cells (in roots and leaves) inhibiting insect feeding and the onset of plant disease infection. The action of applying potassium silicate in a foliar spray serves to induce production of phytoalexins, chitinases and that in turn  strengthen stroma and cell walls. 

Elemental Sulfur

• • • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: 
    • Approved legal uses of the substance (TR 67-75): Elemental sulfur is currently on the National List of Allowed and Prohibited Substances as a synthetic substance allowed for use in organic crop production for the following categories:
      1. For uses as an insecticide, including acaricides or mite control (7 CFR)) 205.601 (e)(5).
      2. For plant disease control (7 CFR 205.601(i)(10)).
      3. As plant or soil amendments (7 CFR 205.601(j)(2)).
      The current sunset review includes all three listings of sulfur, used as an insecticide, plant disease
      control, and as a plant or soil amendment. NOSB Proposals & Discussion Documents April 2023 50 of 199 Sulfur is an essential plant nutrient, naturally present in our food and soil, and is part of normal human biochemistry. When sulfur is used as a soil amendment it can have a strong acidifying effect by replacing sodium with calcium in high pH alkali soils. Sulfur is considered the fourth major plant nutrient after nitrogen, phosphorus, and potassium-. Sulfur can also be used to control insects and/or diseases. It is approved for use on conventional and organic crops to help control fungi and other pests and is commonly used on farms domestically and internationally.

Lime Sulfur

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: Lime sulfur is on the National List at §205.601(e)(6) as an insecticide (including acaricide or mite control) and at §205.601 (j)(6) for plant disease control. As an insecticide, lime sulfur is used to control mites (spider mites and rust mites), aphid, and San Jose scale in tree fruit and other organic crops. As a fungicide, it is used to control powdery mildew, anthracnose, scab, peach leaf curl, fire blight, and several other plant diseases in tree fruit and berry crops. 

Hydrated Lime

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: Hydrated lime is a synthetic substance limited for use in organic crop production for plant disease control and as an external pest control in organic livestock production (7 CFR §205.603(b)(6)). Regarding livestock applications, hydrated lime may not be used to cauterize physical alterations (medical treatment) or deodorize animal wastes. Hydrated lime, also known as calcium hydroxide, is listed for handling as an allowed synthetic, nonagricultural substance which may be used as an ingredient in or on processed products (7 CFR 205.605(b)(8)).

Liquid Fish Products

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: Liquid fish products are used as fertilizers in the production of organic crops. Liquid fish products contain fundamental nutrients and many trace minerals critical for use in organic farming. Liquid fish foliar application can deliver important nutrients that can reduce certain nutrient stresses which can, in turn, improve crop yields.

Sulfurous Acid

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: The primary use of sulfurous acid is as an acidifying agent to neutralize and reduce excessive alkalinity in soil and/or water. The resulting acidic irrigation water can be helpful with nutrient deficiencies that arise when saline or alkaline conditions tie up essential micronutrients. This use supports improved crop yields and can help to reduce soil degradation from salinity build up.

Ethylene Gas

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: Ethylene gas is on the National List for use as a plant growth regulator, for organic pineapple production only. Ethylene gas is used to induce uniform flowering in pineapples and is applied 7-15 months after planting. Application can be repeated two to three times after the initial application (2011 TR lines 53-56). Ethylene gas is made from hydrocarbon feedstocks, such as natural gas liquids or crude oil. Operators should be well trained and prepared. However, the safety concern to workers is limited when correctly used and monitored (2007 TAP, pg. 4).

Microcrystalline cheesewax

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: Microcrystalline cheesewax has been used in organic agriculture as a production aid in log-grown shiitake mushrooms since the 1980s. Microcrystalline cheesewax is used to seal holes in hardwood logs (commonly oak) after the shiitake spawn is inserted.

Potassium chloride

• • • Beyond Pesticides' Comments
    • Submit your own comment here
    • Background: Potassium is required for health in humans, plants, and microorganisms (1995 TAP pg. 4, 14). Potassium is an essential element for plants as they use it to regulate movement of water and nutrients within the plant, photosynthesis regulation, and enzyme activation. While potassium is found in many soils, it may not exist naturally in a high enough concentration for optimal plant growth, and/or it may be present but in a bound format rendering it unavailable. Potassium is commonly used by growers either alone, as a complex in potassium chloride, or as an ingredient in a fertilizer blend for soil supplementation. Chloride is also an essential element for plants (TAP pg. 12); however, monitoring of chloride use is required to assure soil salinity is managed appropriately. The current annotation in the NOP regulations stipulates chloride monitoring when potassium chloride is used to prevent chloride accumulation in soils.

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Proposals

• Ion exchange resins

  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Phosphoric acid is used in organic handling and processing as a cleaning agent for “food contact surfaces and equipment,”. Phosphoric acid has been approved for pH adjustment of some soil amendments (liquid fish products and squid byproducts) and as an equipment cleaner in both organic crop and livestock production. Phosphoric acid has been used as an ingredient in plant
    extractions. When used in this manner, phosphoric acid acts as an acidifying agent and stabilizer to facilitate more efficient extraction of target compoundsThe petition is intended to be limited to extracting target molecules from plants of the lamiaceae family. The extracted target molecules may be subsequently blended with appropriate carriers for help in proper dispersal across the surface of finished food products. Application depends on the finished food matrix as different extracts have hydrophilic or lipophilic properties.”

Sunset

2025 Sunsets 205.605 and 205.606

• • Beyond Pesticides' comments
  • Submit your own comment here
• Calcium carbonate
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: During the Fall 2018 Board meeting, public commenters widely supported the relisting of this material, noting its essentiality to organic production in the absence of viable alternatives. Commenters detailed uses including in soy cheese, yogurts, and beverages as a source of calcium; as much as 15% of the RDA. Comments also pointed to its use as a stabilizer. Calcium carbonate is not listed in the Organic Foods Production Act of 1990.
• Flavors
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Natural flavors are typically used in very small amounts in products (approximately 0.05 to 0.40 percent of ingredients) that contain less than optimal amount of flavor necessary to give the finished products the desired flavor profile. Natural flavors are widely used in baked goods, dairy products, jams and jellies, snack foods, and juice products, as well as in many other foods. Natural flavors are often
    proprietary formulations developed specifically for their intended purpose and functionality of the
    finished product. The significant function of natural flavors must be flavor rather than nutrition.
• Gellan Gum
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Gums are used in organic handling for different reasons, including: (1) thickening and gelling, (2) stabilizing foams, emulsions, and dispersion, (3) inhibiting ice and sugar crystal formation, (4) aiding formulation, and (5) controlling the release of flavors.
• Oxygen
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Oxygen is used in modified atmosphere packaging, the processing of olives, and by wineries, breweries, and manufacturers of carbonated beverages. Oxygen is an odorless and tasteless gas and is commonly used to help maintain color and prevent pallor in food (although in some volumes, it can have the opposite effect). It can also aid in inhibiting the growth of bacteria. Oxygen can be helpful in a modified atmosphere packaging environment because it can help prevent spoilage in products that are high in sugar or water.
• Potassium chloride
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: According to the Food & Drug Administration FDA), potassium chloride is generally recognized as safe (GRAS). Affirmed uses of potassium chloride in foods are as a flavor enhancer, flavoring agent, nutrient supplement, pH control agent, and stabilizer or thickener. Like salt, potassium chloride provides a salty flavor and can also often play other functional roles (such as microbial management, protein modification, flavor enhancement) that affect the taste, texture, and shelf life of food products. Potassium chloride is generally used for two main purposes in food products: to provide potassium enrichment to foods, and as a salt replacement to reduce the sodium content in foods.
• Alginates
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Alginates are used in food production and handling as an emulsifier or emulsifier salt, firming agent, flavor enhancer or flavor adjuvant, formulation aid, processing aid, stabilizer or thickener, surface-active agent, and texturizer.

• Calcium hydroxide
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Calcium hydroxide is used in food processing as a buffer, neutralizing agent, and firming agent. It is used in making calcium acid phosphate (a component of aluminum-free baking powder) and in nutrient supplements. Calcium hydroxide is an available source of calcium, an essential nutrient. In this regard, limestone (calcium carbonate) and thus calcium hydroxide, an essential intermediate in the industrial utilization of limestone, have no alternatives
• Ethylene
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Ethylene is used in the post-harvest ripening of tropical fruit and the de-greening of citrus. Ethylene produced naturally by fruits has not been commercialized, and the mount produced for agriculture are small compared to emissions from car exhaust, petrochemical plants, or fires.
• Glycerides (mono and di)
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Mono- and diglycerides have many applications as food processing aids. They are principally used as emulsifiers. This function also translates into stabilization, preventing food separation, stabilizing air pockets and extending shelf life [TR 2015 82-83]. However, the only use for which mono- and diglycerides are permitted in organic food processing is in the drum drying of food. In this application,
    mono- and diglycerides can have various functions, but most significantly they act as an emulsifier and
    release agent. When mixed with food, mono- and diglycerides help prevent sticking during processing,
    and in drum drying they help to strip the food from the cylinder walls once dried. In drum drying, a
    puree or slurry of food is added to one or two heated cylinders at varying feed rates depending on the
    particular food’s viscosity. As the cylinders or drums rotate, the slurry dries. The process creates powder
    or very fine flakes that can serve as the basis for snacks, soups, baked chips, some bakery items and
    cereals [TR 2015 91-92]. The use of mono- and diglycerides in dehydrated potatoes also aids in
    rehydration [TR 2015 105-106]; at the spring 1995 National Organic Standards Board (NOSB) meeting, it
    was noted that the food industry was trying to move away from use of mono- and diglycerides, but that
    they were still needed for potato flake products [TR 2015 168-172].
• Magnesium stearate
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Magnesium stearate (CAS # 557-04-0) is not commonly used in organic products (TR 2018 102). In conventional production, it is routinely used as an anti-caking agent in salt, spices, powdered foods and drinks, leavening agents, and candy (TR 2018 103-105). It is a flow agent, food processing machine lubricant, and may be an incidental additive. The most common use of magnesium stearate is as a binding agent in dietary supplements. Magnesium stearate is permitted for use only in agricultural
    products labeled “made with organic (specified ingredients or food group(s))” and is prohibited in
    agricultural products labeled “organi
• Phosphoric acid
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Phosphoric acid is used in organic handling and processing as a cleaning agent for “food contact surfaces and equipment,” as described in 7 CFR 205.605(b). Phosphoric acid has been approved for pH adjustment of some soil amendments (liquid fish products and squid byproducts) and as an equipment cleaner in both organic crop and livestock production. (7 CFR 205.601 and §205.603)
• Potassium carbonate
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Potassium carbonate has a vast amount of uses in organic production. Public comments from the previous sunset review demonstrated a continued need for this material. One manufacturer noted its use as a sodium reduction agent and that removal from the list would result in a rise in sodium levels in their product by 18%. Other commenters noted use in a protein bar and as a nutritional supplement.

• Sulfur dioxide
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Sulfur dioxide has been used as an antimicrobial and antioxidant in food, including wine, since Greek and Roman times. Sulfur dioxide is primarily used to inhibit microbial growth and prevent spoilage and oxidation in wine. It has also been used to preserve conventionally produced meats and avoid browning in fresh and dried produce and other products. The current National List annotation limits the use of sulfur dioxide to wine labeled “made with organic grapes” and further limits the sulfite concentration to not exceed 100 ppSulfur dioxide is considered safe at the levels allowed under the current annotation, which are more restrictive than those for nonorganic wines. Strict sulfite labeling requirements also allow sulfite-sensitive consumers to avoid products with added sulfites. Wine can be made successfully without added sulfites, but many winemakers do not find alternative methods and materials satisfactory to prevent spoilage and oxidation in wine.
• Xanthan gum
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Xanthan gums are one of the many gums used in organic handling for reasons including: (1) thickening and gelling, (2) stabilizing foams, emulsions, and dispersion, (3) inhibiting ice and sugar crystal formation, (4) aiding formulation, and (5) to control the release of flavors. Xanthan gum is an important ingredient for gluten-free products; it also is used in salad dressings, sauces, dairy products, along with other products.

• Fructooligosaccharides
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Fructooligosaccharides (FOS) is on the National List at § 205.606 as a non-organically produced agricultural product allowed as an ingredient in or on products labeled as “organic”. As a non-digestible carbohydrate, this substance is used as a soluble prebiotic fiber ingredient in food products. While FOS is included in food products as a source of energy for probiotic bacteria residing in the gut of humans, it is not used as a nutrient source directly for humans. FOS is incorporated into milk products, cakes, biscuits, cookies, crackers, yogurt, ice cream, soup, and hard candy, among other foods.
• Gums - water extracted only
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Public comment received during the last review noted that while organic versions of these gums existed, the supply chain is inconsistent and therefore commenters supported continued listing at § 205.606. There was also a request that the gums be listed individually so that organic supply of each specific gum could be considered on an individual basis. The Handling Subcommittee’s discussion centered around essentiality, the existence of an organic version and questions as to whether there are any environmental or human health concerns since last reviewes.

• Lecithin - de-oiled
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The major uses for lecithin include as an emulsifier in margarine, chocolates, instantizing powders, release sprays, and baked goods. It is used as a natural surfactant between oil and water systems, as with margarine products. Lecithin also helps modify chocolates for better enrobing and reduces the crystallization of cocoa fat. With baked goods and dough, lecithin improves water absorption, increasing volume and shelf life, as well as improving uniformity. In addition, lecithin is used in pharmaceuticals for a wide range of purposes, including as a dietary supplement and an emulsifying agent for intravenous injections.
• Tamarind seed gum
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Tamarind seed gum is a relatively new gum, that is used as a thickener, stabilizer, emulsifier, or gelling
    agent in processed foods. The peer reviewed literature lists the following uses for tamarind seed gum:
    emulsifier, stabilizer, gelling agent, palatability improver, antimicrobial agent, insulator, odor improver,
    glazing agent, stickiness preventer, and bodying agent. Converts organic waste into biofertilizers. etc... During the last review the NOSB determined that tamarind seed gum posed no harm to the environment or human health and recommended to list it due to its compatibility with organic production and handling systems. The Handling Subcommittee’s discussion centered around essentiality, the existence of an organic version, and questions about any environmental or human health concerns since it was last reviewed
• Tragacanth gum
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Tragacanth gum is a polysaccharide that forms a gel that can be used as a thickener and emulsifier. Tragacanth gum forms a gelatinous mass in water and is used as suspending agent, excipient, or emulsifier in food. This material is effective at low pH and at many temperatures. Its stability at low pH is noted as one of its distinguishing characteristics, and it is commonly used in high-acid products like salad dressings (2018 TR). This gum is widely used in low-fat or non-fat products (Nejatian, M., Abbasi, S. and Azarikia, F., 2020.) The percentage of tragacanth gum in final formulations is usually low, below 1% of a total formula (2018 TR).

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Sunset

• 2025 205.603 Sunsets: Synthetic substances allowed for use in organic livestock production

  • Beyond Pesticides' comments
  • Submit your own comment here
• Ethanol
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: he United States Environmental Protection Agency (US EPA) regulates all non-food applications of ethanol, including its use as a pesticide and plant growth regulator. According to the Reregistration Eligibility Decision for Aliphatic Alcohols, ethanol and isopropanol were registered in the US as early as 1948 as active ingredients in indoor disinfectants (US EPA, 1995). Approximately 48 ethanol products were registered for use as hard surface treatment disinfectants, sanitizers and mildewcides as of 2012 (US EPA, 2012a). Ethanol is also the active ingredient in certain plant growth regulator products. The Subcommittee highlighted the fact that to maintain efficacy, producers need a range of sanitizers so
    as to not have any one sanitizer lose its efficacy. Additionally, the benign manufacturing process of this
    material further confirms it as being aligned with OFPA.
• Isopropanol
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Isopropanol is used for a variety of industrial and consumer purposes, ranging from chemical and solvent applications to medical and consumer usage. Agricultural uses of isopropanol include the disinfection of production tools and surfaces and topical antisepsis during medical treatments. Livestock producers may use alcohol (i.e., isopropanol and/or ethanol) solutions for sanitizing and disinfecting surfaces (e.g., production implements, troughs, and floor drains) and during medical treatments as a topical disinfectant.
• Asprin
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Aspirin is important to the humane treatment of organic animals and is commonly used to reduce
    inflammation. It is the only real-time responsive form for inflammation and fever management
    available. There are other products that are available but do not offer the same type of timely response to ensure animal health and well being. This is also a proven remedy and is critical in organic livestock production.
    
• Biologics, Vaccines
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The Organic Foods Production Act (OFPA) specifically allows vaccines to be used in the absence of illness, while prohibiting all other medications from this use. Vaccination against bacterial or viral
    infections is a cost effective and efficient method or lessening animal suffering and disease. A vaccine
    contains, or produces in the vaccinated individual, an antigen that stimulates an immune response and
    enables protection from the disease and/or future infection. In the case of a disease outbreak,
    administration of vaccines may be required by government agencies.
• Electrolytes
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Electrolytes should more properly be called veterinary electrolyte formulations. They are mixtures of multiple synthetic ingredients used to restore ionic balance, especially in oral rehydration solutions to correct dehydration and in oral and injectable formulations for the correction of milk fever. Key
    electrolyte ingredients include calcium, potassium, magnesium, and sodium salts, plus phosphates,
    dextrose, and other additives. Commenters from the previous sunset review universally agreed that electrolytes are essential and should remain on the National List with no changes to the annotation. Organic certification agencies noted they certify many organic producers who use electrolytes to maintain healthy livestock, both mammals and poultry. Environmental and consumer groups, as well as companies that market organic livestock products, also supported the relisting of these materials.
• Glycerine
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Glycerin has over 1,000 uses; however, its use in organic livestock is limited to an ingredient in teat dips. As an ingredient in teat dips it prevents teat irritation and improves skin conditioning. Glycerin does have some germicidal activity. Natural alternatives include castor oil and vegetable oils. There are some management tools for controlling mastitis, which include wiping debris from the teats, massaging the teat to loosen debris and stimulate milk letdown, wiping off the teat dip using individual cloths or paper towels, and applying the milking unit without air admission. None of the management tools seem to be effective alone. The public comments from 2018 were supportive of continued listing of glycerin as a livestock teat dip.
• Phosphoric acid
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Phosphoric acid (H3PO 4) has many uses. As a cleaner, it is generally used to remove rust and mineral deposits found on metal equipment such as boilers and steam-producing equipment. In dairy
    operations, it is used to remove calcium and phosphate salt deposits from processing equipment.
    Phosphoric acid is a hazardous substance. The Subcommittee reviewed the use, manufacturing process, and environmental concerns. A Limited Scope TR was requested, reviewed, and deemed sufficient for explaining alternative practices and products that can be used in place of phosphoric acid. The Subcommittee reviewed the use, manufacturing process, and environmental concerns. A Limited
    Scope TR was requested, reviewed, and deemed sufficient for explaining alternative practices and
    products that can be used in place of phosphoric acid.
• Lime, hydrated
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Under the USDA organic regulations for livestock production, hydrated lime is only permitted for use as an external parasiticide. Regarding livestock applications, the final rule states that hydrated lime may not be used to cauterize physical alterations (medical treatment) or deodorize animal wastes. In the previous sunset review, the majority of public comment supported relisting. Many commenters
    suggested that hydrated lime was essential for organic production in that it prevents the spread of pests
    among herds. A few commenters said that there are no alternatives to hydrated lime. In subcommittee for this review, it was noted that disposal of hydrated lime when treating a herd could be of environmental concern and seek stakeholder input.
• Mineral oil
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background:The USDA organic regulations currently permit the use of mineral oil in organic livestock production for direct topical application and as a lubricant under 7 CFR 205.603(b)(6). Regarding this use pattern, mineral oil acts as an external parasiticide when applied topically to animals infested with mites, lice,
    and other parasites. External parasites such as lice, mange mites, and various insects can adversely
    impact the health of individual animals and lead to economic losses for livestock. These parasites do not
    generally kill their hosts, but they can weaken the animal and, in some cases, transmit diseases to the
    host animals. Mineral oil is also used as a lubricant during artificial insemination (AI)

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Proposals

• Research Priorities 2023
  • • Beyond Pesticides' comments
    • Submit your own comment here 
    • Background: The list of priorities is revisited each year by the NOSB. The list is made meaningful by input through the written and oral public comments shared with the Board, through the expertise of the Board itself and through interactions throughout the year with those engaged in some dimension of the organic farm to fork continuum. When the NOSB has determined that a priority area has been sufficiently addressed, it is removed from the list of priorities. Priorities are also edited each year to reflect the existing need more accurately for new knowledge.

Discussion Documents

• Excluded Methods
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background:The Materials Subcommittee is seeking feedback on the remaining To Be Determined (TBD) List in the Excluded Methods Plant Breeding Techniques discussion document. The goal is to determine whether the techniques are excluded methods under the legal definition at 205.2, OFPA criteria, as well as
    previous NOSB recommendations. . The Materials Subcommittee has requested a limited scope TR for
    induced mutagenesis in order to facilitate the work and has included questions for stakeholder feedback
    in this discussion document.

• Technical Report
  • Beyond Pesticides' comments
  • Submit your own comment here 
  • Background: The Materials Subcommittee (MS) is seeking feedback on an update to the Technical Report (TR)template. The NOSB Policy and Procedures Manual (PPM)1 defines a Technical Report as: “... a report prepared by a third-party expert under contract addressing the environmental, human, and industrial impact of a petitioned material per the OFPA and regulatory evaluation criteria to aid in the thorough evaluation of that material by the NOSB.”
    According to the PPM (Appendix A), “A Subcommittee cannot proceed with a recommendation to list a
    material if it is determined that there is insufficient valid scientific information on that material’s impact
    on the environment, human health, and its compatibility with organic principles.” The NOSB is
    presenting this discussion document to provide the community of experts with an opportunity to
    comment on updates to the format and an opportunity to include relevant questions for materials that
    are at risk for Excluded Methods.

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Discussion Documents

• Petition Improvements
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The Policy Development Subcommittee (PDS) has a responsibility for oversight of the Policy and Procedures Manual (PPM). Among other things, the PPM addresses the requirements for petitions for materials to be used in organic production. Beyond Pesticides supports the suggestions of the National Organic Coalition (NOC) for changes in the Policy and Procedure Manual to improve the petition process. These suggestions are meant to improve the quality of the petitions and limit the submission of petitions to only those that can truly benefit organic producers. Specifically, (1) since virtually anything can now be produced organically, nonorganic 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 should be phased out; (2) petitions must state the specific use or application of the material and demonstrate efficacy; and (3) petitioners should be required to disclose the presence of nanoparticles, and the NOSB should determine whether they are engineered nanomaterials or incidental nanomaterials.

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