Fall 2018 NOSB Meeting

• Fraud Prevention; Developing Criteria for Risk-based Accreditation Oversight; Training and Oversight of Inspector and Certification Review Personnel

  •  Beyond Pesticides' comments
  •  Submit your own comment here
  • Background:  Both the proposal “Developing Criteria for Risk-based Accreditation Oversight” and the proposal “Training and Oversight of Inspector and Certification Review Personnel” would provide positive steps in the direction of eliminating factors that contribute to an accredited certifier having a higher risk of fraud and should be passed. However, the NOSB should go further --fraud is also a problem when crops that are grown with prohibited inputs, when livestock do not get the required access to pasture, and when organic crops are produced in artificial media, and the NOSB should also address these factors.

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Petitions

• Allyl isothiocyanate (AITC)
• Beyond Pesticides' comments
• Submit your own comments here
• Background: Allyl isothiocyanate (AITC) is proposed as a crop fumigant. It would be difficult to find a practice less compatible with organic production than soil fumigation with a “broad-spectrum antimicrobial compound that effectively kills both plant pathogens and beneficial soil microorganisms.” Organic production uses practices that feed soil organisms who feed crop plants. It creates healthy soil food webs. Using a toxic chemical to wipe out soil biology is the antithesis of organic practices. The petition for AITC should be rejected because it is hazardous, not essential for organic production, and incompatible with organic practices.

• Natamycin
  
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Natamycin is an antimicrobial proposed for post-harvest use on organic food crops. It is used in medicine to treat a number of diseases. Natamycin is produced by fermentation, and the NOSB may classify it as a natural material, which would allow its use without restriction. The NOSB should list natamycin on Sections 602 and 604, to prohibit its use in organic crop and livestock production, where use would promote resistance to this medically valuable antimicrobial medication.
• Sodium citrate
  
• Beyond Pesticides' comments
• Submit your own comments here
• Background: Do not support the petition because sodium citrate is not necessary for this use. Sodium citrate does not pose hazards to humans or the environment, but blood may be processed without the use of an anticoagulant such as sodium citrate. Listing of sodium citrate as an allowed synthetic for this use is a convenience that would allow the use of blood meal without documentation regarding its source.

• Strengthen and clarify the requirements for use of organic seed.
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Support the proposal to require that improvement in sourcing and use of organic seed/planting stock be demonstrated every year until the producer uses only organically grown seeds, annual seedlings, and planting stock.

Sunset

• Alcohols : Ethanol and Isopropanol
  
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Ethanol and isopropanol should be relisted if evidence is presented showing that they are not available as organic and/or nonsynthetic alcohols from non-GMO fermentation organisms and feedstock.
• Sodium carbonate peroxyhydrate (SCP)
• Beyond Pesticides' comments
• Submit your own comment here
• Background: SCP should not be relisted. Evidence of its effectiveness has not been presented, and it does not fit into any of the allowed exemptions for synthetic materials used in organic production.
• Newspaper or other recycled paper
  
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Based on information in the most recent technical review, the NOSB should recommend against relisting newspaper and other paper. The new information only leaves more questions regarding how growers can ensure that the paper they use “fosters cycling of resources, promotes ecological balance, and conserves biodiversity,” as required by law. The CS should keep this on its work agenda in order to address some of the issues raised by the review –in particular, whether there is a way for growers and certifiers to identify sources of recycled paper that are compatible with organic principles.
• Plastic mulch and covers
• Beyond Pesticides' comments
• Submit your own comment here
• Background: The NOSB should aim for delisting for plastic mulch, as currently allowed, limiting its use to those cases in which organic mulches or cover crops cannot perform the necessary function. Meanwhile, the NOSB should consider an annotation requiring the highest recycled content available for the plastic mulch. We believe that an annotation is necessary to ensure that OFPA criteria are met. We support research into the most cost- and labor-effective methods of mulching that can be used in place of BBBM or plastic mulch. Such research should consider separately weed suppression and soil warming, for which alternatives may be different. Organic no till practices should be considered to be within the scope of this research.
• Aqueous potassium silicate
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Aqueous potassium silicate for either the insecticide and the plant disease control use. It has been found by the NOSB not to meet the OFPA criteria of essentiality and compatibility with organic production. There are potential adverse impacts that have not been evaluated by the NOSB.

• Elemental sulfur
  
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The NOSB must make a case for the need for sulfur in organic production, protect workers who use it, and ensure that its use does not result in ecological imbalance. The Crops Subcommittee should investigate the particular uses of elemental sulfur in plant disease and insect control to determine when they are necessary, and the committee should propose an annotation for specific uses. These measures may require annotation of the listings in order to ensure that OFPA criteria are met. We suggest this worker protection annotation, “Steps to meet worker protection standards must be documented in the Organic System Plan.”
• Lime sulfur
• Beyond Pesticides' comments
• Submit your own comment here
• Background: The Crops Subcommittee must investigate the particular uses of lime sulfur in plant disease control to determine whether they are necessary, and whether lime sulfur can be used for the purpose without disrupting natural controls. If it can, the listing should be annotated, “For use only when beneficial arthropods are not present.”

• Sucrose octanoate esters (SOEs)

  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: There is insufficient information to evaluate SOEs relative to OFPA criteria. Considering the absence of information and absence of support, SOEs should not be relisted.
• Hydrated lime
•  Beyond Pesticides' comments
•  Submit your own comment here
• Background: Hydrated lime should be relisted with the current annotation. Its negative impacts are associated with use as a soil amendment, which is not allowed.

• Liquid fish products
  
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Liquid fish products should be removed from the National List because they remove valuable nutrients from marine or aquatic ecosystems and are incompatible with organic production. It is concerning that so many growers seem to rely on this synthetic material for routine fertility.
• Sulfurous Acid
• Beyond Pesticides' comments
• Submit your own comment here
• Background: The NOSB should not relist sulfurous acid to correct alkalinity in soil that has accumulated carbonates and bicarbonates through irrigation water in more arid regions. There are potential adverse impacts that have not been evaluated by the NOSB. The NOSB should ask whether the “need” for sulfurous acid reflects unsustainable farming practices. In addition, it would be relevant to discuss the use of sulfurous acid in conjunction with other water issues, such as the use of “produced” water, or water resulting from fracking.
• Ethylene
•  Beyond Pesticides' comments
  
•  Submit your own comment here
• Background: Ethylene gas should be allowed to sunset because it fails to meet the OFPA criteria of freedom from health and environmental harm, essentiality, and compatibility with organic production. There is no category in OFPA allowing an exemption for synthetic growth regulators, and the use of such synthetic materials is contrary to consumer expectations. It appears the ethylene use in pineapples is more a question of economics and farm size rather than agronomic need.
  
• Microcrystalline cheesewax
  
•  Beyond Pesticides' comments
  
•  Submit your own comment here
• Background: Until soy wax or other non-petroleum based wax is available to allow organic producers of mushrooms on logs to choose a more environmentally-friendly alternative, microcrystalline cheesewax should remain on the National List.
  
• Potassium chloride
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Potassium chloride is prohibited unless derived from a mined source and applied in a manner that minimizes chloride accumulation in the soil. Potassium chloride is an extremely soluble form of potassium. The main environmental and compatibility concern is related to excess use, which can result in chloride accumulation in the soil and inhibit nitrification. Therefore, potassium should remain with the annotation that soil testing be required to verify the absence of chloride build-up.

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Other Issues

• “Inerts,” including NPEs
  
• Beyond Pesticides' comments
• Click here to see the full report referenced in Beyond Pesticides' comments
  
• Submit your own comment here
• Background:  “Inert” ingredients frequently compose as much as 99% of pesticide products.  So-called “inert” ingredients are not inert, and are not disclosed to users or others who may be exposed.  Due to NOSB scrutiny of active ingredients “inert” ingredients may be the most hazardous ingredients in pesticide products used in organic production.  We urge the NOSB to insist that NOP move forward quickly with implementation of the NOSB recommendations on inert ingredients.  Allowing the current lack of movement to persist raises serious compliance issues and threatens the integrity of the USDA organic label. The NOSB should not delay in evaluating nonylphenol (NP) and nonylphenol ethoxylates (NPEs), which are “inert” ingredients allowed in organic production.  NP and NPEs are highly toxic to fish, aquatic invertebrates, and aquatic plants.  They are also estrogenic –with significant quantities of direct discharges of NPEs finding their way into surface water from agricultural fields.

• Container production
• Beyond Pesticies' comments
  
• Submit your own comments here
• Background: Hydroponic, aeroponic, or aquaponic operations should not be considered eligible for organic certification. Organic production is soil-based and is defined by principles concerning the growers relationship to the soil. The “Law of Return,” the rule “Feed the soil, not the plant,” and the promotion of biodiversity, provide the ecological basis for organic production. The Law of Return says that we must return to the soil what we take from the soil. The dictum to “Feed the soil, not the plant” reminds us that the soil is a living superorganism that supports plant life as part of an ecological community. Finally, biological diversity is important to the health of natural ecosystems and agroecosystems. Biodiversity promotes balance, which protects farms from outbreaks of damaging insects and disease. It supports the health of the soil through the progression of the seasons and stresses associated with weather and farming. It supports our health by offering a diversity of foods. The NOSB must keep the issue of container and greenhouse production on its agenda until a consensus on regulations consistent with organic principles is reached.
  
• Paper Pots
  
• Beyond Pesticides' comments
  
• Submit your own comments here
• Background: In spite of concerns about the many additives in paper, which include adhesives, such as those used in the paper pots, the characteristics of the pot as planted are probably no worse than the paper currently allowed. The NOSB should recommend that the prohibition on paper pots be postponed, until after the 2019 growing season; commission a technical review to look at the production processes and materials of currently available paper pots, as well as paper pots made by other processes; and, recommend that the NOP facilitate support for the domestic production of paper pots that are compatible with organic principles.
  
• Ammonium Citrate
•  Beyond Pesticides' comments
  
• Submit your own comments here
• Background: A technical review (TR) is needed to evaluate the effect of the glycinates and the chelates. The NOSB should receive more information about chelating agents in general. This should include how natural adsorbing chelating agents differ in their chemistry and impacts from chemical chelating agents like glycinate and EDTA.
• Ammonium Glycinate
  
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: A technical review (TR) is needed to evaluate the effect of the glycinates and the chelates. The NOSB should receive more information about chelating agents in general. This should include how natural adsorbing chelating agents differ in their chemistry and impacts from chemical chelating agents like glycinate and EDTA.
    
    
• Calcium Acetate
• Beyond Pesticides' comments
  
• Submit your own comments here
• Background: The use of calcium acetate as a rapidly available source of calcium is incompatible with organic production. The NOSB should determine the need for a synthetic chemical to reduce heat stress.
  
• Strengthen and clarify the requirements for use of organic seed
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Strengthening and clarifying the requirements for the use of organic seed should remain on the agenda to eliminate inconsistencies in the enforcement of NOP’s broad exemption that allows the use of conventionally produced seed in certified organic

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Petitions

• Ethiopian pepper
  
• Beyond Pesticides' comments
• Submit your own comments here
• Backgroud: Japones pepper, Ethiopian pepper, tamarind seed gum, and collagen gel casings are all petitioned to be listed on §606, nonorganic agricultural materials. It is time to stop adding listings to §606. Organic production is grown up now, and any agricultural commodity can be produced organically. Listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Finally, in the time that it takes to add new regulations, petitioners could develop the demand for the organic product.
• Japones pepper
  
• Beyond Pesticides' comments
• Submit your own comments here
• Background: Japones pepper, Ethiopian pepper, tamarind seed gum, and collagen gel casings are all petitioned to be listed on §606, nonorganic agricultural materials. It is time to stop adding listings to §606. Organic production is grown up now, and any agricultural commodity can be produced organically. Listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Finally, in the time that it takes to add new regulations, petitioners could develop the demand for the organic product.
• Silver dihydrogen citrate
• Beyond Pesticides' comments
  
• Submit your own comments here
• Background: Silver Dihydrogen Citrate (SDC) is an antimicrobial with important medical uses that is proposed for use in handling produce and poultry carcasses. Although the proposed annotation eliminates the nanosilver form, SDC poses health and environmental risks –particularly the risk of increasing resistance to antibiotics and other antimicrobials. The petition for SDC must be denied to protect the effectiveness of remaining antimicrobial medications.

• Sodium chlorite for the generation of chlorine dioxide gas
• Beyond Pesticides' comments
  
• Submit your own comments here
  
• Backgroud: The petition for chlorine dioxide gas produced from sodium chlorite should be rejected because it fails to meet all OFPA criteria. Chlorine dioxide is extremely hazardous to workers and the environment. It is not necessary, as there are other available practices and materials. It is not compatible with organic practices. It is not labeled for the proposed use. The necessary tolerances or exemptions from tolerances do not exist. It is a hazardous chemical used to take the place of care in handling and less hazardous materials. It does not enhance life and properties, is not made from renewable resources, and has a negative impact on biodiversity.
  
• Tamarind seed gum
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Japones pepper, Ethiopian pepper, tamarind seed gum, and collagen gel casings are all petitioned to be listed on §606, nonorganic agricultural materials. It is time to stop adding listings to §606. Organic production is grown up now, and any agricultural commodity can be produced organically. Listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Finally, in the time that it takes to add new regulations, petitioners could develop the demand for the organic product.

Sunset

• Calcium carbonate
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Support the relisting of calcium carbonate, used as a calcium source in soy-based cheese alternative, to provide a similar calcium level for nutritional purposes.
• Flavors
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Flavors should be relisted with the new annotation, which is a small step along the path laid out in the original NOSB recommendation, according to which, producers of flavors used in organic foods should have –and presumably should have been acting on— a plan to move towards all-organic flavors.  An expiration date should be added to encourage further movement towards all-organic flavors.
• Gellan Gum
• Beyond Pesticides' comments
• Submit your own comment here
• Background: TSupport allowing gellan gum to sunset unless the information previously claimed as CBI is released to the NOSB, made available to the public, and considered in NOSB deliberations. The listing should be annotated to ensure that it is not made with materials resulting from genetic engineering. The NOSB should consider the question of whether any of the gums are essential for organic handling and processing.

• Oxygen
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Oxygen should be relisted.
• Potassium chloride
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Support the listing of potassium chloride as a substitute for sodium chloride to reduce the sodium content of foods.
• Alginates
• Beyond Pesticides' comment
• Submit your own comment here 
• Background: Alginates should be removed from the National List unless they have allowed uses for which they are essential and they are produced organically, in order that production not disturb the marine ecology.
• Calcium hydroxide
  
• Beyond Pesticides' comments
• Submit your own comment here 
• Background: The listing for calcium hydroxide should clarify which uses are permitted.
  

• Glycerides: mono- and di-
• Beyond Pesticides' comments
• Submit your own comment here 
• Background: Mono- and di-glycerides should not be relisted because there are nonsynthetic and organic alternatives.
• Ethylene
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Ethylene should not be relisted because it is incompatible with organic agriculture. It is used as a synthetic growth regulator (ripening agent). We agree with one of the TAP reviewers, “This chemical seems incompatible with the principles of sustainable agriculture. The reason for permitting use is related solely to economics since alternatives do exist and would appear to be available to the discrete segment of the agricultural community which is served by this chemical. Moreover, it is a synthetic chemical and a dangerous chemical for its users. While it is not as toxic overall as some synthetics which will remain on the list, it is not as indispensable to a sustainable system of agriculture.”  We also agree with the 1999 TAP review that said, “Ethylene is not an essential material to add to fruit, as sufficiently mature fruit produces it naturally; the minimum required from outside sources is zero.”

• Magnesium stearate
• Beyond Pesticides' comments
• Submit your own comment here 
• Background: The evaluation of magnesium stearate must take into consideration the use of pesticides or genetic engineering in the non-organic production of oils used for its manufacture and the availability of organic oils or sustainably produced palm oil for this purpose. However, it is used only in “made with organic” products and hence does not threaten organic integrity.      

• Phosphoric acid
• Beyond Pesticides' comments
• Submit your own comment here 
• Background: Phosphoric acid poses environmental hazards in manufacture and disposal, and health risks during use. Because its use is slightly different from the other materials on the National List, there may not be a more compatible substance available. Phosphoric acid should be relisted, but the NOSB should seek safer alternatives.

• Potassium carbonate
• Beyond Pesticides' comments
• Submit your own comment here
• Background: PAs presented by the HS, potassium carbonate appears to be a hazardous substance that has many uses, but the HS has not analyzed its essentiality for those uses. The NOSB must consider the essentiality of potassium carbonate.

• Sulfur dioxide
• Beyond Pesticides' comments
• Submit your own comment here 
• Background: Sulfur dioxide is a synthetic preservative, but it is limited in the listing to use only in wine labeled “made with organic grapes,” which does not threaten the integrity of the organic label.

• Xanthan gum
  • Beyond Pesticides' comment
  • Submit your own comment here

  • Background: Xanthan gum should be removed from the National List unless it has allowed uses for which it is essential. The NOSB should consider the question of whether any of the gums are essential for organic handling and processing.

• Fructooligosaccharides (FOS)
  • Beyond Pesticides' comment
  • Submit your own comment here
  • Background: FOS should be removed from §205.606 because it is not an agricultural product. In 2015, the HS said the NOSB has not been given any specifics of an analysis that would allow it to determine that FOS is agricultural, and the technical review does not support classification as agricultural. As a product of fermentation, its production process should be examined closely in the context of NOSB guidance.
• Gums: Arabic, Carob bean, Guar, Locust bean
  • Beyond Pesticides' comment
  • Submit your own comment here
  • Background: The HS should consider an annotation that separates the three gums, so that organic supply (including wild crafted organic) can be taken into account for those that are produced organically or wild crafted. The NOSB should consider the question of whether any of the gums are essential for organic handling and processing.
• Lecithin - de-oiled
  • Beyond Pesticides' comment
  • Submit your own comment here
  • Background: De-oiled lecithin should be allowed to sunset because of the hazards associated with its production and the availability of organic lecithin.
• Tragacanth gum
• Beyond Pesticides' comment
• Submit your own comment here
• Background: Tragacanth gum should not be relisted. There are potential health effects that have not been taken into account, as well as the impacts of nonorganic production of tragacanth gum on consumers, workers, or the environment. The NOSB should consider the question of whether any of the gums are essential for organic handling and processing.

Other Issues

• Collagen Gel (casing) 

  • Beyond Pesticides' comments
  • Submit your own comments here
  • Background: Japones pepper, Ethiopian pepper, tamarind seed gum, and collagen gel casings are all petitioned to be listed on §606, nonorganic agricultural materials. It is time to stop adding listings to §606. Organic production is grown up now, and any agricultural commodity can be produced organically. Listing on §606 only stifles organic production of new organic crops and promotes chemical-intensive production. Finally, in the time that it takes to add new regulations, petitioners could develop the demand for the organic product.

•  Nutrient vitamins and minerals
  
•  Beyond Pesticides' comments
  
• Submit your own comments here
  
• Background: The NOSB must complete work on changing the annotation for nutrient vitamins and minerals. Organic consumers expect that their food contains a full complement of vitamins and minerals based on organic agricultural production practices, not supplementation.  For food– an annotation stating "Minerals (including trace elements), vitamins and similar isolated ingredients are allowed 'only when their use is required by law or to meet an FDA standard of identity in which they are incorporated'” best meets the expectations of organic consumers and original NOSB intent.  For Infant Formula – An argument can be made for allowing supplementation by vitamins and minerals required by 21 CFR 107.100 because infant formula is by its nature artificial.  On the other hand, it does not seem right to allow substances in organic infant formula that are not allowed in other organic foods, so such infant formula should be labeled "made with organic [specific ingredients]," rather than "organic."
  
• Packaging Substances, including Bisphenol A (BPA)
• Beyond Pesticides' comments
• Submit your own comment here
  
• Background: Bisphenol A (BPA) should be eliminated from organic food packaging. At the same time, since known alternatives to BPA may also present similar problems, the NOSB should approach the issue of food packaging in a comprehensive way. The HS should maintain packaging substances as a priority issue and request a technical review on BPA alternatives as well as BPA itself.
• Pullulan
  
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: In view of the data gaps –including definitive data on the lack of alternatives— and the fact that it has not been reviewed by the NOSB, the HS should not act on the pullulans petition before receiving a technical review.
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  Sunset

• Alcohols: Ethanol, Isopropanol
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The NOSB should investigate the availability organic and/or nonsynthetic alcohols from non-GMO fermentation organisms and feedstock. Findings on this issue are necessary to support a proposal to relist. Support the LS proposal to relist ethanol and isopropanol if that evidence is presented..

• Aspirin
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Support the relisting of aspirin because of its importance in treating pain and inflammation.
• Biologics, Vaccines
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Support the relisting of vaccines as listed. The Livestock Subcommittee should ensure consistent enforcement by adding to its work agenda an item that clarifies the listing in §205.603 to explicitly prohibit GE vaccines.
• Electrolytes
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Support the relisting of electrolytes in order to provide support to the animals in times of illness.
• Glycerine
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Glycerine should be relisted. The NOSB needs more clarity around the classification of products of fermentation.
• Phosphoric acid
• Beyond Pesticides' comments
• Submit your own comment here
• Background: .
• Lime, hydrated
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Support the use of hydrated lime when it can replace more toxic inputs. If, as indicated in past comments, the use of hydrated lime as a walk-through can reduce the use of copper sulfate for that purpose, then that use should be encouraged.
• Mineral oil
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Mineral oil should be relisted, but the LS should clarify the potential conflict with FDA concerning the internal use.
    
• Sucrose octanoate esters (SOEs)
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: In view of the difficulty that beekeepers have in maintaining the health of honey bee hives, SOEs should be relisted within a context of defined organic apiculture practices if they are actually used. If there is no support from organic beekeepers for this use, then SOEs should be allowed to sunset. NOP must adopt apiculture rules, which would provide a framework for making decisions about materials used in organic beekeeping.
    

Other Issues

• Day-old chicks
• Beyond Pesticides' comments
  
• Submit your own comment here
  
• Background: Antibiotic resistance is a major threat to human health, and exposure to antibiotics promotes resistance. Agriculture provides the largest source of exposure to antibiotics. The organic standards prohibit the routine use of antibiotics, with the exception of the use of antibiotics in chicks prior to day two of life because the Organic Foods Production Act exempts day-old chicks from organic management. The exemption came about because untreated day-old poultry was not commercially available at the time, but major poultry producers have recently phased out the use of antibiotics in hatcheries for organic and nonorganic production, changing the availability of untreated chicks. We request that the NOSB place this issue on the Livestock Subcommittee work agenda, and recommend a clear prohibition on antibiotics at all stages of life for all farm animals used in organic food production.
  
• Oxalic Acid
• Beyond Pesticides Comments
  
• Submit your own comment here
  
• Background: Oxalic acid is petitioned for use in controlling varroa mites in organic beehives. However, since there are no practice standards for organic apiculture, the NOSB lacks a framework for making a decision on this and other materials used by organic beekeepers. Therefore, this petition should be put on hold until such standards are adopted.

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• Current Research Priorities
  
• Beyond Pesticides' comments
• Submit your own comment here
  
• Background: All of the research priorities identified by the subcommittees should be pursued except for the celery powder proposal. The research priorities on biodegradable biobased bioplastic mulch (BBBM) and methionine in poultry production should be modified. Nonorganic celery powder is allowed as a source of nitrites and nitrates in processing. Given the hazards of nitrites and nitrates in food, research should investigate alternatives to those chemicals instead. Research is needed to help determine the most cost- and labor-effective methods of mulching with natural soil-building materials that can be used in place of BBBM or plastic mulch. Research into methionine alternatives in poultry production should include systems for raising black soldier fly larvae, now that they have been approved as poultry feed.

•   Protecting the Genetic Integrity of Seed Grown on Organic Land and Excluded Methods Terminology
• Beyond Pesticides' comments
• Submit your own comment here
• Background: It is important to protect the genetic integrity of organic crops. The best way is to increase the use of organic seed, but it is important to have a protocol for those cases in which organic seed is not available. Much of the MS proposal makes sense – it makes sense to view any system adopted now as a starting point, to be improved as we learn more; it makes sense to start with corn, which is the most at-risk crop, and to extend the process to other at-risk crops. However, rather than allowing the organic grower to choose a degree of purity, up to “over 5%,” it would make sense to create a minimum standard of purity and then rachet down the amount of genetic contamination.
  
  The continued inclusion of excluded methods terminology on the NOSB work agenda is important as genetic technologies develop quickly, and the NOSB must continuously monitor them on behalf of the organic community. Technologies used to manipulate the genetic code in a manner that is outside traditional plant and animal breeding should remain prohibited in organic production. Transposons should be listed as an excluded method. Transposons are mobile genetic elements that have been used to genetically engineer plants and animals and meet the criteria for excluded methods.

Other Issues

• Contminated inputs, including fracking water 
  
• Beyond Pesticides' comments
• Submit your own comments here
• Background: It is important for the NOSB to maintain a focus on the problem of contaminated inputs, which threatens the quality of organic products and soil on organic farms. However, the NOSB last addressed the issue in a report in Spring 2015. The report offered an approach for addressing this complex issue through examining feedstocks and pathways. The approach in that report is valid. In the intervening three years, the NOSB has not made progress, but another source of contamination has risen in importance –use of water contaminated by oil and gas production.
  
• Marine Materials (marine algae and extracts) on the National List
  
  • Beyond Pesticides' comments
  • Submit your own comments here
  • Background:The conservation of marine materials used in organic production affects materials used in crop production, livestock production, and handling. The excellent discussion document produced by the Materials Subcommittee (MS) outlines a coordinated approach that will ensure a consistent policy. The proposal to apply organic standards for cultivation or wildcrafting to all uses of marine algae in organic production and products should be adopted (and applied to marine animals as well), but marine plants and animals should not be certified as organic because of the uncertainties created by ocean circulation.
• Sanitizers
  
• Beyond Pesticides' comments
• Submit your own comments here
• Background: OFPA requires that all cleansers, sanitizers, and disinfectants used in organic production be itemized on the National List by specific use or application. NOP guidance and the practice of certifiers and inspectors has been inconsistent.  The inadequacy of the National List with regard to cleansers has led to an acceptance of the practice of using any available cleanser (sometimes antimicrobial) with intervening steps deemed by the producer/processor, certifier, and inspector to be “sufficient” to prevent contamination of organic product. Bringing practice into compliance with OFPA requires that the National List be evaluated for sufficiency and that cleansers be added to the National List. The inconsistencies among OFPA and regulations, guidance documents, and practice support the need for a comprehensive review of sanitizers, disinfectants, and cleansers that will lead to a clarified National List that meets OFPA criteria and the needs of organic producers.
  
  A comprehensive review of sanitizers, disinfectants, and cleansers used in organic production is needed. It should start with the questions: For what purposes are sanitizers needed? Are specific (e.g., chlorine-based) sanitizers required by law?

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Policy Development

• Transparency, open docket, subcommittee notes
• Beyond Pesticides' Comments
  
• Submit your own comments here
• Background: The organic sector is exceptional in its dedication to transparency and public involvement. Organic stakeholders have insisted on a regulatory system that is transparent and welcomes public involvement at every stage. It is essential that subcommittee minutes record motions, votes, and the stated justification for them for both the public and the full NOSB. NOP should also implement the open docket in a way that encourages NOSB members and subcommittees to solicit information on specific issues from the public between official comment periods.
  
  

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