Spring 2018 NOSB Meeting

• Click here to see Beyond Pesticides' comments
• Submit your own comment here

• Background: A comprehensive review of sanitizers, disinfectants, and cleansers used in organic production is needed. It should start with the questions:
  

  1. For what purposes are sanitizers needed?
  2. Are specific (e.g., chlorine-based) sanitizers required by law?
  • 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 and often violates OFPA.
  • 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 considered 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.
    
    

Marine Materials

• Beyond Pesticides' comments
  
• Submit your own comment here
• Background: Marine biodiversity is important, and the roles played by marine algae (seaweed) are important to marine biodiversity and ecology. Human threats to marine environments include overfishing, global warming, biological introductions, and pollution. The NOSB should continue its efforts to clarify the identities of species of marine algae used in organic production as well as to develop guidance for the application of the wildcrafting standard to marine algae.  Application of Latin binomials to seaweeds needs to be clarified, and any restrictions need to be justified.  The NOSB must investigate mechanisms for protecting marine ecology from the impacts of over-harvesting marine algae for use in organic products and production.  It must also look at natural materials in use in crops and livestock as well as those on the National List.  Lastly, the NOSB must protect rockweed (Ascophyllum nodosum) to the extent possible and specifically list it as a prohibited natural.  Seaweeds (marine algae) and products made from them should be allowed as ingredients in organic food, feed to organic livestock, and crop inputs only “when harvested from a designated area that has had no prohibited substance applied to it for a period of 3 years immediately preceding harvest and when harvested in a manner that ensures that such harvesting or gathering will not be destructive to the environment and will sustain the growth and production of the population of the species.” Marine animals used as fertilizers should be similarly protected.

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• Addressing Fraud in Organic

  •  Beyond Pesticides' comments
  •  Submit your own comment here
  • Background:  The fraud problem goes beyond imports. It is a problem whenever someone portrays as organic a product that does not meet the standards. Fraud hurts all sectors of the organic community –especially organic producers who follow the letter and spirit of the law and the consumers who depend on the market to provide organic food that meets organic standards. Fraud is 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.
    The topic of inspector qualifications and training, listed separately on the NOSB agenda, is an integral part of fraud prevention. Regulations must be clear, so that they can be enforced. NOP must have a will to enforce, whether the violator is large or small, foreign or domestic. The task facing the NOSB and NOP is to craft a multi-faceted strategy to prevent organic fraud.
• Eliminating the incentives to convert native ecosystems to organic cropland
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: Unfortunately, the legal requirement to avoid the use of prohibited substances for three years before land can be certified organic produces an unintended incentive to convert important native habitat to organic farms. The NOSB should pass this proposal, which has gone through several rounds of public discussion, followed by improvements, and will protect native lands. The details of how certifiers build it into organic system plans should be worked out in guidance in cooperation with the Wild Farm Alliance and experienced certifiers.  
• Inspector qualifications
  • Beyond Pesticides' comments
    
  • Submit your own comment here
  • Background: Qualified inspectors are important to ensuring organic integrity. We agree with the CACS that inspector qualifications include knowledge and skills that can be acquired through both training and experience. We agree that ongoing evaluation is needed. However, we disagree with the CACS recommendation that NOP should develop guidelines. NOP has encouraged or permitted the certification of practices that are incompatible with organic principles –including hydroponic production, dairy facilities with inadequate (if any) access to pasture, and poultry operations without outdoor access. USDA has withdrawn the Organic Livestock and Poultry Practices rule. With such a record, the department should not be given the responsibility for developing the guidance for inspectors who will be the judge of whether operations are meeting organic standards. Instead, the NOSB should develop guidelines for ensuring that inspectors have adequate training and experience. These guidelines should include guidance for determining when production is in the soil, in the ground, when dairy has adequate pasture, and when poultry has adequate outdoor access.
    

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Petitions

• Polyoxin D Zinc salt
• Beyond Pesticides' comments
  
• Submit your own comment here
• Background: The NOSB should reject the petition for polyoxin D zinc salt (PDZ) as a fungicide. PDZ does not meet any of the OFPA criteria—for environmental and health impacts, compatibility with organic systems, or essentiality. PDZ causes nontarget effects on beneficial organisms in the organic system, moderate toxicity to aquatic organisms, and chromosomal aberrations test animals.
  
• Natamycin
• Beyond Pesticides' comments
• Submit your own comment here
• Background: The NOSB should not allow the use of natamycin in organic production. Its classification as nonsynthetic cannot be supported with the available information, and when judged against the criteria for allowing synthetic substances, it fails to meet the criteria for no hazards to human health and the environment, essentiality, and compatibility with organic practices. Natamycin has been shown to provoke antimicrobial resistance in human pathogens and affects soil fungi.
  
• Sulfur (as a molluscicide)
  
• Beyond Pesticides' comments
  
• Submit your own comment here
• Background: The technical documentation for this petition does not support listing in crops. It does not address crucial issues associated with crop use. In view of this documentation and additional documentation we have found, the NOSB should reject the listing of sulfur as a molluscicide.
  

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.
• See Sanitizers under Cross-Cutting Issues
• 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 modify the listing for plastic mulch to limit its use to those cases in which organic mulches or cover crops cannot perform the necessary function. This annotation is necessary to ensure that OFPA criteria are met.
• 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

• "Inert" ingredients
  
• 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.
• Prohibition of  NPEs in "inerts"
  
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: The NOSB should not delay in evaluating nonylphenol (NP) and nonylphenol ethoxylates (NPEs).  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.  Organic producers should be leading the way in environmental protection and regeneration.  The use of toxic and endocrine-disrupting materials like NPEs is clearly inconsistent with The Principles of Organic Production and Handling.  EPA has identified alternatives to NPEs, and it is time for the NOSB and National Organic Program to banish these harmful substances.
    
    
• Container and greenhouse production
  
  • Beyond Pesticides' comments
  • Submit your own comment 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.
    
    
• Strengthen and clarify the requirements for use of organic seed (NOP 5029)
• 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

• Silver dihydrogen citrate
• Beyond Pesticides' comments
  
• Background: Silver dihydrogen citrate is nanosilver. The NOSB voted in 2010 to exclude engineered nanomaterials from organic production and handling. The petition should be denied because of the toxicity of the material to a wide range of organisms and its incompatibility with organic production.
  

• Sodium dodecylbenzene sulfonate (SDBS)
• Beyond Pesticides' comments
• Submit your own comment here
• Background: SDBS is used as one of the active ingredients in a formulated product used as an antimicrobial processing aid in produce wash waters. The intended function of the product itself is to reduce the number of microorganisms in fruit and vegetable process water and on the surface of the fruit or vegetable. SDBS rates a green circle (verified to be of low concern based on experimental and modeled data) on EPA’s Safer Chemical Ingredient List, and as such, is a material that the NOSB should consider in its quest to eliminate chlorine. However, that consideration should take place in the context of a comprehensive review of sanitizers, so SDBS should not be listed at this time. The technical review (TR) of SDBS is a good step in the direction of the comprehensive review of sanitizers, disinfectants, and cleaners that we propose.

Sunset

• Calcium carbonate
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Calcium carbonate is a natural substance that should be allowed for its use as a calcium source in soy based cheese alternative, to provide a similar calcium level for nutritional purposes. Alternatives are not more natural and may change the flavor of the soy based cheese alternative. It is also used as gelling agent in soy yogurt and a pH buffer.
• Flavors
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: At its Fall 2015 meeting, the NOSB voted to change the annotation to: “Flavors, non-synthetic flavors may be used when organic flavors are not commercially available. All flavors must be derived from organic or nonsynthetic sources only, and must not be produced using synthetic solvents and carrier systems or any artificial preservative.” The changed annotation has been included in proposed rulemaking by NOP. Flavors should be relisted with the new annotation.
• Gellan Gum
• Beyond Pesticides' comments
• Submit your own comment here
• Background: The petitioner of gellan gum claimed as CBI sections of the petition relating to amounts of the material used in products and the entire section on “sources and detailed description of manufacturing procedures.” Since then, the NOSB adopted a policy that Confidential Business Information (CBI) claims will no longer be accepted in petitions. This policy places new materials petitions at a disadvantage in having to disclose information not disclosed by previous petitioners. In the interest of fairness, therefore, materials should not be relisted during the sunset process unless the CBI claimed in the original petition is disclosed. This data should be disclosed, and it should be disclosed in a manner that allows public comment on it to be considered “timely.” The sunset date should be replaced by an expiration date. The expiration date would require that gellan gum be delisted on the sunset date unless it is repetitioned and relisted. This will allow new information –and in particular, that which had claimed to be CBI— to be considered in a meaningful fashion.

• Oxygen
• Beyond Pesticides' comments
• Submit your own comment here
• Background: In the fall of 2015, only one commenter expressed an interest in keeping oxygen on the National List. Despite the lack of harm posed by oxygen, it is a material otherwise prohibited, requiring an exemption for use in organic production. As such, its essentiality must be documented. Unless it is essential, it should not be relisted.
• Potassium chloride
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Potassium chloride should be relisted for its functions as a salt replacer, which is important reduced sodium products, including cheese and cheese and dairy based powders.
• Alginates
• Beyond Pesticides' comment
• Submit your own comment here
• Background: Alginates are synthetic derivatives of brown seaweeds. The listing of alginates should specify the seaweeds used and ensure that their harvest does not disturb the marine ecology. One way to do this would be to require that the seaweeds be organically produced –either through cultivation or wildharvest. Alginates are extracted through a method that causes chemical changes. Brown algae concentrate heavy metals and radioactivity, so those contaminants will be present either in the finished product, the waste stream, or both. The use of alginates is to create textures, and is therefore incompatible with organic regulations.
  
  Alginates should be removed from the National List unless they have allowed uses for which they are essential and can be shown not disturb the marine ecology in their production.
• Calcium hydroxide
  
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Calcium hydroxide is used as a pH buffer and as the alkaline substance in aluminum-free baking powder. It is also used to fortify foods with calcium, clarify sugar cane or beet juice, for making hominy and masa, as a firming agent, in the production of organic corn starch, and to remove impurities from solutions. Some uses may not be compatible with organic practices. 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 for postharvest ripening of tropical fruit and degreening of citrus because it is incompatible with organic agriculture. It is used as a synthetic growth regulator (ripening agent). It is 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 segment of the agricultural community that benefits from this chemical. Moreover, it is a synthetic chemical and a dangerous chemical for its users.

• Magnesium stearate
• Beyond Pesticides' comments
• Submit your own comment here
• Background: The evaluation of magnesium stearate must take into consideration the use of pesticides/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.        

• 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. The NOSB should seek safer alternatives.

• Potassium carbonate
• Beyond Pesticides' comments
• Submit your own comment here 
• Background: Potassium carbonate appears to be a hazardous substance that has many uses.  But the HS has not analyzed its essentiality for those uses. The HS and NOSB should consider the question of for which uses potassium carbonate is essential.

• 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. Xanthan is the product of fermentation that uses a plant pathogenic organism. The fermentation medium is a complex chemical mixture, and the recovery of xanthan gum from the fermentation broth is a difficult and expensive process that depends on a number of synthetic solvents.

• Fructooligosaccharides (FOS)
  • Beyond Pesticides' comment
  • Submit your own comment here
  • Background: Beyond Pesticide supports removing FOS from the list of nonorganic agricultural products allowed in organic processed food because it is not an agricultural product. Specifics of past analysis supporting the agricultural classification have not been shared with the NOSB as a whole or the public.
• 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 wildcrafted organic) can be taken into account for those that are produced organically or wildcrafted.
• Lecithin - de-oiled
  • Beyond Pesticides' comment
  • Submit your own comment here
  • Background: De-oiled lecithin should not be relisted because of the hazards associated with its production (chemical-intensive soy 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, including occasional severe allergic reactions. The HS has not investigated the impacts of nonorganic production of tragacanth gum on consumers, workers, or the environment.

Other Issues

•  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.
  
• Nutrient Vitamins and Minerals -annotation change
  
  • Beyond Pesticides' comments
  • Submit your own comment here
    

  • Background: After producing a discussion document with different options for public comment in Spring 2016, the Handling Subcommittee (HS) has apparently let drop the issue of changing the annotation for nutrient vitamins and minerals. As stated by the HS, “It has been acknowledged that it [the annotation] needs to change since the Federal Rule first came out.” This issue needs to be a priority.

• Reclassification of Magnesium chloride
  • Beyond Pesticides' comments
  • Submit your own comment here
    

  • Background: Magnesium chloride is available in nonsynthetic form, so it should no longer be allowed as a synthetic and should be listed as an allowed nonsynthetic.

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  Petitions

• Glycolic Acid
  • Beyond Pesticides' comment
  • Submit your own comment here
  • Background: The petition for glycolic acid teat dips should be denied because it poses environmental and health hazards, is not essential, and is incompatible with organic production. Glycolic acid is incompatible with organic production for several reasons –it is a synthetic designed to be used preventively, it contains “inert” ingredients not permitted in organic production, and there are no tolerances or exemptions from tolerance that would permit it to be used as petitioned. While the NOSB should seek alternatives to iodine- and chlorine-based teat dips, there is no indication that glycolic acid would substitute for them.

Sunset

• Alcohols: Ethanol, Isopropanol
  • Beyond Pesticides' comment
  • 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.

• Aspirin
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Aspirin should be relisted because of its importance in treating pain and inflammation. It has a wide safety margin with low risk of side effects.
• Biologics, Vaccines
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Vaccines should be relisted because of their importance in disease prevention. No vaccines based on genetically engineered organisms have been or should be approved.
• Electrolytes
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Electrolytes should remain on the list in order to provide support to the animals in times of illness.
• Glycerine
• Beyond Pesticides' comments
• Submit your own comment here
• Background: Glycerin should be relisted. However, the Materials Subcommittee give more attention to the classification and acceptability of materials, such as glycerine, that are made by fermentation.
• 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. However, there may not be a more compatible substance currently available. The NOSB should look for alternatives, and consider those rated by EPA’s Safer Choice Program.
• Lime, hydrated
  • 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.
• Mineral oil
  • 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.
• Sucrose octanoate esters (SOEs)
  • Beyond Pesticides' comments
  • Submit your own comment here
  • Background: PSOEs were originally petitioned as a control for varroa mites on honey bees –and that remains the only supported livestock use. The LS should seek input from beekeepers. The generic annotation “in accordance with approved labeling,” which always applies, should be replaced with one that describes the use –such as “for control of varroa mites in honeybees.”
    In view of the restrictive use of SOEs, they should remain on the National List.”

Other Issues

• Defining emergency treatment for parasiticides
  
• Beyond Pesticides Comments
  
• Submit your own comment here
  
• Background: When the NOSB drastically reduced the period between emergency treatment with parasiticides and sale of milk from treated animals, it increased the importance of defining “emergency” for such treatments. The NOSB should approve the subcommittee’s proposed definition and the proposed addition to §205.238 (b) that defines the context in terms of the farm’s Organic System Plan.
  

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• Non-GMO Organic Seed Integrity (Seed Purity from GMOs)
  
  • Beyond Pesticides' comments
  • Submit your own comment here
    
  • Background:The issue of protecting the genetic integrity of seed grown on organic land is related to two others that are not on the agenda –excluded methods terminology and strengthening and clarifying the requirements for the use of organic seed. Addressing these two other issues adequately would help to ensure that the presence of plants growing from genetically engineered (GE) seeds is greatly reduced on organic farms. The issue of protecting the genetic integrity of seed grown on organic land is concerned with those instances when organic producers plant nonorganic seed, so any efforts to strengthen the requirements for organic seed would tend to eliminate the problem. Efforts to quantify the extent of GE contamination and provide transparency in GE content of non-organic seeds should not further burden organic growers.
• Excluded Methods Terminology
  
  • Beyond Pesticides' comments
  • Submit your own comment here
    
  • Background:Excluded methods terminology should be maintained on the NOSB agenda to keep up with a fast-moving biotechnology industry.
• Contamination of Farm Imputs
  
• Beyond Pesticides' comments
• Submit your own comment 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. We support the approach in that report. 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.
  
• Sanitizers
  
• Beyond Pesticides' comments
• Submit your own comment here.
• Background: A comprehensive review of sanitizers, disinfectants, and cleansers used in organic production is needed. It should start with the questions:
  
  1. For what purposes are sanitizers needed?
  2. Are specific (e.g., chlorine-based) sanitizers required by law?
  • 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 and often violates OFPA.
  • 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 considered 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.
• See also Sanitizers under Cross Cutting Issues

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  The Policy Development Subcommitte has not meet since the Fall 2017 NOSB meeting.

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