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Fall 2024 NOSB Meeting

National Organic Standards Board

Fall 2024 NOSB Meeting
Comment by 11:59 pm EDT, Monday, September 30, 2024!

The NOSB Fall Meeting 2024 will be held in person from Tuesday, October 22, through Thursday, October 24, in Portland, OR. Links to listen in to the virtual comment webinars and the public meeting will posted on this webpage one week before the meetings in October.

From the very beginning, with the passage of the Organic Foods Production Act in 1990, “organic” has meant “continuous improvement.” The primary mechanism for continuous improvement in organic production is the high level of public involvement that comes from twice-annual meetings of the stakeholder board.

The second mechanism is the sunset process, which helps move synthetic substances out of organic production as the market invests in growing organic inputs and ingredients. Despite USDA’s efforts to weaken the sunset process, the 5-year cycle of review of every synthetic substance currently used in organic production and processing offers us an opportunity to keep organic strong and strengthen any weaknesses.

For a more detailed analysis of all upcoming issues, please scroll down to the Table of Contents description and links. For a quick copy and paste, use the text below to comment at Regulations.gov.

Priority Issues

Due to updates to the Regulations.gov website, our team is now able to offer "click and submit" forms that prepopulate our comments on the following priority issues!
 >> Click to submit on the following three issues—we encourage you to add a sentence or two at the beginning of the comments explaining why organic is important to you!
Inert ingredients used in organic production.
USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA. The Materials Subcommittee has proposed two options for addressing this problem.
The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling.The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food.
Beyond Pesticides' comments
Submit your own comment here 
Beyond Pesticides Report: Inert Ingredients Used In Organic Production
Compost Regulations The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. Beyond Pesticides supports the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a ‘de minimis ‘ doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.”. 

Beyond Pesticides' comments
Submit your own comment here 

Meloxicam in organic livestock.  The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes it be listed without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.” Beyond Pesticides opposes the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.

Beyond Pesticides' comments
Submit your own comment here

>> Click to submit on the following three issues—we encourage you to add a sentence or two at the beginning of the comments explaining why organic is important to you!

Make elimination of plastic in organic a research priority.
Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling. 

Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products.
Beyond Pesticides' comments
Submit your own comment here

 

 

Eliminate nonorganic ingredients in processed organic foods as a part of NOSB's sunset review. 
Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” Materials on §205.606 up for sunset review this year made from agricultural products that can be supplied organically should be taken off the National List of allowed materials. 

The majority of the Handling Subcommittee voted to remove dried orange pulp from §205.606 because organic dried orange pulp is now available. This should be supported.
Beyond Pesticides' comments
Submit your own comment here

 

 

All segments of organic production and regulation should cooperate in ensuring that organic products are produced using organic seed and starts.
Processors should not require organic growers to produce varieties if the seeds or starts for those varieties are not available organically. Processors who sell products with the organic seal benefit from certification and should share the responsibility for continuous improvement.

Organic cotton growers find it very difficult to source organic seed due to the small size of the industry. Most growers must use conventional, untreated, non-GMO seed. Given current seed regulations, the delinting process used on conventional seeds (sulfuric acid) is allowed since the seeds themselves are untreated and non-GMO. Also, due to the consolidation of seed companies, organic growers have an increasingly hard time finding their desired varieties that have been available in the past. The push for genetically modified cotton varieties has also made seed sourcing for organic growers even more difficult. The NOSB and NOP should make the availability of organic seed a priority.
Beyond Pesticides' comments
Submit your own comment here

 

  

 

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Fall 2024 NOSB Meeting

The Fall 2024 NOSB meeting dates have been announced and public comments are due by September 30, 2024, at 11:59 pm EDT. Your comments and participation are critical to the integrity of the organic label.

Where: The meeting will be held in person in Portland, OR and online meeting access information will be available here approximately one week before the webinars in October.

When: Tuesday, October 22, Wednesday, October 23, and Thursday, October 24, 2024.

Written comments may be submitted through Regulations.gov until 11:59 pm EDT Monday, September 30, 2024. Reservations for oral webinar comments can be made here. Keep in mind they fill up fast and the deadline is also by 11:59 pm EDT September 30, 2024. The online webinar for comments will take place on Tuesday, October 15, and Thursday, October 17.

The proposals of the National Organic Standards Board (NOSB), as a part of its ongoing review of practices and materials, are published for public comment. The public comment period will end on September 30, 2024. On this page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board on our website pages. You can view USDA's announcement of the NOSB's meeting and proposals here. Please see Beyond Pesticides' analysis below (and more coming soon).

Issues Before the NOSB for Fall 2024

Materials in the list below are either the subject of petitions or the subject of sunset review. Petitioned materials must have evidence summarized in the proposals that they meet the OFPA requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices. Sunset items are already on the National List, and being considered for delisting. They are subject to the same criteria, but are being considered under NOP's new rules.

The NOSB will vote on materials subject to sunset review at the Fall 2023 meeting.

To truly make an impact in the future of organic, Beyond Pesticides encourages you to:

Compliance, Accreditation, and Certification Subcommittee

Crops Subcommittee

Handling Subcommittee

Livestock Subcommittee

Materials Subcommittee

 

Draft Meeting Agenda

 

 

Take Action at Regulations.gov!
(Comments Due September 30th, 2024!)

 

See All Comments So Far

 

See Beyond Pesticides' Commenting Guidelines

 

See All Meeting Materials and Issues

 

The Organic Foods Production Act

 

 

Proposals

  • 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.
 
Discussion

  • Residue Testing for a Global Supply Chain

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Residue testing is an essential tool for ensuring compliance with organic regulations. Preharvest residue testing can support evaluating an organic producer’s efforts to prevent contamination, provide objective data when prohibited substance use is suspected, and monitor unavoidable residual environmental contamination levels. Postharvest residue testing can support the evaluation of contamination prevention in postharvest handling activities and across supply chains and provide objective data when prohibited substance use or when commingling or substituting conventional products is suspected. Residue testing does not substitute for the certification process and verification of compliance through an organic system plan review and annual inspection. However, it can support this process with objective results related to the presence of prohibited substances or the use of excluded methods. 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.

  • Risk-Based Certification

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Risk-based oversight as a model for decision-making and compliance prevention strategy is an approach used by certified operations and certifiers in organic certification. As the organic supply chain and businesses engaged in the organic industry get more complex, organic certification is becoming less “one size fits all”. It is becoming more important for organizations to use a risk-based approach in order to optimize their activities (i.e. focus their attention on the areas of highest risk to their organization). Certified operations and certifiers can both apply risk-based oversight to themselves and their activities; or as an evaluation process to determine the risk of another organization they do business with. This could be a certified operation evaluating a supplier or a certifier evaluating one of their certified operations.

  • Consistency in Organic Seed Use Discussion Document

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: The Certification, Accreditation, Compliance Subcommittee (CACS) seeks to understand the current state of organic seed use, potential tools for increasing the amount and variety of organic seed that is commercially available, and methods for strengthening enforcement of the existing commercial availability requirements.
      Organic producers are generally required to use organically grown seeds (7 USC § 6508(a); 7 CFR §
      205.204). Nonorganically produced, untreated seeds may only be used “when an equivalent organically produced variety is not commercially available” (7 CFR § 205.204(a)(1)). In August 2005 and November 2008, the NOSB made recommendations on implementation of the commercial availability requirement, and in 2013, the NOP issued Guidance 5029, which outlines procedures for verifying compliance with the commercial availability requirement. The relevant statutory, regulatory, and guidance text is attached as Appendix A. The NOSB made additional recommendations for rulemaking and strengthening Guidance 5029 in 2018 and 2019, respectively. The 2018 and 2019 recommendations are summarized in Appendix B.

Return To Table Of Contents

 
Proposals

  • Carbon Dioxide - petition

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Carbon dioxide is currently allowed for use as an ingredient in organic labeled processed food products: §205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).” (b) Synthetic allowed: - Carbon dioxide. This original petition requested the allowance of carbon dioxide in organic crop production. The same petition requested the addition of
      carbon dioxide at §205.601(a) of the National List for use as an algicide, disinfectant, and sanitizer, including uses in irrigation systems, to acidify irrigation water. Because there was a lack of information in the petition about the importance or need for the substance to be listed as a crop or soil amendment, the Subcommittee has been hesitant to recommend its listing.        

  • Compost Production for Organic Agriculture

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: The NOSB should adopt the proposal of the Crops Subcommittee (CS) to maintain control over synthetic substances used in organic crop production and continue a definition of compost based on plant and animal materials. A petition had sought to change the definition to allow “compost feedstocks” that could allow organic farming to serve as a waste disposal system for synthetics like “compostable” tableware. Beyond Pesticides supports the conclusions of the CS, including: “NOP regulations are working, and there is room for improvement, but defining compost feedstocks to include synthetic substances not on the National List or referring to a ‘de minimis ‘ doctrine that has not been established in our definitions or regulations. Bypassing the NOSB process is a dangerous implementation of new procedures that circumvents our unique version of American democracy.”
Discussion

  • Pear Ester – petition

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Pear ester is a chemical (Ethyl-2E,4Z-Decadienoate) synthesized to be structurally and
      functionally identical to a volatile substance emitted by mature and ripening pears and other fruits. It is attractive to codling moths and is used in various ways to control them. Pear ester is described as a “kairomone,” which is defined as “a chemical that is pertinent to the biology of an organism (organism 1) and that when it contacts an individual of another species (Organism 2) evokes in the receiver a behavioural or physiological response that is adaptively favourable to organism 2 but not to organism 1.  Our comments address both pear ester per se and delivery mechanisms. The Crops Subcommittee (CS) states, “Pear ester was previously allowed for use in organic crop production under the synthetic pheromone classification until its correct reclassification as a kairomone.” The petitioner would like pear ester to be added to the National List as a pheromone.

Sunset

Soaps, ammonium

      • Beyond Pesticides' comments
      • Submit your own comment here
      • Background: Ammonium soaps should be allowed to sunset because they do not meet any of the three OFPA criteria of absence of harm to humans and the environment, essentiality, and compatibility with organic practices. Drift from spraying ammonium soaps may damage plants and kill aquatic insects. Alternative materials include area repellents, including tankage (putrified meat scraps), bone tar oil, blood meal, human hair, and bar soap –which should be applied close to or on the plants needing protection– and contact repellents that work by taste and are applied directly to plants, including putrescent egg solids and hot pepper sauce. Other methods include habitat modification, hunting, shooting, fencing/exclusion, encouraging predators.

Oils, horticultural

      • Beyond Pesticides' comments
      • Submit your own comment here
      • Background: The listing for horticultural oils should be annotated in a way that protects workers from inhalation hazards, and nontarget arthropods from harm. If this is not possible, horticultural oils should be delisted. We suggest this annotation: “Steps to meet worker protection standards must be documented in the Organic System Plan. Must not be used when predators, parasitoids, or pollinators are present.”

Pheromones

      • Beyond Pesticides' comments
      • Submit your own comment here
      • Background: We support the following listing for pheromone products, which we believe captures the sense of the conditions for exempting pheromone products from regulation: §205.601(f) As insect management. Pheromones, provided that they are identical to or substantially similar to natural pheromones as defined in 40 CFR 152.25(b), in passive dispensers, without added toxicants, and with only approved inert ingredients.
        Despite the lack of specificity, pheromone products have permitted growers to avoid the use of more toxic controls. They can be used in a way that complements alternative methods suggested by the technical review: biological controls, traps, repellents, soil management, sanitation, other cultural practices, physical barriers, hand removal.

Ferric phosphate

      • Beyond Pesticides’ comments
      • Submit your own comment here
      • Background: Ferric phosphate should be allowed to sunset because ferric phosphate alone is ineffective, therefore not essential, and ferric phosphate in combination with EDTA (ethylenediaminetetraacetic acid) poses risks to soil organisms, uses highly toxic materials in manufacture, and is not compatible with organic agriculture.

Potassium bicarbonate

      • Beyond Pesticides’ comments
      • Submit your own comment here
      • Background: Potassium bicarbonate should be removed from the list because it does not fit into any of the categories of allowable synthetics in §6517(c)(1)(B)(i) of OFPA, which is limited to: copper and sulfur compounds; toxins derived from bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and minerals; livestock parasiticides and medicines and production aids.

Magnesium sulfate

      • Beyond Pesticides’ comments
      • Submit your own comment here
      • Background: 
      • Magnesium sulfate is acceptable only under limited conditions. Synthetic plant nutrients should not be taking the place of organic soil-building practices. Synthetic magnesium sulfate is a synthetic plant nutrient, and hence its use as a foliar spray is contrary to the organic philosophy of feeding the soil to feed the plants. Magnesium should be abundant in biologically active soils, so organic soil-building practices should be used to enrich soils with magnesium.

Hydrogen chloride

      • Beyond Pesticides' Comments
      • Submit your own comment here
      • Background: Hydrogen chloride should be relisted due to the lack of alternatives of organic cotton growers. However, in view of the extreme hazard posed by gaseous hydrogen chloride, NOSB should call for support for research and development of alternative methods of delinting cotton seed in preparation for planting.

Ash from manure burning

      • Beyond Pesticides' Comments
      • Submit your own comment here
      • Background: Ash from manure burning should remain on §602, nonsynthetic substances prohibited for use in organic crop production. Burning a material that is central to maintaining soil fertility and tilth in organic soils would be incompatible with organic production systems.

Sodium fluoaluminate (mined)

      • Beyond Pesticides' Comments
      • Submit your own comment here
      • Background: Sodium fluoaluminate (cryolite) should remain on §602, nonsynthetic substances prohibited for use in organic crop production. Cryolite is harmful to human health and the environment. It is a nonselective pesticide, and there are alternative materials and management practices.
  •  

Return To Table Of Contents

Proposals

  • Potassium Phosphate – petitioned

    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Potassium phosphate is currently allowed on the National List of Allowed and Prohibited Substances (the National List) portion of the USDA organic regulations in 7 CFR 205.605(b)(28) with the following annotation: For use only in agricultural products labeled “made with organic (specific ingredients or food group(s)),” prohibited in agricultural products labeled “organic.” The petitioner asks: (1) to remove the restriction that potassium phosphate can only be used in products labeled ‘made with organic ingredients’ and (2) to change “potassium phosphate” to “potassium phosphates,” which would allow new types of potassium phosphate (e.g., diphosphates and triphosphates) in organic food products.

  • L-Malic Acid Reclassification

    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: L-malic acid occurs naturally in many fruits and vegetables, including apples and cherries, and can be obtained by enzymatic conversion of fumaric acid and by fermentation of glucose and other carbohydrates. It is not economical to extract L-malic acid from natural foodstuffs such as apple juice. Beyond Pesticides opposes the relisting of L-malic acid. We conclude that there is not sufficient information to support the relisting of L-malic acid on §605(a). Information from the TR challenges the classification of L-malic acid as nonsynthetic and raises issues of compatibility. Ancillary substances have not been identified or assessed. Therefore, L-malic acid should not be relisted.
Discussion

  • Ethylene – petitioned

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: The Handling Subcommittee (HS) has ordered a limited scope technical review (TR) to evaluate any human health or environmental concerns related to the use of ethylene, specifically when used to inhibit sprouting of potatoes or onions. We anticipate receiving this TR in sufficient time to inform a proposal for the Spring 2025 meeting. The HS has also interviewed organic potato and onion growers to gauge interest in use of the substance. One organic potato grower indicated that the nonsynthetic sprout inhibitor currently allowed, clove oil, has limited effectiveness and can cause significant irritation to workers applying it. One organic onion grower expressed interest in the use of ethylene if it reduced the percentage of onions that must be culled when packing. As we await the technical review, we welcome any feedback from stakeholders on the use of ethylene as a sprout inhibitor in organic potatoes and onions. Ethylene has the potential to extend storage life and reduce culls in organic potatoes and onions. Should HS consider this substance any differently than it does for ripening tropical fruit because in the petitioned use it would be inhibiting growth rather than encouraging it? It appears that clove oil is currently in use to inhibit sprouting in organic potatoes, but it may be less effective and cause health risks for workers. How should HS consider petitioned synthetic substances which may pose less of a human health concern than natural alternatives? 3. If the HS recommends an annotation change to ethylene to permit its use as a sprout inhibitor, should HS consider any additional revisions to the annotation related to ripening of tropical fruit or degreening citrus for these allowed uses to be more clear? 
  •  

Sunset

2025 Sunsets 205.605 and 205.606

  • Acids - Citric
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Citric acid is widely used in food processing. It is used as an ingredient, acidulant, pH control agent, flavoring, and as a sequestrant. It is used as a dispersant in flavor or color additives. It is also an ingredient in dietary supplements and a nutrient, sequestrant, buffer, antioxidant, firming agent, acidity regulator (in jams and jellies, soft drinks and wines), raising agent, and emulsifying salt for many other products. It is also used to improve baking properties of flours, and as a stabilizer, and to inhibit color and flavor deterioration in fruits. Roughly 75% of all citric acid commercially produced is used by the food industry including baby food, breakfast cereals, frozen desserts, frozen entrees and certified organic personal care products. The remainder is used in cleaning agents, or in the cosmetics and pharmaceutical industries.
  • Acids - Lactic
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Lactic acid is widely used in almost every segment of the food industry, where it carries out a wide range of functions. The major use of lactic acid is in food and food-related applications, which in the U.S. accounts for approximately 85% of the demand. It is found naturally in milk, meat, and beer but is normally associated with sour milk. Lactic acid controls the growth of bacteria including listeria (NOSB Fall Meeting Transcript 2015 pp. 263). The other uses are non-food industrial applications. Lactic acid occurs naturally in many food products. It has been in use as an acidulant and pH regulator for many years. It regulates microflora in food and has been found to be very effective against certain types of microorganisms, giving it pronounced efficacy as a preservative (Vijayakumar, Aravindan and Viruthagiri 2008). Other uses include mixing with sodium, potassium, and distilled water to form intravenous fluids commonly used after blood loss. It is sometimes used in the pharmaceutical industry to adjust acidity. Lactic acid appears on the
      National List, 7 CFR Part 205.605(a), as a non-synthetic material without further annotation.
  • Calcium chloride
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: We consider the level of impurities in food grade calcium chloride – up to 6% – to be high for a food grade material. The presence of calcium bromide is troublesome. We recommend that the HS investigate this more closely.
  • Enzymes
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Enzymes are naturally occurring proteins that act as highly efficient catalysts in biochemical reactions. Enzymes are produced by all living organisms; however, the 2023 Limited Scope TR only focuses on enzymes produced by microorganisms (including fungi). In some cases, enzymes are produced by microorganisms that are developed using excluded methods, which was the focus of the 2023 Limited Scope TR. In the organic food industry, enzymes are used to carry out biological processes that are useful in the processing of food products or ingredients.
  • L-Malic Acid
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Malic acid exists in D-, L-, and racemic DL-forms, which is a mixture of equal parts of D- and L-. L-malic acid is the form listed at §205.605(a), while the D- and DL-forms are not approved for use in organic production. L-malic acid is used as a flavor enhancer, flavoring agent, adjuvant, and pH control agent in a variety of foods. The 2002 malic acid petition also notes it is used in dry mix beverages, carbonated beverages, bakery products, fruit juices, candies, gelatins, desserts, frozen specialties, and tea as a flavor enhancer and food acidulant, and that malic acid provides greater tartness and better taste retention than other major food acids. Malic acid has a smooth, persistent sourness and can be blended with other organic acids, sugars, sweeteners, and flavors. It also intensifies and extends the impact of flavors, allowing producers to reduce the amount of added flavoring. U.S. Food and Drug Administration (FDA) lists L-malic acid as a Generally Recognized as Safe (GRAS) food additive as a pH control agent, flavor enhancer, flavoring agent, and adjuvant in all food types except for baby food. The listing also includes maximum good manufacturing practice (GMP) levels for various applications (21 CFR 184.1069; U.S. FDA 2018).
  • Magnesium sulfate
  • Microorganisms
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Microorganisms are organisms that are so small they can only be viewed with a microscope, broadly encompassing bacteria, fungi, viruses and other single-celled organisms. The microorganisms used in organic handling include bacteria, yeasts and viruses, but yeasts are reviewed separately as their applications are broad. Microorganisms are used as probiotics, for fermentation, and bacteriophages are used for food safety. Microorganisms are used by organic processors to make many well-known products including yogurts, miso, soy sauce and sake. The use of these microorganisms can increase the digestibility of products, create different flavors and textures, and provide potential health benefits to the consumer. Additionally, bacteriophages can work to decrease harmful food organisms and increase the safety of processed foods.
  • Perlite
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Perlite is used as a filter aid in food processing, such as in the filtration of juices, beer, wine, and vegetable oils. Manufacture Perlite is an amorphous volcanic glass that occurs naturally and is sourced primarily from mines in the U.S., Greece, Turkey and China. The high-water content of the mineral causes it to expand many times its original volume when exposed to temperatures of 850-900°C. Perlite should be relisted because is an excellent filter aid and often substitutes for diatomaceous earth in filtering beer. The subcommittee received clear indication from a range of stakeholders that perlite continues to be necessary.
  • Potassium iodide
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Potassium iodide is used as a form of iodine in trace mineral supplements. Iodine is an essential component of the thyroid hormones that regulate basal metabolism. Iodine deficiency causes thyroid enlargement (goiter), Intellectual Disability that can be severe (cretinism in 10% of the population), and hypothyroidism. The developing brain is the most sensitive organ; iodine deficiency reduces IQ by 13.5 points [2011 TR 356- 359]. Iodization of salt eliminated new cases of cretinism in Switzerland.
  • Pullulan
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: According to the FDA Center for Drug Evaluation and Research (CDER), pullulan is a “product used for tablet coating, as an excipient to aid tableting processes, in the production of edible films, and as an alternative to gelatin in capsule production” (FDA 2014). The unique film-forming property of pullulan 74 enables the production of clear capsules and coatings for dietary supplements (Farris et al. 2014). [2018 TR 72-75] In addition to the petitioned use of pullulan as an ingredient in tablets and capsules for dietary supplements, edible pullulan films are used to extend the shelf life of various foods.
  • Yeast
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Yeast is widely used and has been for centuries. Yeast is a microorganism that is commonly used for fermentation, baking, food flavors, adding nutritional value and providing health benefits. Yeasts are inkingdom Fungi and are single celled eukaryotic organisms. They utilize organic materials for energy by releasing enzymes that digest organic matter or by absorbing simple molecules directly through their cell walls. Yeasts differ from other fungi, such as molds and mushrooms, in that they exist as individual cells rather than forming hyphae that interconnect with other cells.
  • Activated Charcoal
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Activated charcoal is used in processing for mechanical filtration involving the physical separation of suspended solids from a liquid passing through carbon arrayed as a porous media in a column or bed. This type of filtration is used as a taste and odor-removing agent and purification agent in water and food. Activated carbon has a very large surface area and pore volume that gives it its unique adsorption capacity. Activated charcoal should not be relisted as currently allowed. The use, as petitioned, to improve the color and flavor of grape juice, is not compatible with organic production and handling. The listing should limit its use to filtering water and require steam activation.
  • Ascorbic acid
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Ascorbic acid is used as a dietary supplement and nutrient, flavor ingredient, used in meat and meat containing products, curing and pickling, in flour to improve baking quality, as an antioxidant in fats and oils, and a wide variety of other food processing uses. It is also used in frozen and precut fruits as an antioxidant. Industrially produced L-ascorbic acid is widely used in the feed, food, and pharmaceutical sector as a nutritional supplement and preservative, making use of its antioxidative properties. Ascorbic acid is often added to processed foods for nutritional purposes and is one of the most common sources of Vitamin C, which provides many important biological functions. Several animals, including humans, a variety of primates and guinea pigs have lost the ability to produce ascorbic acid and must obtain this essential vitamin through their diets. As it is water soluble, and cannot be stored in the body, it must be consumed daily. However, its addition as a nutritional fortifier also provides preservative properties. The preservative nature of the compound is derived from its reducing nature, through which it reacts with oxidized species (including radicals and molecular oxygen) to prevent enzymatic browning and food spoilage. Ascorbic acid is GRAS as a chemical preservative (21 CFR 182.3013), a dietary supplement (21 CFR
      182.5013), and nutrient (21 CFR 182.8013) when used in accordance with Good Manufacturing Practices. The FDA has identified ascorbic acid as a required nutrient in infant formula (21 CFR 107.100).
  • Calcium citrate
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Calcium citrate is used as an ingredient in dietary supplements, where it provides calcium. It is also used as a nutrient; sequestrant; buffer; antioxidant; firming agent; acidity regulator in jams and jellies, soft drinks and wines; raising agent; an emulsifying salt; to improve the baking properties of flours; a stabilizer; to remove scale from boilers, evaporators and other processing equipment; to wash equipment to remove off flavors; in cosmetic and personal care items; and as a water softener.
  • Collagen Gel
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Collagen gel acts as an edible film used in meat products (e.g. sausage) as an alternative to casings, which is listed at §205.606(b). Collagen casings protect the meat product from oxidation and discoloration by acting as a semipermeable membrane for gases, moisture, and other solvents. The casing also provides a more desirable bite and texture to meat products as well as aids in additional flavorings to the product [2019 TR 282-284]. Collagen gel is a more affordable, efficient, and sanitary means of manufacturing meat products and increases opportunities to produce a larger variety of organic meat products [2019 TR 27-28]. It allows production of single-species products that can meet the needs and preferences of different consumer populations.
  • Ferrous Sulfate
  • Hydrogen Peroxide
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Hydrogen peroxide (CAS# 7722-84-1) is a very simple molecule with a formula of H2O2. It is a weak acid but also a strong oxidizer, which makes it an effective microbial pesticide for organic handling purposes. It is used as a disinfectant, sanitizer, and for post-harvest treatment of produce. USDA organic regulations currently allow the use of hydrogen peroxide in organic crop production under 7 CFR §205.601(a) as an algicide, disinfectant and sanitizer, and under 7 CFR 205.601(i) for plant disease control as a fungicide. Hydrogen peroxide is also permitted for use in organic livestock production as a disinfectant, sanitizer and medical treatment under 7 CFR 205.603(a). Lastly, synthetic hydrogen peroxide may be used as an ingredient in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s))” under 7 CFR 205.605 (b).
  • Nutrient vitamins and minerals
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: This listing allows nutrient vitamins and minerals to be added to organic food in accordance with 21 CFR 104.20, which is the U.S. Food and Drug Administration’s (FDA) fortification policy. That policy lays out principles intended to serve as a model for the rational addition of nutrients to food and promote a balanced and nutritious food supply, while avoiding over- or under- fortification of consumer diets. It outlines situations in which it may be appropriate to add nutrients to food, including certain situations where needed to correct a dietary insufficiency recognized by the scientific community to exist and known to result in nutritional deficiency; to restore nutrients lost in storage, handling, or processing; to avoid nutritional inferiority of a food that replaces a traditional food; as well as where required by regulation. It states that FDA does not encourage indiscriminate addition of nutrients to foods, nor does it consider it appropriate to fortify fresh produce; meat, poultry, or fish products; sugars; or snack foods such as candies or carbonated beverages. Manufacturers are urged to use these principles to design fortified foods. The 2015 TR breaks this umbrella listing into five categories: fat-soluble vitamins (Vitamins A, D, E, K, carotenoids), water-soluble vitamins (Vitamins C, B1, B2, B6, B12, niacin, folate, pantothenic acid, biotin, choline, inositol), trace mineral elements (chromium, copper, iodine, iron, manganese, molybdenum,
      selenium, zinc), major minerals in bone (calcium, phosphorus, magnesium, fluorine), and major electrolyte minerals (potassium, sodium, chloride).
  • Peracetic acid/Peroxyacetic acid
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Peracetic acid (CAS # 79-21-0) is currently allowed for use in organic handling in wash water and rinse water, including during post-harvest handling, to disinfect organically produced agricultural products according to FDA limitations, and to sanitize food contact surfaces, including dairy-processing equipment and food-processing equipment and utensils. It is an important sanitizer used in organic handling. It is widely used as a sanitizer on food contact surfaces and as a disinfectant for fruits and vegetables.
  • Potassium citrate
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Potassium and sodium citrate are used as ingredients where they function as acidulants, pH controls, flavoring agents, sequestrants, and buffering or emulsifying agents. Potassium citrate is used to replace sodium citrate whenever a low sodium content is desired. The three citrates (which include potassium citrate, sodium citrate, and calcium citrate) are also used as dispersants in flavor or color additives, and to wash processing equipment to remove off flavors. Potassium citrate is commonly used in biscuits, baby food, soup mixes, soft drinks, and fermented meat.
  • Potassium phosphate
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Potassium phosphate can be used as a pH control in milk and dairy products, to make acidified milk products and in milk protein stabilization. Potassium phosphate interacts with milk proteins, such as casein, to function as emulsifiers that prevent the separation of fat and water in cheese that stabilize milk and cheese by chelating (“sequestering”) calcium. [2016 TR, pgs. 4, 6]
      Potassium phosphate can also be used as a nutritional additive for a source of potassium and as a nutrient in yeast. It can also be used in prepared meat applications and liquid eggs. The 1995 Technical Advisory Panel report (TAP) included a recommendation to list this material as an approved synthetic in products labeled “organic,” but was only approved for use in “made with” products.
  • Sodium acid pyrophosphate
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: The 2010 Technical Report (TR) indicates that sodium acid pyrophosphate is used in conventional foods as a chemical leavening agent in baked goods; a sequestrant (chelating agent) to maintain the appearance of cooked and uncooked fruits and vegetables, particularly processed potatoes; an emulsifying agent and stabilizer in cheeses and related products; an inhibitor of struvite formation in canned tuna; and a curing accelerator in processed meat and poultry products [2010 TR 36-40]. The NOP regulations at 7 CFR 205.605(b) limit the use of sodium acid pyrophosphate in organic foods to use only as a leavening agent. Sodium acid pyrophosphate is used as a component of chemical leavening agents (“baking powder”). In some meat- and poultry-containing processed foods, sodium acid pyrophosphate is used to accelerate color fixing or to preserve color during storage of cured pork and beef cuts, cured poultry, and cured comminuted poultry and meat food products. However, in organic foods, sodium acid pyrophosphate is permitted solely for leavening, so this color-fixing use is not permitted.
  • Sodium citrate
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Potassium and sodium citrate are used as ingredients where they function as acidulants, pH controls, flavoring agents, sequestrants, and buffering or emulsifying agents. Potassium citrate is used to replace sodium citrate whenever a low sodium content is desired. These materials are also used as dispersants in flavor or color additives, and to wash processing equipment to remove off flavors. Sodium citrate is used as an emulsifier in dairy products to keep fats from separating, and in cheese making where it allows the cheeses to melt without becoming greasy. Sodium citrate is chiefly used as a food additive, usually for flavoring or as a preservative. Sodium citrate gives club soda both its sour and salty flavors. It is common in lemon-lime soft drinks, and it is partly what causes them to have their sour taste. Additionally, it is used in jams, jellies, meat products, baby foods, and milk powder.
  • Tocopherols
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Synthetic tocopherols are currently permitted for use in organic agriculture handling/processing as an antioxidant ingredient in foods (2015 TR). Tocopherols are added to foods to help prevent oxidation of the fatty acids present in the lipid components of the food. Tocopherols derived from vegetable oil are allowed for use as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group[s])” when rosemary extracts are not a suitable alternative (7 CFR 205.605[b]).
  • Celery powder
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Celery powder serves a dual purpose in the formulation of meat products. In addition to flavor, its primary function is as a natural source of nitrate which cures meat without relying on synthetic nitrates and nitrites and has been used in this application for millennia. There are other vegetables and minerals which contain natural nitrates including beets, spinach, and sea salt. Although each has its benefits and challenges, none is an ideal substitute for natural celery powder in quality, form, and function. In the organic sector, celery powder is used in a variety of processed meat products (hot dogs, bacon, ham, corned beef, pastrami, pepperoni, salami, etc.) to provide “cured” meat attributes without using prohibited nitrites.
  • Fish oil
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Fish oil is used in organic processing and handling as an ingredient to increase the content of omega-3 fatty acids—primarily, eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA)—in foods to benefit human health by contributing to healthy brain development and reducing risks of cardiovascular disease, diabetes, inflammation, atherosclerosis. Fish oil is used in a variety of food products, including breads, pies, cereals, yogurt, cheese products, frozen dairy products, meat products, cookies, crackers, snack foods, condiments, sauces, and soup mixes. [2015 TR 19-25] Fish oil is also used in aquaculture as a feed supplement for farmed fish (Naylor et al., 2001). The farmed fish are fed fish oil because their diets are typically deficient in plants and animals that lead to the inherent production of fish oil (Naylor et al., 2001). [2015 TR 148-150]
  • Gelatin
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Gelatin is used in a wide range of products as a clarification or fining agent in teas, juice, and wine, as a stabilizer, texturizer, thickener, and in capsules. It may either be an ingredient or a processing aid in candies (gummy bears), desserts (puddings, jello, marshmallows), dairy products (yogurt, sour cream, ice cream), cereals, and cosmetics. Fish gelatin is widely preferred for uses in kosher foods. Collagen, also on the National List, is the native form of gelatin and chemically the two are indistinguishable.
  • Orange pulp, dried
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Dried orange pulp is used as a moisture retention agent and fat substitute in baked goods, pastas, salad dressing, confectionary, processed cheese spreads, beverages, meat products and frozen foods. Dried orange pulp is used in rates up to 5 percent depending on use but is self-limiting after that point due to loss of desirable eating qualities.  The evaluation of dried orange pulp must take into consideration the use of pesticides in the non-organic production of oranges and the availability of organic oranges for this purpose, as well as the potential availability of the dried pulp if the demand existed. Beyond Pesticides opposes the relisting dried orange pulp, because of hazards to workers and the environment and lack of essentiality.
  • Seaweed, Pacific kombu
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Seaweed is used as food, in cosmetics and fertilizers, processed to extract thickening agents, and as an additive to animal feed (FAO, 2014). Increasing demand over the last fifty years outstripped the ability to supply the market from natural (wild) stocks. Cultivation industries now produce more than 90 percent of the markets’ demand. Some commercial organizations have been promoting seaweed for restaurant and domestic use, with some success. An informal market exists among coastal dwellers in some developing countries where there has been a tradition of using fresh seaweeds as vegetables and in salads (FAO, 2012). [2016 TR 193-195] Kombu, produced from hundreds of hectares of brown seaweed, Laminaria japonica that is grown on suspended ropes in the ocean.
  • Wakame seaweed (undaria pinnatifida)
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Seaweed is used as food, in cosmetics and fertilizers, processed to extract thickening agents, and as an additive to animal feed (FAO, 2014). As the world has internationalized, seaweed consumption as food including Wakame, has expanded from China, Japan, and Korea to the entire world. Farming seaweed on lines in the ocean has expanded globally for production of alginates, carrageenans, other chemicals and the edible seaweed varieties, as management of harvest of wild seaweed forests continues throughout the world. (Hunter, 1975). [2016 TR 379-383] Increasing demand over the last fifty years outstripped the ability to supply the market from natural (wild) stocks. Cultivation industries now produce more than 90 percent of the markets’ demand. Some commercial organizations have been promoting seaweed for restaurant and domestic use, with some success. [2016 TR 192-193]

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Proposals

  • Meloxicam in organic livestock

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: The Livestock Subcommittee (LS) has put forth a proposal to approve the use of the non-steroidal anti-inflammatory drug (NSAID) meloxicam for livestock. The LS proposes it be listed without the required identification of specific use or application, offering only the general limitation of “[u]se by or on the lawful written order of a licensed veterinarian; and [a] meat withdrawal period of at least two-times that required by the FDA.” Beyond Pesticides opposes the petition because the LS has not sought review through a technical review (TR), which has become a standard practice in material review by the NOSB. The LS relies solely on information provided by the petition and hence lacks complete and independent support.

  • Annotation Change - DL-methionine

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: Methionine is an essential sulfur-containing amino acid used in organic poultry rations. It was first allowed in organic poultry rations when its National List reference became effective on November 3, 2003. Since that time, methionine garnered scrutiny through NOSB reviews, petitions to amend annotations, and stakeholder comments. A full documentation of its NOSB and regulatory history can be found in the Petitioned Substances Index. Methionine is undergoing its five-year sunset review, and the Livestock Subcommittee (LS) is not recommending its removal, however, the LS is scrutinizing the current annotation and evaluating whether the impacts of this annotation on organic poultry flocks align with organic principles and the goals of encouraging natural alternatives.

  • Annotation Change – Iodine

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: The National Organic Standards Board (NOSB) acknowledges that iodine sanitizers remain necessary to livestock operations as a sanitizer for medical procedures as well as for topical use, particularly as a teat dip for dairy animals. The NOSB has also heard from numerous stakeholders that it is time to ensure that iodine products used on organic farms are free from nonylphenol ethoxylates (NPEs). The Livestock Subcommittee (LS) requested a limited scope technical report (TR) in 2024 to evaluate the availability of NPE-free iodine products and their suitability, the potential for NPEs contained in iodine products to contaminate organic products and the environment, and what detrimental effects may occur should NPEs enter the supply chain or be applied to soil.

 

Sunset

2026 Sunsets 205.603 &205.604

  • Atropine
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Atropine is a naturally occurring alkaloid (a nitrogen-containing molecule that is produced in plants and is physiologically active) produced by the plants in the nightshade family (EFSA 2008, Timberlake 2015). Atropine is primarily isolated from Atropa belladonna (also known as deadly nightshade) and is a component in both human and veterinary medicines for a range of treatments. Although, it is most widely used in both human and veterinary practices as a treatment for organophosphate poisoning. [2019 TR 35-39] Atropine is currently allowed by the United States Department of Agriculture (USDA) organic regulations as a medical treatment for organic livestock production (7 CFR 205.603(a)). USDA organic regulations restrict atropine to “use by or on the lawful written or oral order of a licensed veterinarian,” and it must be followed by “a meat withdrawal period of at least 56 days after administering to livestock intended for slaughter; and a milk discard period of at least 12 days after administering to dairy animals. [2019 TR 24-28]
  • Hydrogen Peroxide
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Historically, agricultural disinfectants containing hydrogen peroxide have been used for the disinfection of livestock housing surfaces and production equipment. Synthetic hydrogen peroxide is permitted for use in organic livestock production as a disinfectant, sanitizer, and medical treatment [7 CFR 205.603(a)]. It is also permitted for use in or on processed products labeled as “organic” or made with organic (specific ingredient or food group(s)) per 7 CFR 205.605(b), and for various uses in organic crop production per 7 CFR 205.601.
  • Iodine
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Iodine has excellent antimicrobial qualities and is widely used in organic livestock production as a topical treatment, disinfectant and antimicrobial, especially as a teat dip used both pre-milking and post- milking. Mastitis is a painful inflammation with infection. Antibiotic use is prohibited in organic agriculture so preventive healthcare is of critical importance. While a clean barn, clean milking parlor, and clean cows are a vital aspect of an organic milk production system, barns are not sterile environments and thus antimicrobial teat dips used in pre- and post-milking are vital preventive healthcare products. There are many teat dips available commercially. Iodine-based teat dips are the most commonly used in organic livestock production. Iodine can be in molecular form or iodophor form. Typically, molecular iodine is “complexed” into a variety of iodophors where surfactants are mixed with molecular iodine to enhance water solubility and sequester the molecular iodine for extended release in disinfectant products. There may also be several other ingredients in iodine-based teat dips, some of which may be excipients.
  • Magnesium sulphate
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Magnesium sulfate has a number of veterinary uses. It acts as an anticonvulsant, laxative, bronchodilator, electrolyte replacement aid with hypomagnesaemia, and may be used to treat cardiac arrhythmias. Specifically, in swine, magnesium sulfate is administered to treat malignant hypothermia. Magnesium sulfate can be added to livestock feed to treat conditions stemming from a magnesium deficiency. Lactation tetany or grass tetany occurs when ruminants graze on grasses low in magnesium or suffer from a low level of magnesium in their diet. The condition is often realized after cases of sudden death in cattle. Clinical signs include convulsions and muscular spasms, and death may occur due to respiratory failure. If livestock are feeding on pastures with high potassium levels, which interfere with the uptake of magnesium by grasses, supplemental magnesium sulfate may be needed. Magnesium capsules can be inserted into the rumen of livestock and after a one-week stabilization period, the capsule begins to release magnesium for up to 80 days. This capsule is recommended for use in high-risk or valuable animals. It is advised that, in addition to the capsule, the livestock be fed hay in order to increase absorption of the magnesium. If immediate treatment for magnesium deficiency is needed, magnesium sulfate can be administered intravenously. A magnesium lick can also be provided for livestock to increase the amount of magnesium in the diet. Because magnesium sulfate is not palatable, molasses is added to the magnesium lick to encourage cattle‘s use. Licks are generally 80 percent molasses and 20 percent magnesium sulfate and are considered to be less reliable than supplementing feed with magnesium. Magnesium sulfate, as Epsom salts, can be used to treat inflammation and abscesses in livestock. Soaking the affected area in a mixture containing Epsom salt and water can reduce signs of inflammation.
  • Parasticides, Fenbendazole
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: In veterinary medicine the term parasiticide refers to anthelmintic drugs (medicines used to destroy parasitic worms) [2015 TR 148]. Anthelmintics are medications capable of causing the evacuation of parasitic intestinal worms. As veterinary drugs, parasiticides are articles intended for use in treatment or prevention of disease in animals (Section 201(g)(1)(B) & (C) of the Federal Food, Drug, and Cosmetic Act [21U.S.C. 321(g)(1)(B) & 234 (C)]). The use of parasiticides in organic production is strictly confined to emergencies and the practice of returning livestock production to a healthy steady state does not include the routine use of parasiticides. Parasitism may be the weakest link in organic livestock production (Karreman, 2004). Outbreaks of disease due to nematode parasites can happen even in well managed herds. When changes in a production system occur as a result of land use, weather, or transient exposure of susceptible animals to parasites the natural imbalance favors parasite infestation. When unnoticed, undetected and without treatment parasite infestation can lead to disease and potentially death. (Stockdale, 2008) [2015 TR 394-398]
  • Parasiticides, Moxidectin
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: In veterinary medicine the term parasiticide refers to anthelmintic drugs (medicines used to destroy parasitic worms), [2015 TR 148] although moxidectin is also effective against arthropod parasites (e.g., ticks, mites, fleas, lice, etc.). As veterinary drugs, parasiticides are articles intended for use in treatment or prevention of disease in animals (Section 201(g)(1)(B) & (C) of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321(g)(1)(B) & 234 (C)]).
      The use of moxidectin in organic production is strictly confined to emergencies and the practice of
      returning livestock production to a healthy steady state that does not include the routine use of
      parasiticides. Routine management of parasiticides should include proper grazing management (rotating pastures when the grass is less than six inches tall), herbal and natural remedies, and selective breed genetics.
  • Peroxyacetic/peracetic acid
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Peracetic acid (PAA) is listed in the National List as allowed for use in organic livestock production for sanitizing facilities and processing equipment. This is consistent with the substance’s primary use in the food industry as a bactericide and fungicide for sanitizing and disinfecting structures, equipment, and hard surfaces. 2016 Technical Report (TR) line 99 states, peracetic acid may be used in livestock production in dairies – milking parlors, dairy production and transfer facilities and equipment – as well as in poultry premises, hatcheries, livestock quarters, stables, stalls, pens, cages, and on feeding and watering equipment.
  • Tolazoline
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: In organic livestock production, tolazoline is limited to use only by a veterinarian prescription and is further restricted for “use only to reverse the effects of sedation caused by xylazine.” Xylazine is primarily used in veterinary medicine as a sedative, tranquilizer, and analgesic. Sedation of animals is necessary for both planned medical procedures and emergency procedures to prevent pain and suffering and injury to the veterinarians performing the procedures. Tolazoline is commonly used as a reversal agent for xylazine by competing for the α2-adrenergic receptors, blocking binding events for xylazine. Structural similarities with xylazine allow tolazoline to compete with xylazine for biological binding sites, providing the mode of action for its approved use in organic livestock production as a reversal agent for xylazine [2019 TR 116-118].
  • Xylazine
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Xylazine is essential for use in veterinary surgical procedures for livestock, especially cattle. Xylazine is a substance with potent hypnotic and muscle-relaxation properties. The side effects of xylazine include significant cardiac arrythmias, which has resulted in its lack of approval for human medical applications (Green et al. 1981, EMEA 1999, Reyes et al. 2012). Due to the lack of approval for use in human medical applications, information on the mode of action and toxicity of xylazine is limited.
  • Oxalic acid
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Oxalic acid is used as a parasiticide specifically for apiculture. Oxalic acid is currently labeled and approved by the EPA for use in beehives (Registration #91266-1). It is used both in the hive and during transport of honeybees in cages when sold as “bee packages”. It can be used in rotation with formic acid, currently on the National List, to control varroa mites and is a useful tool for beekeepers to manage honeybee parasites. Oxalic acid can be applied to a hive in two ways: In a sugar syrup to be trickled between frames, and as a vapor treatment. There are numerous types of equipment, both home-made and commercially available, that provide the beekeeper the means of heating the oxalic acid and filling the hive with this vapor. In addition, oxalic acid is used to treat packaged bees before they are shipped to customers. Packaged bees with infestations of varroa mites have been a problem for beekeepers and the use of a sugar/oxalic acid syrup spray is a useful method to address this issue. Varroa mites, an invasive pest, are one of the many production problems affecting the livelihood of beekeepers. Numerous chemical varroa mite treatments have been used over the years in nonorganic operations. Many of these treatments are no longer effective due to the development of resistance by the varroa mite. Formic acid has been used for many years in honeybee hives, with no varroa mite resistance. It is considered unlikely that resistance will occur. Similar to formic acid, it is unlikely that varroa mites will develop resistance to oxalic acid.
  • DL Methionine
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Methionine is an essential amino acid for poultry since it cannot be produced biologically by the birds and is necessary for proper cell development for the growing chicks and for proper feathering. The USDA organic standards require that all agricultural ingredients for livestock feed be certified organic, and prohibit feeding meat by-products to organic poultry. This restriction narrows the options for natural sources of methionine.
  • Trace minerals
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: Minerals are required in animal nutrition for their vital roles in various metabolic, enzymatic, and biochemical reactions in the animal body. Forages and grains are good sources of calcium and phosphorus, respectively. Minerals may be provided through the intake of plant matter feedstuffs and through synthetic supplements. Several factors directly or indirectly influence the levels of minerals in plants, including location, nature, and chemical composition of the soil; level of fertilization; and the presence of anti-nutritional factors that may reduce mineral bioavailability. Bioavailability is defined as the total proportion of the nutrient in a feedstuff that is available for use in normal body functions. As a result, the amounts of minerals for animals that depend on plants as feedstuffs will vary.
  • Vitamins
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: The National Organic Program (NOP) currently allows the use of vitamins as feed additives in organic livestock production under 7 CFR 205.603, “Synthetic Substances Allowed for Use in Organic Livestock Production” for enrichment or fortification when FDA approved. Section 205.237(b)(2) prohibits the use of feed supplements and additives in amounts above those needed for maintenance of adequate nutrition and health. Further, the USDA organic regulations require producers to meet certain standards for livestock health care practices. As part of this requirement, livestock feed rations must meet nutritional requirements, including vitamins, minerals, protein and/or amino acids, fatty acids, energy sources, and fiber (ruminants) (7 CFR 205.238(a)(2)).

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Proposals

  • Research Priorities 2024
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Background: The National Organic Standards Board (NOSB) presents an annual list of research priorities for organic food and agriculture, a process originally established by the Board in 2012. The NOSB requests that integrated research be undertaken with consideration of the whole farm system, recognizing the interplay of agroecology, the surrounding environment, and both native and farmed species of plants and animals. As part of this year’s process, the Livestock, Crops, and Handling Subcommittee have made an effort to categorize and differentiate highest priority topics from ongoing topics.

Discussion

  • Inert Ingredients in Organic Pesticide Products
    • Beyond Pesticides' comments
    • Submit your own comment here
    • Overall: USDA’s National Organic Program (NOP) and the NOSB have relied on an allowable list of “inert” ingredients that is no longer maintained by the U.S. Environmental Protection (EPA), Lists 4A and 4B. While most of these materials are not of toxicological concern and are natural, many are synthetic and must undergo NOSB review under its responsibility to evaluate allowable synthetic substances on the National List of Allowed and Prohibited Substances in OFPA.

      The Materials Subcommittee has proposed two options for addressing this problem.

      The NOSB should adopt Option #1, which is consistent with the approach advocated by Beyond Pesticides for several years. Option #1 requires the NOSB to evaluate each synthetic “inert” according to the criteria in the Organic Foods Production Act (OFPA), which says that synthetic materials used in organic production must (1) not be harmful to human health or the environment, (2) be necessary for organic production, and (3) be consistent with organic farming and handling.

      The NOSB should reject Option #2, allowing any “inert” with an exemption from tolerance—which considers only effects of residues in food.

Discussion

  • Excluded Methods - TBD List/induced metagenesis

    • Beyond Pesticides’ comments
    • Submit your own comment here
    • Background: At the November 18, 2016 in-person National Organic Standards Board (NOSB) meeting, the NOSB recommended that the National Organic Program (NOP) develop a formal guidance document for the determination and listing of excluded methods. In addition to the 2016 recommendation, a discussion document provided a “To Be Determined (TBD) list” of technologies needing further review to determine if they should be classified as excluded methods or not. The 2016 TBD list included TILLING, Induced Mutagenesis (IM), Haploid Doubling Technology, Transposons, and Cell Fusion. In several comment opportunities since 2016, organic stakeholders, including seed breeders, have urged the NOSB to resolve the status of methods on the TBD list.  Induced Mutagenesis, Transposons, and Cell Fusion using in vitro nucleic acid techniques were
      determined to be excluded methods in 2019, but those techniques, in the absence of recombinant DNA techniques, remained on the TBD list. In 2022, cell fusion and protoplast fusion were determined to be excluded methods only when donor and recipient cells are not within the same taxonomic plant families and/or when derived using techniques of recombinant DNA technology. This discussion document addresses Induced Mutagenesis (IM) methods used without in vitro recombinant DNA technology

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