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Continuing a long tradition of public participation in setting organic standards, more than 1,000 people submitted comments leading up to the National Organic Standards Board (NOSB) meeting in Savannah, Ga. between Nov. 30 and Dec. 1. To view a webcast of the 4-day meeting, click here. The comments were in response to specific agenda items which the NOSB was convening to consider, including many important materials review decisions. At the meeting, NOSB members frequently cited both individual comments and the collective weight of public opinion as decisive factors in determining how they voted. Beyond Pesticides thanks everyone who used our Keeping Organic Strong webpage as a resource for developing their comments and encourages the public to continue making your voices heard in the development of organic standards.
The NOSB was established under the Organic Foods Production Act of 1990 (OFPA) which authorizes the U.S. Department of Agriculture (USDA) to operate an organic certification program. Appointed by the U.S. Secretary of Agriculture, the 15-member NOSB is responsible for making recommendations on whether a substance should be allowed or prohibited in organic production or handling, assisting in the development of standards for substances used in organic production, and advising the secretary on other aspects of implementing OFPA. No substance can be added to the National List of Allowed and Prohibited Substances that governs material use on certified production and handling operations without a supportive recommendation from the NOSB. Beyond Pesticides Executive Director Jay Feldman received a five-year appointment to the NOSB beginning January 2010 as an environmentalist—one of seven constituencies represented on the board.
Here is a brief summary of some of the NOSB’s major votes on Crop and Handling materials taken in Savannah:
This material was petitioned for use in exploding underground devises used to kill burrowing pests, including ground squirrels. The Crops Committee voted against this allowance in advance of the meeting and the full board affirmed that decision in Savannah. Those opposed to the petition stated that there is a full range of alternative materials to odorized propane and that methods already allowed in organic systems that can effectively control rodents, including habitat modification, traps, introduction of predators (such as dogs), rodenticide baits and many others, without the adverse impacts on biodiversity and with greater efficacy. These alternatives, in a more effective and less costly manner, achieve with management what propane would achieve with off-farm synthetic inputs.
Under existing organic standards, sulfur dioxide can only be added to wine labeled ‘made with organic grapes,’ provided that the total concentration of sulfite does not exceed 100 parts per million (ppm). Only wines to which no sulfites, which function as a preservative, have been added can be labeled ‘organic’ and display the USDA organic seal. Arguing that this restriction holds back growth in the marketplace for organically produced wines, a number of wineries petitioned with a request that the annotation be amended to allow sulfur dioxide use and resultant concentrations of sulfites not exceeding 100 ppm in wines labeled as ‘organic’ and displaying the USDA organic seal.Those opposing the petition commented that the addition of sulfites to wine has not been proven to be essential and argued against adding sulfites, which are a recognized allergen, to ‘organic’ wine. The NOSB rejected the petition, thereby retaining the distinction between wines that are ‘organic’ and 'made with organic grapes.’
In advance of the Savannah meeting, the Crop Committee recommended placing additional protections on the use of copper sulfate in rice production. The committee cited concerns that routine application rates of this material results in residual copper levels that threaten aquatic organisms including amphibians both in the rice fields and downstream after the irrigation water is released. When the committee proposed a preference for a well-established cultural practice—drill seeding of rice—in lieu of chronic dependence of synthetic copper sulfate, some rice producers questioned the practicality of such a solution. In the final vote in Savannah, copper sulfate in organic rice production was retained on the national list without the preference for drill seeding when conditions allowed.
This material was petitioned for use in spray applications to control weeds prior to planting food crops, at the base of grape vines and fruit trees and on the soil surface between crop rows or at the edges of plastic film mulch. Citing concerns about compatibility with organic practices and toxicity to aquatic invertebrates and the availability of several alternatives that do not require using a synthetic substance, the Crops Committee had rejected this petition and the NOSB concurred with that position.
The Handling Committee had proposed a recommendation to bring the use of chlorine in handling into compliance with the existing guidance policy established by the National Organic Program. This guidance will permit use of chlorine up to maximum labeled rates for sanitation of equipment and labeled uses in direct contact with products like fruits or vegetables, as long as there is a potable water rinse with no higher than drinking water levels after use. Additionally, it restricts chlorine in water used as an ingredient must to the level permitted in drinking water. Beyond Pesticides argued that this recommendation did not adequately address the significant human health and environmental risks known to result from chlorine’s manufacture and release into the environment. Furthermore, adoption of this recommendation means that there will be no differentiation between the allowance for chlorine use in organic and nonorganic products. Despite Jay Feldman’s dissenting vote, the NOSB approved the Handling Committee’s recommendation.
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The National Organic Standards Board (NOSB) will meet this month to decide on a range of issues regarding the future of organic food and farming in the U.S. The NOSB will vote to allow or prohibit substances and practices in certified organic food and farming after considering input from the public. Your participation is vital to this process. Public input can be highly influential to the development of organic standards, as farmers and consumers relay their ideas to the board for consideration, but only if you speak up. The public comment period closes after this Sunday, Nov. 13. Take Action.
There is a wide range of issues that the board is considering for this meeting including pest control materials, inputs in processed food, internal board procedures and many others. You can access background on these issues on our Keeping Organic Strong webpage and then send comments to U.S. Department of Agriculture (USDA) by the end of day, Nov. 13.
Submit your comments using this form. This will bring you to a form in which you can fill out your personal information and type your comments. When filling out your personal information, you only need to fill in the fields with a blue asterisk next to the label. Other fields, such as Submitter’s Representative and Government Agency should be left blank. Under Organization Name, enter the name of the group you are representing, “None” or “Private Citizen” if you are representing only yourself. You may then type your comment or upload it as a separate file. Finish by clicking the orange Submit button.
We recommend using these guidelines and referring back to the organic law in order to organize your thoughts in your comments. As our comments demonstrate, this will help to clearly and succinctly lay out your points and make it easier for NOSB members to follow your reasoning.
Here is our commentary on just a few of the pressing issues under consideration:
The Policy Development Committee has proposed a recommendation that would enhance the transparency of the NOSB’s committee meetings and decision processes. Specifically, the committee has recommended that full, accurate minutes be taken on Committee meetings and conference calls that reflect the source of positions taken on issues, and that minutes, reports, transcripts, and other documents related to board decisions be made freely accessible to the public in hard copy as well as electronically through the World Wide Web. We fully support this recommendation and encourage further transparency in any way it can be achieved. The development or organic standards is intended to be a public stakeholder process in which anyone who has an interest in organic integrity and the future of the organic sector can also have a voice in the process. Increased transparency allows interested parties to give more informed and effective input, leading to more agreeable results for all involved.
A petition was submitted to the Crops Committee to allow propane to be exploded in burrows in order to control underground rodents. We support the Committee’s decision to deny the petition and not allow such explosions for a number of reasons. Firstly, exploding underground burrows does not fall under any category of allowed synthetic substances in the Organic Foods Production Act.
Beyond the legal considerations, controlling rodents by essentially bombing their habitats is wildly inconsistent with organic principles and ideals of minimizing environmental impact and encouraging beneficial natural interactions. Such practices would kill or harm any organisms in the surrounding area, including those in the soil, as well a number of beneficial endangered species which also burrow or live underground. The potential for causing fires and the safety risks to the operator are further concerns around the use of propane devices.
There is also a full range of alternative materials and methods already allowed in organic systems which can effectively control rodents, including habitat modification, traps, introduction of predators (such as dogs), rodenticide baits and many others. These alternatives, in a more effective and less costly manner, achieve with management what propane would achieve with off-farm synthetic inputs.
Because of the likely widespread damage to ecosystems, the availability of alternatives, and the unpredictable nature of the use of such a material combined with its questionable efficacy, we strongly recommend supporting the committee’s decision and denying the use of this material.
The Materials Committee proposed a discussion document which “shares the committee’s current thinking on a process to collect, prioritize and maintain research needs related to organic production methods and materials.” We are happy to see the NOSB address the issue of setting research priorities. Like the committee, we welcome the prospect of a process that will help bring more research efforts to troublesome problems in organic production and handling. We look forward to a time when disagreements will be decreased by the availability of research into alternatives that everyone can support.
We would also particularly like to request better quality control over the technical reviews that are received by the committees scientifically evaluating particular substances with regards to their compatibility with organic systems. These reviews are highly influential in the board’s evaluation of particular substances and they should fully address all of the pertinent issues. We would support a return to the use of Technical Advisory Panels such as were used in previous years, which incorporate more diverse viewpoints and expertise.
Here are the rest of the issues for this meeting:
– Copper Sulfate
– List 3 Inert Ingredients
– Ammonium Nonanoate
– Peracetic Acid
– Calcium Chloride
– Indole-3-butyric Acid (IBA)
– Organic Aquaculture
– Sulfites in Wine
– ARA and DHA
– Public Comment Procedures
– Conflict of Interest Policy
We encourage you to use and build upon our commentary in making your own comments.
We share your enthusiasm for organic practices as the solution to pesticide pollution, to advance clean food, air, water and a sustainable environment—and want to ensure that organic grows stronger every day. But, this won’t happen without your involvement.
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