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Keeping Organic Strong: Changes in organic regulations and farming practices
National Organic Standards Board

Recommended Guidelines for Commenting

According to the Organic Foods Production Act, a synthetic substance may only be allowed for use in organic production if it meets the following criteria [7 USC 6517(c)(1)(B)]:

  • It contains an active synthetic ingredient in the following categories: 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 including netting, tree wraps and seals, insect traps, sticky barriers, row covers, and equipment cleansers.
  • It contains synthetic inert ingredients that are not classified by the Administrator of the Environmental Protection Agency as inerts of toxicological concern.

Additionally, it must be fully established that the use of the substance [7 USC 6517(c)(1)(A)]

  • would not be harmful to human health or the environment;
  • is necessary to the production or handling of the final product because natural substitutes are not available; and
  • is consistent with organic farming and handling (see the NOSB’s Principles of Organic Production and Handling).

Structuring your comments on synthetic substances around these points and referencing the specific stipulations in the law will help the members of the NOSB to understand your argument and will make your input more effective.

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