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.Eating with a Conscience .Latest News .Take Action: Make Organic Stronger .Publications .Media .Organic Program Page .Home		Keeping Organic Strong: Changes in organic regulations and farming practices National Organic Standards Board Beyond Pesticides' Archives of Previous NOSB meetings Take Action: Join Us at Upcoming Meeting Meeting to take place May 22-25, 2012 The National Organic Standards Board (NOSB) will meet at the end of the month to decide on a range of issues regarding the future of organic food and farming in the United States. The 15 member board will vote to allow or prohibit substances and practices in certified organic food and farming after considering input from any interested members of the public, such as farmers, consumers, food processors, or professionals. Public participation is vital to the development of organic standards, as farmers and consumers relay their ideas to the board for consideration. Thank you to all who submitted written comments to the board. You will be sure that your concerns are considered by the board at the meeting in Albuquerque. You can read about the issues below and we invite you to join us at the meeting to take part in the discussion and follow all of the developments. TAKE ACTION: Making Your Voice Heard The organic regulatory process provides numerous opportunities for the public to weigh in on what is allowable in organic production. USDA maintains a National List, set by the NOSB, of the synthetic substances that may be used and the non-synthetic substances that may not be used in organic production and handling. The Organic Foods Production Act (OFPA) and NOP regulations provide for the sunsetting of listed substances every five years and relies on public comment in evaluating their continuing uses. The public may also file a petition to amend the National List. In both cases, sunset and petition, the NOSB is authorized by OFPA to determine a substance’s status. Check in with this page to learn about how you can take part in future NOSB meetings. View the full docket for the Spring 2012 meeting to see other comments already submitted. It should be noted that the NOSB meeting structure has been changed from how it was previously organized. The NOSB will now complete all activities (listen to public comments, then discuss/vote on agenda items in light of those comments) on a given committee before moving onto the next. To help the NOSB use your comments, please use your written comments to address multiple topics and focus your oral comments on one committee’s agenda items. If you choose to address multiple committees’ topics in your oral comments, the National Organic Program (NOP) asks that you be very clear about which topics you wish to address so they can schedule your comments before the NOSB votes on those agenda items. Issues Before the NOSB for Spring 2012 Final Meeting Agenda Full Meeting Packet with Agenda and All Proposals Inert Ingredients GMO Vaccines Carrageenan Public Communications with NOSB Significant Residues Extractants and Solvents Public Comment Procedures Research Priorities Conflict of Interest Policy GMO Letter to Secretary Sanitizers and 100% Organic Label Agar-agar Curry and Kaffir Lime Leaves Other Handling Committee materials Choline Inositol Gibberellic Acid Calcium Sulfate Glucono Delta-Lactone Cellulose Inert Ingredients Committee Proposal “List 3” We support the committee proposal to address and review inert ingredients as individual materials, as any and all synthetics used in organic production must be reviewed. Inert ingredients previously categorized by the EPA as “List 3,” meaning that they were of unknown toxicity, have until this point been categorically allowed in "passive pheromone dispensers". However, this allowance is out of sync with the National List review process and was never intended to be a long-term solution. The current proposal would rectify this by ensuring that the board reviews the small handful of ingredients that had been allowed as part of the List 3 classification. We urge the board to adopt this proposal and ensure that these materials, like any synthetics in organic production, are safe and appropriate for use. “List 4” Though it is not part of the current proposal, we also urge the board to review the allowance of inert ingredients that had been classified by EPA as “List 4” reduced risk inerts. As we know, “inert” ingredients in pesticides are in no way inert. They are simply not the claimed active ingredients in the pesticide products, and may have negative impacts on human health and ecological systems. The Organic Foods Production Act does not make any mention of a special allowance or exception for inert ingredients in the review of materials. All synthetic materials used in organic production must be subject to individual review by the NOSB. We urge the board to adopt a policy which would implement this practice. Regardless of the strategy for addressing the former List 4 materials, the three or four former List 3 chemicals must be addressed immediately with a full review as required by the Organic Foods Production Act. These chemicals never should have been listed without review, and their listing cannot be justified by any rationale applied to the former List 4 materials. See Beyond Pesticides’ comments for full background. See selected public comments on inerts. GMO Vaccines Proposed Committee Recommendation We urge the NOSB to reject the proposal from the Livestock Committee to allow the use of GMO vaccines without review in emergency situations. Of the approximately 73 registered animal vaccines, 13 are produced using genetically modified organisms (GMOs, also known as “excluded methods” in organic rules). GMO vaccines are not legally allowed in organic production. This recommendation proposes a change which will allow GMO vaccines only in a declared emergency without losing organic status of livestock. The recommendation from the Livestock Committee would allow unreviewed GMO vaccines to be used in organic production under certain prescribed “emergency” conditions. We are concerned with the possibility for abuse of such an emergency allowance, in part because we have seen how emergency exemptions for pesticide use have been misused, in spite of every effort to tightly define an “emergency.” Specifically, we are concerned about the lack of any opportunity for public review or input for a proposed emergency allowance. Numerous questions remain regarding the implementation of this proposed policy and we urge the board to postpone any action on this issue until it has all of the necessary information. See Beyond Pesticides’ comments for full background. See selected public comment on GMO vaccines. Carrageenan Proposed Committee Recommendation We urge the NOSB to reject the recommendation of the Handling Committee and to remove carrageenan from the National List. Carrageenan is extracted from certain red seaweeds and is used as a bulking agent, carrier, emulsifier, gelling agent, glazing agent, humectant, stabilizer, or thickener in a variety of foods. The Handling Committee is recommending that carrageenan be reclassified as a synthetic material. However, the technical review of the material shows severe health effects from carrageenan, including “induction or promotion of gastrointestinal tract inflammation, ulcerations and/or neoplasms.” It also documents serious ecological impacts from both harvesting of wild seaweeds, as well as culture of certain species for carrageenan production. Furthermore, carrageenan is unnecessary. The USDA technical review lists a number of substitutes that “may be substituted for carrageenan to achieve a similar functionality when used either alone or in combinations.” The Cornucopia Institute has surveyed organic products, and found that every product made with carrageenan can be made without it. Some people prefer food that has none of these materials. See Beyond Pesticides’ comments for full background. See selected public comment on the carrageenan proposal. Public Communications with the NOSB Proposed Committee Recommendation We urge approval of the recommendation that has been proposed. Current NOP policy restricts communication between the public and the NOSB to formal comments submitted through a docket or through a formal petition. We would like to see this policy changed to allow a more free exchange of ideas and information so that both the board and the public are better informed. The NOSB is intended to represent the organic community as a whole. This would be more easily accomplished if the community were able to provide input throughout the NOSB decision making process. See Beyond Pesticides’ comments for full background. See selected public comments on Policy Development Committee issues. Significant Residues Proposed Discussion Document We urge the Board to define “significant residue” in such a way that, if a synthetic chemical is used in producing the material, the material will be classified as synthetic and reviewed by the NOSB. The full review of any and all synthetic materials that are used in organic farming or in the production of materials that are used by organic farmers is required by the Organic Foods Production Act (OFPA.) OFPA clearly requires that synthetic chemicals be limited as much as possible in organic production and, when they are unavoidable, requires that they be reviewed to ensure that they are not harmful. For this reason, “significant residue,” for the purposes of classifying whether a material is synthetic or not, should be defined in such a way that, if a synthetic chemical is used in producing the material, the material must be classified as synthetic and reviewed by the NOSB. See Beyond Pesticides’ comments for full background. See selected public comments on Materials Committee issues. Solvents and Extractants Proposed Discussion Document Related to the issue of significant residues is the use of chemical solvents as extractants in manufacturing materials and ingredients used in organic food and farming. Volatile synthetic solvents have always been regarded as materials to avoid in organic production, but the regulations prohibiting their use fail to define the term “volatile synthetic solvent” and lack clarity and consistency in their application. We urge the NOSB to adopt a policy which makes it clear that the use or presence of a synthetic solvent in an ingredient disqualifies the product from being labeled as “organic.” The use or presence of a synthetic solvent in a material used in organic production or handling must trigger a full review of the material, resulting in the classification of that material as synthetic. See Beyond Pesticides’ comments for full background. See selected public comments on Materials Committee issues. Public Comment Procedures Proposed Committee Recommendation We urge adoption of the proposed recommendation concerning public comment procedures on NOSB proposals and at NOSB meetings, though we suggest extending the in-person time limit to five minutes instead of three. We urge the board chair to be prepared to be flexible according to the circumstances. This includes allocating unused time to allow those on a waiting list to speak or to allow the board to ask further questions. See Beyond Pesticides’ comments for full background. See selected public comments on Policy Development Committee issues. Research Priorities Committee Proposal We support the committee’s proposal for a framework by which the NOSB can develop and make known its priorities for research in organic production. Field research on how best to improve organic management systems for better production and fewer synthetic inputs is vital to ensuring that organic retains the integrity that it has today and continues to gain ground. We would especially like the board to emphasize research into organic systems management, rather than into specific material inputs whenever possible. See Beyond Pesticides’ comments for full background. See selected public comments on Materials Committee issues. Conflict of Interest Policy Committee Proposal We support the recommended proposal which would clarify and strengthen the NOSB’s Conflict of Interest Policy. The NOSB is designed to be an advisory committee composed of representatives of various segments of the diverse organic community. For this reason, all members have an inherent interest in actions taken by the board. However, it is helpful to have policies that differentiate between representing a segment of the organic community and advocating for one’s personal interest. Most importantly, transparency in the NOSB’s decision-making process requires disclosure of interests. See Beyond Pesticides’ comments for full background. See selected public comments on Policy Development Committee issues. Letter to Secretary Concerning GMOs Proposed Letter Several member of the NOSB have proposed sending a letter to Secretary of Agriculture Tom Vilsack outlining concerns the board has regarding the increasing prevalence of genetically modified crops gaining approval from the U.S. Department of Agriculture (USDA). Specifically, the letter takes the position that “USDA’s actions on genetically engineered crops have been insufficient to protect the organic industry” and discusses ways that the NOSB ad hoc GMO committee can recommend solutions to address the issue. We are happy to see the board communicating directly with Secretary Vilsack about serious public concerns raised to the Board about GMO contamination in organic production. We support the Board’s recognition of its duty to advise the Secretary and strongly agree with the Committee’s assessment that “the responsibility to prevent GMO contamination of organics is shared by those who develop, use, and regulate this technology.” See Beyond Pesticides’ comments for full background. See selected public comment on the letter to the Secretary concerning GMOs. Sanitizers and 100% organic status Committee Discussion Document Current organic regulations stipulate that, if any agricultural product comes into contact with a processing aid or sanitation material (e.g. chlorine) in its journey from the field to the shelf, this means that it cannot be labeled as “100% organic,” (as opposed to simply “organic”) even if no residue remains in the final product. The committee sent out a discussion document seeking input from the organic community regarding what value the “100% organic” label holds and whether the current regulations are appropriate. We fully support the current regulations and believe that it is wholly appropriate, and is in fact the explicit intention of organic certification, to label a product based on the materials that are used in its production. Even if no residue remains on the final product, the fact is that product was produced with non-organic materials and should not be able to achieve the gold standard “100% organic” level. Residue in the food is only one factor when it comes to the impact of organic agriculture. 100% Organic food should not be causing adverse health and environmental effects by virtue of the manufacture, use, or disposal of any of its components. In addition, the 100% Organic label has value as a goal for the continuous improvement that should be part of every organic enterprise. As seemingly insignificant processing aids and food contact substances are removed, it lessens the negative impact on the entire ecosystem. See Beyond Pesticides’ comments for full background. See selected public comment on the issue of sanitizers and "100% Organic" status. Agar-agar Committee Proposal Agar (or agar-agar) is a food additive which may be natural (nonsynthetic) or synthetic. Nonsynthetic agar is made from Gellidium species of seaweed. The Handling Committee has recommended that the natural form of the material retain its current allowance in handling organic food. However, the committee has also recommended that a synthetic form of the material be added to the National List as an allowable substance. We support the continued allowance of natural forms of agar-agar with the annotation, “from Gellidium species, processed without alkaline pretreatment.” We oppose the proposed allowance of agar-agar in its synthetic forms due to the fact that natural forms are clearly available as well as adverse ecological impacts resulting from the production of synthetic forms. See Beyond Pesticides’ comments for full background. See selected public comment on Handling Committee issues. Curry and Kaffir lime leaves Committee Proposals: Curry leaves, Kaffir lime leaves We support the listing of curry leaves and Citrus hystrix leaves as ingredients in organic food that may be non-organically sourced. Although we always advocate for the use of organic ingredients in processed organic food whenever possible, the plain fact is that, currently, organic production does meet the demand for these products. However, we urge the board to thoroughly review these ingredients again in five years when they come up for sunset review, and try to ascertain whether the supply of organically sourced spices has grown to the extent that the non-organic allowance is no longer needed. This appears to be a classic case where the lack of availability of certain ingredients could well be met by the time of sunset action. See Beyond Pesticides’ comments for full background. See selected public comment on Handling Committee issues. Other Handling Committee Materials Choline Committee Proposal We urge the board to reject the Handling Committee’s recommendation to allow synthetic choline in organic infant formulas. The Committee has not shown a need for synthetic choline to be added to the National List. The manufacture requires nonrenewable feedstocks, may release toxic air pollutants, and may result in a formulated product containing toxic chemical residues in the synthetic choline. Inositol Committee Proposal The Handling Committee has not shown a need for synthetic inositol to be added to the National List. Additionally, the addition of an unnecessary synthetic ingredient to organic food is not compatible with consumer expectations of organic food. Therefore, we urge the board to reject the recommendation to list synthetic inositol for use in organic infant formulas. Gibberellic Acid Committee Proposal Lacking any data supporting need, and in view of the potential harm, use of volatile synthetic solvents in its production, and long distance transport as a justification, we must take a precautionary approach and oppose the listing of gibberellic acid for use on bananas on the National List. Calcium Sulfate Committee Proposal Calcium sulfate has been used as a coagulant for tofu for over 2000 years in China. Although there are other coagulants that may be used, calcium sulfate is essential for traditional Chinese tofu. However, other uses are allowed under the current allowance for this material, and the need for them has not been established. We have not seen sufficient evidence to support the use of calcium sulfate for all food uses. Therefore we support renewing the listing of calcium sulfate, provided that it includes the annotation, “For use only as a coagulant in bean curd (tofu and similar products).” Glucono Delta-Lactone (GDL) Committee Proposal Although some questions remain about its essentiality in the production of silken tofu, we support the relisting of glucono delta-lactone with the following annotation: ”For use only as a coagulant in bean curd (tofu and similar products); when produced by oxidation of D-glucose by non-genetically-modified, nonpathogenic, and nontoxicogenic microorganisms or by enzymes derived from these organisms. No volatile synthetic solvents may be used in the crystallization process.” Cellulose Committee Proposal We urge the committee to update its review to examine the availability of nonsynthetic, possibly even organic, forms of cellulose for the proposed uses. The board has received a petition to remove silicon dioxide for some of these uses because of the existence of an organic rice concentrate alternative, which should be considered. We also urge the board to delist microcrystalline cellulose as an anticaking agent because it is a highly processed synthetic material, and nonsynthetic alternatives are available. See Beyond Pesticides’ comments on Handling Committee materials for full background. See selected public comment on Handling Committee issues. About the NOSB USDA’s Agricultural Marketing Service oversees the National Organic Program (NOP) and the NOSB. The NOSB includes four producers, two handlers, one retailer, three environmentalists, three consumers, one scientist and one certifying agent. The board is authorized by the Organic Foods Production Act and makes recommendations to the Secretary of Agriculture regarding the National List of Allowed and Prohibited Substances for organic operations. The NOSB also may provide advice on other aspects of the organic program.The executive director of Beyond Pesticides is serving a five-year term (2010-2014) on the NOSB as one of three environmentalist/resource conservationist stakeholders. For more information on the history of organic agriculture and why it is the best choice for your health and the environment, please see Beyond Pesticides’ Organic Food Program Page.
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