All Synthetic Chemicals in Organic Must be Examined—Including “Inerts”
The National Organic Standards Board (NOSB) is receiving written comments from the public, which must be submitted by September 28, 2023.
This deadline precedes the upcoming public comment webinar on October 17 and 19 and deliberative hearings on October 24-26—concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov. by 11:59 pm EDT, September 28. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October.
The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials (substances) allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health.
The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and the Fall 2023 issues page. see Keeping Organic Strong and the Fall 2023 issues page. USDA’s National Organic Program (NOP) and the NOSB have relied on allowable lists of “inert” ingredients that are no longer maintained by the U.S. Environmental Protection (EPA), Lists 4A and 4B.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. Beyond Pesticides has advocated that the NOSB break down the hundred or so “inerts” of potential concern into groups of chemical families and common toxicological mechanisms to conduct its review over several years. For example, the ethoxylated compounds could be evaluated together. In fact, they are not permitted in EPA’s Safer Choice labeling program. (For a more in-depth discussion of the “inerts” in organics, please see “Inert” Ingredients Used in Organic Production.)
This is not a new issue for the NOSB and NOP, but one that needs resolution now.
Some crucial facts must be acknowledged by USDA:
- “Inert” ingredients are not necessarily biologically or chemically inert. The Beyond Pesticides report ”Inert” Ingredients in Organic Production compares the toxicity of active substances and “inert” substances used in organic production. In almost every category, there are more harmful “inerts” than active substances.
- OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application” based on a recommendation by the NOSB, following procedures in OFPA.
- The NOSB has repeatedly passed recommendations telling the NOP to evaluate individual “inerts.”
We urge you to submit comments to the docket on the NOSB/NOP “Inerts Pre-Discussion Document” (under consideration at the upcoming NOSB meeting in October), incorporating the following points (feel free to cut-and-paste these comments you submit in the docket):
Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste the comments above into Regulations.gov and add or adjust the text to personalize it. Please see this instructional video for guidance. (Regulations.gov has changed its look since this video was made.)