National Organic Standards Board Recommended Guidelines to Prevent Your NOSB Comments from Being "X"ed Out

Keeping Organic Strong: Changes in Organic Regulations and Farming Practices


Thank you for taking action to protect organic integrity.

A Framework to Keep in Mind When Commenting to the NOSB

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.

Beyond Pesticides encourages citizens to provide a detailed comment to the Board, with the understanding that considerate, well thought-out comments carry more weight than form letters or copy/pastes of our organization's summaries. You might notice that many comments on the regulations.gov website have an "X" marked through them. When this is done, regulators are essentially grouping your comment together as one comment. This unfair practice minimizes your voice. The best way to avoid the "X" is to start with a personal statement such as:

I am a mother of two young children. I buy organic because I want the best food for them....
I am a school teacher and I teach my students about the value of organic products....
Organic products are crucial to me because of my chemical sensitivities....

By personalizing your comments in this way, they are set apart as unique. We encourage you to also provide your unique take on the issue on which you are commenting. However, we understand the constraints of modern living, and encourage you to provide the best comments that your time constraints allow. If hard pressed, you can copy the summary of Beyond Pesticides comments, or simply express your concern that organic integrity be protected. That being said, the more detailed comments the Board gets, the less likely it is that you will be "X"ed out, and the more likely it is that we can really Keep Organic Strong.

Note: If you plan on submitting comments to multiple subcommittees, please consider submitting a separate comment for each subcommittee, as this will make the process easier and ensure that your comments are more effective.

See regulations.gov's official "Tips for Submitting Effective Comments."

Still have questions on how to structure your comments? Call us at 202-543-5450 or send us an email.