Public Comment Alerts
Top Priority Issues
April 12, 2016
We have previously listed our positions on some of our top priority issues, such as inerts, sanitizers, ancillary substances, carrageenan, and paraciticides (below, as of March 18, 2016). We have now updated this page with the rest of our top priority issues. Please feel free to use our positions as the basis for your comments, or directly copy and paste from below, in addition to a personal note of your own to ensure your comment is treated as unique and read by an NOSB member. You can submit your comments here, through regulations.gov.
Policy and Procedures Manual Revisions
"I appreciate the response to fall comments regarding the difficulty of reviewing proposed changes to the Policy and Procedures Manual (PPM). I appreciate, in particular, the clarification that the NOSB will vote on the proposed changes and the publication of a redlined version and an annotated table of contents. I do not think it is appropriate, however, for the NOSB to consider such a complicated proposal without an explanation and justification of each change. OFPA created the NOSB as a means of ensuring that the organic community retained control over the organic program, despite its bureaucratic location within USDA, a hostile agency. The PPM is the instrument through which the NOSB maintains its ability to set the course for organic production in the United States. The NOSB must not relinquish that control by weakening the PPM."
Nutrient vitamins and minerals
"I appreciate the efforts of the Handling Subcommittee in untangling the mess that has come from mistaken implementation of past NOSB recommendations. Added vitamins and minerals –synthetic or nonsynthetic—should not be permitted in products labeled “organic” unless required by law. Consumers expect that organic food contains a complete complement of nutrients based on organic agricultural production practices, not supplementation."
We have begun to analyze the numerous recommendations and are providing you with our positions that we hope you will use as the basis for your comments. We will provide positions on additional topics in the near future. Please feel free to develop your own comments or cut and paste ours below. Putting a personal note of concern before cutting and pasting our positions will make sure your comment is treated as a unique comment and read by NOSB members. You can submit your comments here, through regulations.gov.
"Three items on the NOSB agenda concern so-called “inert” ingredients in pesticides –sunset of List 3 “inerts,” a discussion document on the prohibition of nonylphenol ethoxylates as List 4 “inerts,” and a verbal update from the Inerts Working Group. (1) The NOSB must take the sunset review of List 3 “inerts” seriously. The NOSB must do a full review of these chemicals, which it previously recommended to come off the list at the end of last year, but are likely to remain on for at least 5 more years without action at this meeting. (2) The NOSB should move as expeditiously as possible in recommending an end to the use of endocrine-disrupting nonylphenol ethoxylates (NPEs). The evidence shows the dangers of NPEs, and alternatives are available. Postponing will not prevent formulators from procrastinating. (3) The fall 2015 recommendation on the “inerts” annotation must be implemented in a way that ensures NOSB participation in the initial review and future sunset review of the chemicals."
"There are three proposals to list hypochlorous acid –for use in crops, handling, and livestock—and another petition for use of sodium dodecylbenzene sulfonate in handling that are under consideration. While both materials offer some advantages over currently allowed materials, the NOSB lacks a frame of reference for deciding which sanitizing agents are needed in organic production. Sanitizers do not always offer improvements in health, and I urge the NOSB to do a comprehensive survey of needs for sanitizing agents before adding more to the National List. I suggest that the NOSB investigate sanitizers approved for EPA’s Safer Chemical Ingredients List –most of which are already allowed in organic production—as alternatives to harsher chemicals."
"Ancillary substances are added to ingredients found in organic foods to achieve some effect in those ingredients --preservative, adjusting moisture, even pest control. The NOSB adopted a policy in 2013 that all ancillary substances would be reviewed according to OFPA criteria, but the Handling Subcommittee has simply been listing those ancillary substances known to be in use. Now the Handling Subcommittee is proposing to modify the policy. (1) Definitions are needed. In order to be meaningful and useful, the ancillary substances policy must define terms it uses: technical or functional effect, direct food additive, incidental food additive, food contact substance, functional class, and significant amount. (2) Each ancillary substance must be approved for each particular use. Whether the approval of ancillary substances is communicated by means of listing on the National List –which we believe to be required by OFPA—or by other means, each ancillary substance must be reviewed according to OFPA criteria. The NOSB must not categorically allow substances in a functional class that have not been specifically reviewed and it must not rubber stamp ancillary substance just because they are currently in use."
"I oppose the relisting of carrageenan on §205.605(a) and believe that the substance should be removed from the National List. Carrageenan should be reclassified as a synthetic. This use does not meet the requirements of the Organic Food Production Act —carrageenan may have adverse effects on the health of consumers, its production results in adverse ecological impacts, there are alternatives to its use, and its use is inconsistent with a system of organic and sustainable production. Independent scientists have presented evidence to the NOSB demonstrating inflammatory impacts of carrageenan. Due to consumer concerns about the use of carrageenan in organic products, it has been removed from many, and every product containing carrageenan is available without it –demonstrating the lack of essentiality."
"In reviewing all three parasiticides together, livestock subcommittee failed to bring forward motions to remove ivermectin and moxidectin due to adverse ecological effects. This would have allowed the NOSB to consider the full range of actions that have been supported by public comment. As noted in comments from former NOSB member Dr. Karreman, the intention of the NOSB in approving fenbendazole was to allow for the removal of ivermectin and possibly moxidectin. Since such an action at this meeting would be prohibited as a substantive action not proposed for public comment, these proposals should be referred back to the subcommittee, to return with proposals that address the full range of actions supported by the available evidence."