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Spring 2023 NOSB Meeting

National Organic Standards Board

Spring 2023 NOSB Meeting
Comment by April 5th, 2023!

The NOSB Spring Meeting 2023 will be held in-person Tuesday April 25th through Thursday April 27th, 2023 in Atlanta GA. Links to listen in to the virtual comment webinars and the public meeting will be posted on this webpage one week before the meetings in April.

From the very beginning, with the passage of the Organic Foods Production Act in 1990, “organic” has meant “continuous improvement.” The primary mechanism for continuous improvement in organic production is the high level of public involvement that comes from twice-annual meetings of the stakeholder board.

The second mechanism is the sunset process, which helps move synthetic substances out of organic production as the market invests in growing organic inputs and ingredients. Despite USDA’s efforts to weaken the sunset process, the 5-year cycle of review of every synthetic substance currently used in organic production and processing, offers us an opportunity to keep organic strong and strengthen any weaknesses.

***UPDATE: Check out the oral comments made to the NOSB Board by Executive Director Jay Feldman and Board member Terry Shistar on April 18, 2023. 

Priority Issues.

For more detailed analysis on all upcoming issues, scroll down to the description and links. For quick copy and paste, use the text below to comment at Regulations.gov. Add a personal message about why this is important to you at the top, if possible.

Prohibit the Routine Allowance of Ingredients Processed with Ion Exchange. Because the ion exchange process is a chemical process, all organic ingredients processed in this manner must be subject to review by the NOSB. Ion exchange creates synthetic ingredients through chemical change—removing some components and substituting other chemicals—that are used in processed food. It is not simply filtration. Chemicals in the ion exchange resins may leak into the food product. Yet, the Handling Subcommittee of the NOSB is proposing to allow any and all resins without review. To maintain the integrity of the organic label, resins must be subject to full National List (National List of Allowed and Prohibited Substances) review to determine whether these ingredients meet organic standards, rather than establishing a blanket allowance of ion exchange in organic processing.

Organic Agriculture is Climate-Smart Agriculture. In a draft letter to Secretary of Agriculture Tom Vilsack, the NOSB has written an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to dramatically increase support for converting chemical-intensive agriculture to organic. It is critical that the National Organic Program ask, “What more should USDA be doing to advance organic?” As the Board states, the resiliency of organic is established: “Organic is the solution to mitigating climate change and responding to it.” However, despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should require the adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs and abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry.

Plastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging

The NOSB should use the review (or sunset) process to eliminate nonorganic ingredients in processed organic foods. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.

(Beyond Pesticides will be populating this page over the next several weeks with draft comments on all the other issues)

Not sure how to use our suggested language to comment? Follow these simple steps:

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

 

Spring 2023 NOSB Meeting

The Spring 2023 NOSB meeting dates have been announced and public comments are due by April 5th 2023. Your comments and participation are critical to the integrity of the organic label.

Where: The meeting will be held in person in Atlanta, GA and online meeting access information will be available here approximately one week before the webinars in April.

When: Tuesday April 25, Wednesday April 26, and Thursday April 27, 2022

Written comments may be submitted through Regulations.gov until 11:59 pm ET April 5th, 2023. Reservations for oral webinar comments can be made here. Keep in mind they fill up fast and the deadline is also by 11:59pm ET April 5th, 2023. The online webinar for comments will take place on April 18th and 20th.

The proposals of the National Organic Standards Board (NOSB), as a part of its ongoing review of practices and materials, are published for public comment. The public comment period will end April 5th, 2023. On this page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board on our website pages. You can view USDA's announcement of the NOSB's meeting and proposals here. Please see Beyond Pesticides' analysis below (and more coming soon).

Issues Before the NOSB for Spring 2023

Materials in the list below are either the subject of petitions or the subject of sunset review. Petitioned materials must have evidence summarized in the proposals that they meet the OFPA requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices. Sunset items are already on the National List, and being considered for delisting. They are subject to the same criteria, but are being considered under NOP's new rules.

The NOSB will vote on materials subject to sunset review at the Fall 2020 meeting.

To truly make an impact in the future of organic, Beyond Pesticides encourages you to:

**On certain browsers, it may be necessary to download a PDF version of Beyond Pesticides' comments in order to view the navigation pane**

Compliance, Accreditation, and Certification Subcommittee

Crops Subcommittee

Handling Subcommittee

Livestock Subcommittee

Materials Subcommittee

Policy Development Subcommittee

 

Draft Meeting Agenda

 

 

Take Action at Regulations.gov!
(Comments Due April 5, 2023!)

 

See All Comments So Far

 

See Beyond Pesticides' Commenting Guidelines

 

See All Meeting Materials and Issues

 

The Organic Foods Production Act

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