Comment by October 4: Ask the NOSB to Uphold Real Organic Integrity

September 18th, 2018

[This alert is over.]

Beyond Pesticides is a highly-respected ally in our fight to protect the integrity of the organic label. Since we are doing less direct scrutiny of materials, we are depending more upon their analysis. Why?

  1. In a process greatly accelerated during the Obama administration, the National Organic Standards Board has been successfully stacked with employees of members, or corporate allies, of the powerful industry lobby group, the Organic Trade Association — even in seats designated for citizens who “own and operate” organic farms.
  2. Under the leadership of the NOSB board representative who works for Clif Bar, the OTA-friendly panel gave away much of its power and autonomy to set its work plan and meeting agendas to the political appointees at the USDA. The will of Congress, that the NOSB be an independent body advising the USDA Secretary, has been subverted.
  3. Finally, since the Trump administration has taken over, USDA Secretary Sonny Perdue has shown no hesitation in overruling unanimous votes on approving/disapproving non-organic substances for use in organic food and agriculture (and has scuttled animal welfare policy advice as well). This disrespect for the public-private NOSB collaboration is unprecedented.

Thus, we are directing more of our resources to marketplace education and activism. However, Cornucopia staff will be at the upcoming NOSB meeting to “witness” the proceedings and report back to the organic community. And we will be testifying.

As an example, all the materials of concern to Beyond Pesticides, delineated below, are dubious in terms of their need. Good organic stewardship is about preventing problems with crops and livestock rather than having to remediate them, using chemicals, after the fact. It is quite questionable whether or not these proposals are consistent with the philosophies underpinning organic management (a requirement of law before they are approved).

MAK


Comment by October 4 to Protect Organic Integrity!

The Fall 2018 NOSB meeting dates have been announced and public comments are due by October 4, 2018. Your comments and participation are critical to the integrity of the organic label. Written comments may be submitted through Regulations.gov until 11:59 pm ET October 4, 2018. Reservations for in-person and webinar comments close at the same time.

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 October 4, 2018. On this page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board when it meets in Saint Paul, MN on October 24 – 26, 2018. You can view USDA’s announcement of the NOSB’s meeting and proposals here.

Issues before the NOSB include materials allowed in organic production as well as some policy issues. Materials are either the subject of petitions or the subject of sunset review (concerning whether to be allowed for another 5 years). To be allowed, 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.

Major issues before the NOSB at the Fall 2018 meeting include:

  • Natamycin is an antimicrobial proposed for post-harvest use on organic food crops. It is used in medicine to treat a number of diseases. Natamycin is produced by fermentation, and the NOSB may classify it as a natural material, which would allow its use without restriction. The NOSB should list natamycin on Sections 602 and 604, to prohibit its use in organic crop and livestock production, where use would promote resistance to this medically valuable antimicrobial medication. See Beyond Pesticides draft comments.
  • Allyl isothiocyanate (AITC) is proposed as a crop fumigant. It would be difficult to find a practice less compatible with organic production than soil fumigation with a “broad-spectrum antimicrobial compound that effectively kills both plant pathogens and beneficial soil microorganisms.” Organic production uses practices that feed soil organisms who feed crop plants. It creates healthy soil food webs. Using a toxic chemical to wipe out soil biology is the antithesis of organic practices. The petition for AITC should be rejected because it is hazardous, not essential for organic production, and incompatible with organic practices. See Beyond Pesticides draft comments.
  • Silver Dihydrogen Citrate (SDC) is an antimicrobial with important medical uses that is proposed for use in handling produce and poultry carcasses. Although the proposed annotation eliminates the nanosilver form, SDC poses health and environmental risks –particularly the risk of increasing resistance to antibiotics and other antimicrobials. The petition for SDC must be denied to protect the effectiveness of remaining antimicrobial medications. See Beyond Pesticides draft comments.

Written comments may be submitted through Regulations.gov until 11:59 pm ET October 4, 2018.

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

  1. Select the text in our comments (place your cursor before the first word in the text, then press and hold down the left mouse button and, without releasing the button, move the cursor to the end of the comments).
  2. Copy the selected text by selecting the Ctrl and C keys simultaneously.
  3. Click on this link to open a new tab and in that tab, place your cursor in the “Comment” box.
  4. Paste the comments you copied by selecting the Ctrl and V keys simultaneously.
  5. Personalize your comments before entering your contact information and selecting “Continue”.

More information will be available soon on Beyond Pesticides’ Keeping Organic Strong webpage to learn more about these and other substantive issues, and to provide a unique public comment to the NOSB.

Thank you for helping to protect and uphold organic integrity!

Take action now!

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