Talking Points for Comments Due March 30, 2022

Personalization will make your comments most effective. Tell the regulators why you care!

Comment in the Federal Register
  • The National Organic Program’s failure to implement National Organic Standards Board (NOSB) recommendations is actively eroding organic integrity. The NOP process for taking action on NOSB recommendations must be faster and much more transparent. Without continuous improvement, the organic marketplace is governed by old science and compromised by profit-driven industrial operators.
  • Seventy-one backlogged issues currently require NOP action. Some NOSB recommendations have languished at USDA for almost 20 years. This is a breakdown of the intended process and must be rectified.
  • All languishing NOSB recommendations require NOP attention. These issues are urgent:
    1. Perverse incentive to convert native ecosystems to organic production
    2. Hydroponic/container/greenhouse production standards
    3. Increased use of organic seeds
    4. Recommendations related to genetic engineering and excluded methods
    5. Clarification of emergency synthetic parasiticide use with organic livestock
    6. Organic mushroom production standards
    7. Organic apiculture production standards
  • USDA should reverse the 2013 policy change to the sunset process for synthetic materials on the National List. The current sunset process stifles innovation and continuous improvement. The process change was made unilaterally, without public notice and request for comments, despite its wide-ranging effects on the organic marketplace.
  • The NOP has also failed to make changes to the National List based on NOSB recommendations. In some cases, the NOP has unilaterally “closed” National List recommendations without transparency or adequate justification. There are many unresolved National List issues, including:
    1. Carrageenan: In 2016, the NOSB voted to remove carrageenan from the National List. NOP decided to instead relist the material based on a small number of industry comments without consideration of the NOSB’s justification for its removal. Given how it is processed, carrageenan should be reclassified as a synthetic material and removed from organic products.
    2. Sodium nitrate: In 2011, an NOSB vote addressed sodium nitrate, a high-nitrogen fertilizer produced from mined minerals in an environmentally harmful process, to prohibit its use in organic production. NOP inaction resulted in an “invalid listing,” meaning there are currently no restrictions on the use of sodium nitrate in organic agriculture. Reliance on high-nitrogen fertilizers flagrantly contradicts the soil building practices that are foundational to organic systems.
    3. Natamycin: In 2018, the NOSB voted to prohibit natamycin, a nonsynthetic pesticide used to control fungal diseases. In 2020, the NOP decided to allow the use of this material. Its use can promote microbial resistance, which is concerning because natamycin is used to treat a number of human diseases.
    4. Oxytocin: In 2017, the NOSB voted to remove oxytocin from the National List. In a final rule published on February 28, 2022, the NOP stated that it is relisting oxytocin. Oxytocin is a hormone. The use of a hormone in organic dairy production is contrary to consumer expectations for organic products.
  • The NOSB should have the opportunity to identify and prioritize topics for inclusion in the work agenda that are brought forward by organic stakeholders.