Washington, DC–(ENEWSPF)–September 9, 2013. The National Organic Standards Board (NOSB) is now accepting public comments until October 1, 2013 for its upcoming fall meeting, to be held October 22-24, 2013 at the Galt House Hotel in Louisville, KY (140 North Fourth St., Louisville, KY, 40202). Beyond Pesticides has compiled a list of the issues before the Board, which can be viewed on the Keeping Organic Strong website. We strongly encourage all those concerned about the future of organic food to review the issues and submit a public comment to the NOSB. The 15 member Board meets twice a year to review substances petitioned for allowance on the “National List of Allowed and Prohibited Substances” in organic production and processing.
Beyond Pesticides’ Keeping Organic Strong website provides a number of resources for people to participate in the organic review process alongside the Board. Note that throughout the week, we will be updating the page with sample comments, Beyond Pesticides’ full comments to the Board, and comments from key stakeholders in the organic community.
Written comments on the proposals can be submitted until 11:59 pm on Tuesday, October 1, 2013 at regulations.gov. You can also attend the NOSB meeting in person to provide oral comments before the Board. Pre-registration to provide oral comments must be completed by October 1, 2013. You can register to provide a public comment here.
The NOSB acts as a life-line from the government to the organic community, as it considers input from you, the public – the concerned consumers and residents upon which organic integrity depends. That is why your participation is vital to the development and the continual reassessment of organic standards. Rest assured, if you submit a public comment either in person or online, your concerns will be considered by the Board.
The Board is authorized by the Organic Foods Production Act (OFPA) to make recommendations to the Secretary of Agriculture regarding the “National List of Allowed and Prohibited Substances.” The NOSB also may provide advice on other aspects of the organic program. OFPA and National Organic Program (NOP) regulations provide for the sunsetting of listed substances every five years and rely on public comment in evaluating their continuing uses. Sunset review, the process of reviewing substances on the National List every five years, is mandated by the OFPA. While no substances are up for sunset review at this meeting, there are other key issues related to organic integrity, including the question of whether the antibiotic streptomycin should be phased out next year from organic apple and pear production. There are, for instance, numerous substances that have been petitioned for use in organic production, including synthetic materials that would be used in yet to be defined organic aquaculture. To be added to the list of allowed synthetics, it must be shown that the use of such substances – (i) would not be harmful to human health or the environment; (ii) is necessary to the production or handling of the agricultural product because of the unavailability of wholly natural substitute products; and, (iii) is consistent with organic farming and handling. The public may also file a petition to amend the National List, either by removing a material currently on the list or by adding a new one. In both cases, sunset and petition, the NOSB is authorized by OFPA to determine a substance’s status.
Background on upcoming NOSB Decisions
Streptomycin -The Board will be considering whether its previous decision to phase out streptomycin in organic apple and pear production will take effect next year. Along with tetracycline, streptomycin has been permitted for use to control fire blight. In April 2011, the NOSB voted to put an expiration date of October 21, 2014 on both antibiotics. The tree fruit industry petitioned to restore both materials to the National List. In April 2013, the NOSB voted to uphold the 2014 expiration date for tetracycline, but did not vote on streptomycin. Many issues are the same for the two materials. See Beyond Pesticides’ comments on tetracycline, Comments from the Infectious Diseases Society of America (IDSA), Statement from the IDSA on Resistance and the Pesticides and You articles “Antibiotics in Fruit Production,” “A is for Apples, Alar, and Antibiotics” for more information. At the October 2013 meeting, the NOSB will vote on whether to extend the use of streptomycin by restoring it to the National List with an extended expiration date. Beyond Pesticides opposes the extension of the use of streptomycin.
Synthetic materials in organic aquaculture -The Board is also considering allowed synthetic materials under yet to be established organic aquaculture standards. At the October meeting, the NOSB will decide on proposals relating to synthetic chlorine, tocopherols, vitamins, and trace minerals as inputs in organic aquaculture systems, when the National Organic Program (NOP) issues aquaculture rulemaking. NOP has not yet proposed regulations defining organic aquaculture systems. All of these materials are petitioned for routine use rather than under defined conditions when natural feeds are insufficient. Beyond Pesticides opposes the listing of any synthetics for routine use and the listing of any synthetic materials for use in aquaculture until regulations defining organic aquaculture systems have been adopted in final form and can be assessed in relation to previous board policy and the petitioned materials.
Public comments are critical to maintaining organic integrity
Please check back as we will be updating our Keeping Organic Strong webpage with more detailed information. And, as we raise our voices to protect organic integrity, don’t forget the big picture: Organic agriculture is an ecologically-based management system that prioritizes cultural, biological, and mechanical production practices and natural inputs by strengthening on-farm resources, such as soil fertility, pasture and biodiversity. As opposed to conventional chemical agriculture, where there are tens of thousands of synthetic materials, including over 200 registered pesticide active ingredients, there are currently only around 50 entries on the “National List” of allowable synthetics. And all of these products have been reviewed for their human and environmental health effects, essentiality to organic production, and their compatibility with the values of organic as it pertains to the Organic Foods Production Act. To maintain this high standard, the public must maintain a strong voice in the organic review process.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.