Recap Of Public Comments Submitted To The
Recap of Public Comments Submitted to theNational Organic Standards BoardSpring 2014 MeetingApril 29 – May 2San Antonio, TexasCompiled by the staff of The Cornucopia Institute
How to Use This DocumentFor the benefit of National Organic Standards Board members, and other organic stakeholders, The CornucopiaInstitute has endeavored to compile, as accurately and objectively as possible, a recap of all formal writtencomments pursuant to the Spring 2014 NOSB meeting. This also includes comments made in advance of thecancelled Fall 2013 meeting.Cornucopia greatly appreciates the work, dedication and enormous time commitment required to serve on theNOSB. Our hope is to provide a valuable resource for the Board better enabling members to understand thescope and sentiment of organic industry participants, including: FarmersCitizensPublic Interest GroupsFood ProcessorsHandlersManufacturers DistributorsRetailersTrade AssociationsIndustry ConsultantsOrganic CertifiersThis document is organized by NOSB Subcommittee, in the order presented on the Draft Agenda. Under eachagenda item, a table shows the number of comments submitted and the various stakeholder positions on thatitem. The “Notes” section under each table provides additional explanation.Thank you for your work on behalf of all organic stakeholders. Please feel free to contact us regarding any of ourfindings or our methodology.Will FantleResearch DirectorThe Cornucopia Institute2
CROPS SUBCOMMITTEEStreptomycinMotion: To remove the expiration date of October 21, 2014 for streptomycin andreplace that with a new expiration date of October 21, 2017Petitioned by: Washington State Horticultural Association,California Pear Advisory Board, U.S. Apple Association, Michigan State Horticultural SocietyPurpose: Antibiotic to control Erwinia amylovora (fire blight) on apples and pearsSupport (Retain on the List)Farmers / CitizensPublic Interest GroupsNoneCitizen PetitionsNoneFood Processors /HandlersDistributors / RetailersNoneTrade Associations /Consultants / ResearchersCertifiersUNFI (Melody Meyer)Organic Produce Wholesalers Coalition(OPWC) – Neutral (1)Organic Trade AssociationOrganic Tree Fruit AssociationDavid GranatsteinCalifornia Certified Organic FarmersPennsylvania Certified OrganicWSDA Organic Food Program – NeutralOppose (Allow to Expire in 2014)403 (on www.regulations.gov)Beyond PesticidesCalifornia Safe SchoolsCenter for Food Safety (CFS) (2)Consumers UnionCornucopia Institute (3)Food & Water Watch (FWW)National Organic CoalitionNo Spray ZoneOrganic Consumers Association (OCA)CFS – 30,498 signaturesFWW – 12,427 signaturesOCA – 39,851 signaturesNature’s PathNoneInfectious Disease Society of AmericaNone3
Notes:(1) OPWC is neutral but urges the NOSB to “recognize the production challenges.”(2) CFS states: “The risks of using Streptomycin are even clearer than those from using tetracycline, whichthe NOSB voted to allow to sunset at its April 2013 meeting.”(3) Cornucopia states: “From an organic perspective, the systems approach should be the first line of defenseagainst fire blight, because a properly designed system will have less disease.”Magnesium OxideMotion: Magnesium oxide (MgO) has been petitioned for use under §205.601Petitioned by: Mesa Verde ResourcesPurpose: To control the viscosity of a clay suspension agent for humatesFarmers / CitizensPublic Interest GroupsFood Processors / Handlers /ManufacturersDistributors / RetailersTrade AssociationsCertifiersSupportNoneNoneCROPP CooperativeOppose5Beyond Pesticides (BP) (1)Cornucopia Institute (1)California Safe SchoolsNoneNoneNoneNoneNoneNoneNoneNote:(1) BP and Cornucopia both support the Crops Subcommittee’s following annotation: “Until May 1, 2019 (or5 years after the date it is first allowed).”4
VinasseMotion: To classify Vinasse as nonsynthetic.Motion: To add language to the listing of Vinasse in the Guidance on Materials for Organic Crop Production(NOP 5034-1). Minority opinion is stated below (1).Petitioned by: BioBizz WorldwidePurpose: Fertilizer for organic crop productionFarmers / CitizensPublic Interest GroupsFood Processors / Handlers /ManufacturersDistributors / RetailersTrade alifornia Certified Organic FarmersOrganic Materials Review InstitutePennsylvania Certified OrganicOppose3Beyond Pesticides (BP) (2)Cornucopia InstituteNational Organic Coalition (NOC) (3)NoneNoneNoneNoneNotes:(1) Minority Opinion: Identifying the allowed and prohibited formulations of vinasse through the NationalList process is the appropriate action for the NOSB. The minority proposes to create a hybrid listing onboth 601 and 602, explaining in the recommendation that vinasse is available in both synthetic andnonsynthetic forms.(2) BP states: “We urge the NOSB to (i) send the classification question back to the CS for action as describedabove, (ii) ask the subcommittee to identify the synthetic form of vinasse based on criteria thatdistinguish synthetic from nonsynthetic vinasse, and (iii) request that the subcommittee complete areview of synthetic vinasse to determine compliance with the checklist criteria under OFPA and proposea 205.601 recommendation.”(3) NOC notes: “[T]he main issue [is] related to the classification of these substances as synthetic ornonsynthetic. [This] is indicative of the strong need for a clearly defined policy on Classification ofMaterials.”5
LaminarinMotion: Motion to classify Laminarin as nonsyntheticPetitioned by: Laboratoires Goëmar SAPurpose: Pesticide that stimulates plant’s natural defense mechanismsFarmers / CitizensPublic Interest GroupsFood Processors /Handlers / ManufacturersDistributors / RetailersTrade neNoneOppose3Beyond Pesticides (BP) (1)Cornucopia InstituteNational Organic Coalition (NOC) (2)NoneNoneNoneNoneNoneNoneNoneNoneNoneOrganic Materials Review Institute(OMRI) (3)Pennsylvania Certified OrganicNoneNotes:(1) BP comments: “Determining as nonsynthetic substances formulated with high levels of sulfuric acidresulting in high levels of sulfate sets a bad precedent for future synthetic-nonsynthetic decisions.”(2) NOC asserts that “a policy on Classification of Materials is an essential part of the infrastructure of theorganic industry. We think a defined policy would benefit all organic stakeholders through more uniformimplementation of the synthetic/nonsynthetic definition at each juncture at which materials are used andevaluated.”(3) OMRI suggests that the sodium sulfate residues left over in the extract should be evaluated as an inertingredient.6
Sulfurous AcidDiscussion: Sunset Review. Comments regarding relisting on §205.601Purpose: As a plant or soil amendmentFarmers / CitizensPublic Interest GroupsFood Processors / Handlers /ManufacturersDistributors / RetailersTrade AssociationsCertifiersRenew (Retain on List)Driscoll’sGarrett FarmsGrimmway Farms/Cal-Organic (GF/CO) (1)Reiter BrothersNoneDo Not Renew194 (all consumers)Terry Gong (2)Beyond PesticidesCornucopia InstituteCalifornia Safe SchoolsNoneNoneNoneCalifornia Certified Organic FarmersNoneNoneNoneNotes:(1) GF/CO’s comment states: “Sulfurous Acid is a very specific tool that is very helpful to arid regiongrowers.”(2) Gong submitted the original petition for Harmon Systems International (HSI), the manufacturer of H2SO3generators.7
Sodium Carbonate PeroxyhydrateDiscussion: Sunset Review. Comments regarding relisting on §205.601Purpose: As an algaecideFarmers / CitizensPublic Interest GroupsFood Processors /Handlers /ManufacturersDistributors /RetailersTrade AssociationsCertifiersRenew (Retain on List)NoneNoneNeutral/Seeks ClarificationNoneNoneBioSafe Systems (BSS) (1)Do Not Renew194Beyond Pesticides (2)Cornucopia InstituteCalifornia Safe SchoolsNoneNoneNoneNoneNoneCalifornia Certified OrganicFarmersNoneNoneNoneOrganic Materials ResearchInstituteNoneNotes:(1) BSS states: “CA Rice Commission has approved of the use of sodium carbonate peroxyhydrate in CA Riceand recognizes the need for an alternative to copper based chemistries due to concerns about thecontinued build up of elemental copper in the Sacramento and San Francisco water sheds.”(2) BP states: “It has been found by the NOSB in its 2007 recommendation not to meet the OFPA criteria ofessentiality, compatibility with organic production, and no impacts on human health and theenvironment.”8
Aqueous Potassium SilicateDiscussion: Sunset Review. Comments regarding relisting on §205.601Purpose: As an insecticideFarmers / CitizensPublic Interest GroupsFood Processors / Handlers /ManufacturersDistributors / RetailersTrade AssociationsCertifiersRenew (Retain on List)1NoneNoneDo Not Renew196Beyond Pesticides (BP) (1)Cornucopia InstituteCalifornia Safe SchoolsNoneNoneNoneCalifornia Certified Organic FarmersNoneNoneNoneNote:(1) BP states: “It has been found by the NOSB not to meet the OFPA criteria of essentiality and compatibilitywith organic production.”9
LIVESTOCK SUBCOMMITTEESynthetic Methionine in Organic Poultry FeedMotion: To revise the current listing of synthetic methionine (MET) on the National List §205.603 to read: “foruse only in organic poultry production at the following maximum average pounds per ton of100% synthetic methionine in the diet over the life of the flock: Laying and broiler chickens – 2 pounds; Turkeysand all other poultry – 3 pounds.Petitioned by: Livestock SubcommitteePurpose: Essential amino acid for poultryFarmers / CitizensPublic Interest GroupsFood Processors / Handlers /ManufacturersDistributors / RetailersTrade AssociationsCertifiersSupport1Cornucopia Institute (1)California Natural ProductsCashton Farm SupplyFarmers HenhouseCROPP CooperativeCountry Egg Hen FarmKreher’s Sunrise FarmColeman Natural FoodsBC Natural ChickenUNFIMethionine Task Force (MTF) (2)Organic Egg Farmers of AmericaOrganic Trade AssociationUnited Egg ProducersCalifornia Farm Bureau FederationWashington State Dept. of AgricultureMidwest Organic Services AssociationPennsylvania Certified OrganicOregon TilthOppose3Beyond PesticidesCenter for Food SafetyConsumers UnionFood & Water WatchNational Organic CoalitionCalifornia Safe SchoolsNo Spray ZoneNoneNoneNoneNone10
Notes:(1) Cornucopia supports the language revision but also wants the NOSB to commit to aggressive researchinto alternative management and feed supplements as well as a commitment to Sunset syntheticmethionine in 2019.(2) The MTF proposes a slight increase in methionine for layer and broiler chickens to 2.5 lbs. per tonbecause they feel the step-down was too drastic for chickens and is causing some serious healthproblems.(3)Acidified Sodium ChloriteMotion: To list Acidified Sodium Chlorite at §205.603(a) and §205.603(b) of the National List annotated asfollows: “Acidified Sodium Chlorite, allowed for use on organic livestock as a pre and post teat dip treatment,acidified with lactic acid or other GRAS acid.” Livestock Subcommittee voted to deny this motion.Petitioned by: Ecolab, Inc.Purpose: Disinfect cow teatsFarmers / CitizensPublic Interest GroupsFood Processors / Handlers/ManufacturersDistributors / RetailersTrade AssociationsCertifiersSupportDaniel Giacomini (1)NoneSelect Sire Power, Inc.Oppose3Beyond PesticidesCornucopia InstituteCalifornia Safe SchoolsNoneNoneNoneNoneNoneNoneNoneNote:(1) Giacomini, an animal nutritionist and former NOSB member, believes that Acidified Sodium Chlorite is abetter product than the alternatives.11
Aquaculture: AnimalsAll Materials SummaryMotion: To add the following items to the National List §205.611 for aquatic animal production:Chlorine, Tocopherols, Minerals, Vitamins, and VaccinesPetitioned by: Aquaculture Working GroupPurpose: Inputs to support animal aquacultureFarmers / Citizens / FishermenSupportNoneOppose230 (2)Public Interest GroupsNoneCitizen PetitionsFood Processors / Handlers /ManufacturersDistributors / RetailersTrade AssociationsCertifiersNoneNoneBeyond PesticidesCenter for Food SafetyConsumers UnionCornucopia InstituteFood & Water Watch (FWW)National Organic CoalitionNo Spray Zone11,880 signatures gathered by FWWNoneNoneAquaculture Working GroupOregon Tilth (OT) (1)PCC Natural MarketsOrganic Trade Association (OTA) (3)Maine Organic Farmers & Gardeners AssociationNotes:(1) OT recommends approving aquaculture materials because they are already certifying some aquacultureoperations. They state in their comments, “Certifiers, Accreditors, and Organic Growers appreciateconsistency wherever possible; especially when a material is permitted in multiple sections of theNational List.”(2) Much of the consumer opposition registered the same sentiment as this comment: “Organic shouldmean something incorruptible about the quality of our food. Farmed fish feedlots damage marineecosystems and harm wild fish populations. Disease, parasites, pollution, escapees all threaten wild fishthat live in proximity even briefly to industrial fish pens. The aquaculture industry’s efforts to address12
these problems with vaccines, antibiotics, synthetic feed, chlorine, will invite mockery of the term‘organic’ if it labels farmed fish.”(3) OTA suggests that the Livestock Subcommittee table the recommendations on materials petitioned foruse in organic aquaculture until a proposed rule has been released by NOP. All the other public interestgroups have taken a similar stance.Aquaculture: CropsAll Materials SummaryMotion: To add the following items to the National List §205.609 for aquatic crop production:Micronutrients, Carbon Dioxide, Chlorine, Lignin Sulfonate, and Vitamins B1, B12, and HPetitioned by: Aquaculture Working GroupPurpose: Inputs to support crop aquacultureFarmers / Citizens / FishermenSupportNoneOppose230Public Interest GroupsNoneFood Processors / Handlers /ManufacturersDistributors / RetailersTrade AssociationsCertifiersNoneBeyond PesticidesCornucopia InstituteFood & Water WatchNational Organic CoalitionNoneNoneAquaculture Working GroupOregon Tilth (OT) (1)NoneOrganic Trade Association (OTA) (2)NoneNotes:(1) OT recommends approving crop aquaculture materials (with the exception of Carbon Dioxide) becausethey are already certifying some aquaculture operations. They state in their comments, “Certifiers,Accreditors, and Organic Growers appreciate consistency wherever possible; especially when a materialis permitted in multiple sections of the National List.”(2) OTA suggests that the Livestock Subcommittee table the recommendations on materials petitioned foruse in organic aquaculture until a proposed rule has been released by NOP. All the other public interestgroups have taken a similar stance.13
HANDLING SUBCOMMITTEEAmmonium HydroxideMotion: To add to the National List §205.605Petitioned by: Richard TheurerPurpose: Boiler additive to prevent corrosionFarmers / CitizensPublic Interest GroupsFood Processors / HandlersIngredient Suppliers / MaterialManufacturersDistributors / RetailersTrade Associations / IndustryConsultantsCertifiersSupportNoneCornucopia Institute (4)NoneNoneNoneRichard Theurer (1)Wolf, DiMatteo and AssociatesNoneOppose60 (2)Beyond Pesticides (BP) (3)Consumers Union (CU) (3)National Organic Coalition (NOC) (3)NoneNoneNoneNoneNoneNotes:(1) Theurer states: “The Handling Subcommittee fails to distinguish between the manageable hazard ofammonium hydroxide added to a boiler in a factory and the absence of any risk created by consumptionof a food product containing a few parts per million of ammonium carbonate contributed by condensatewater. Currently ammonia is permitted in the treatment of water that becomes part of processed foodlabeled as “organic” under 7 U.S.C. 6510 (a)(7).”(2) The public comments state ammonium hydroxide is “toxic to the environment and humans.”(3) BP, CU and NOC state that the substance is a “severe irritant” and presents a “serious toxicologicalconcern.”(4) Cornucopia cites the GRAS status of Ammonium Hydroxide as a food ingredient and its appearance to bea less potentially toxic material than other boiler treatments already on the List. Based on survey workwe are in the process of completing, the large majority of boiler operators claim that boiler additives areessential for proper maintenance.14
GlycerinMotion: To remove glycerin from the National List as an allowed non-agricultural synthetic §205.605(b)Petitioned by: Draco Natural ProductsPurpose: Food additiveFarmers / CitizensPublic Interest GroupsFood Processors / HandlersIngredient Suppliers / MaterialManufacturersSupport (Remove from List)6 citizensBeyond Pesticides (BP) (1)Consumers UnionCornucopia InstituteNational Organic Coalition (NOC)Elan, Inc.Draco Natural ProductsMarroquin Organic International, Inc.NoneDistributors / RetailersTrade Associations /ConsultantsNoneNoneCertifiersOregon TilthOppose (Retain on List)NoneNoneNoneCalifornia Natural ProductsVantage OleochemicalsVitusa Products, Inc.Flavor and Extract ManufacturersAssociation of the United StatesNoneOrganic Trade Association (OTA) (2)Environment Health SustainabilityQAINotes:(1) BP notes that glycerin is also listed on §205.603 as a teat dip and asks if it is possible to also remove glycerinfrom §205.603.(2) OTA raises three concerns: 1. The supply of organic glycerin may not be adequate at this time; 2. It must bemade clear that the removal of nonagricultural synthetic glycerin from the National List on §205.605(b)does not preclude the allowance of nonorganic (non-synthetic) agricultural forms in NOP certified “madewith” products, or in NOP compliant ingredients such as natural flavors; and 3. the NOSB is advised to retainglycerin on § 205.605(b) (non-agricultural synthetic) with an annotation requiring organic forms in organicproducts unless commercially unavailable, and add glycerin to § 205.606 (non-organic agriculturalingredients allowed in organic products when organic forms are unavailable) of the National List. This wouldrecognize agricultural forms of glycerin and accordingly allow for the use of non-organic agricultural glycerinin “made with products.”15
Polyalkylene Glycol Monobutyl Ether (PGME)Discussion Document: To determine if it is necessary to petition PGME for addition to §205.605 (b).To determine whether PGME is used in direct contact with organic products.Petitioned by: Pellet Products, Inc.Purpose: Boiler additiveFarmers / CitizensPublic Interest GroupsFood Processors / HandlersIngredient Suppliers / MaterialManufacturersDistributors / RetailersTrade AssociationsCertifiersSupport (Allow without Petition)NoneNonePellet Products, Inc.NoneOppose (Needs to be Petitioned)4Beyond Pesticides (BP) (1)Cornucopia Institute (1)Consumers Union (CU) (1) (2) (3)NoneNoneNoneNonePennsylvania Certified OrganicNoneNoneNoneNotes:(1) BP, CU andCornucopia state that PGME needs to be petitioned, reviewed and approved before it canbe allowed in organic feed production.(2) CU writes that organic certification is systems based, and all synthetic inputs used in the process,from field to fork, regardless of “contact with organic products” or residues in the final product, mustbe approved for use.(3) CU states that the petitioner should be instructed to petition PGME for §205.603 – “Syntheticsubstances allowed for use in organic livestock production,” rather than §205.605.16
Gellan GumDiscussion: Sunset Review. Comments regarding relisting of High-Acyl Gellan Gum on §205.605(a)Petitioned by: Nordic SugarPurpose: Food additiveFarmers / CitizensPublic Interest GroupsFood Processors / HandlersIngredient Suppliers / MaterialManufacturersDistributors / RetailersTrade AssociationsCertifiersSupportNoneNoneCROPP Cooperative (1)Hain Celestial Group (HCG) (2)StonyfieldCP KelcoNoneJuice Products AssociationAssociation for Dressings and SaucesInternational Food Additives CouncilQAIOppose6Beyond PesticidesConsumers Union (CU) (3) (4)Cornucopia InstituteNational Organic CoalitionNoneNoneNoneNoneNoneNotes:(1) CROPP states: “We have removed carrageenan from our products,
National Organic Coalition No Spray Zone Organic Consumers Association (OCA) Citizen Petitions None CFS – 30,498 signatures FWW – 12,427 signatures OCA – 39,851 signatures Food Processors / Handlers None Natures Path Distributors / Retailers UNFI (Melody Meyer) Organic Produce Wholesalers Coalition (OPWC) – Neutral (1) None
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