(Beyond Pesticides, March 22, 2016) Make your voice heard! The public comment period has opened on National Organic Standards Board (NOSB) proposed recommendations affecting organic standards, materials and policy. Comments are due by April 14, 2016 at 11:59 PM. As usual, there are many important issues that are under NOSB consideration. Your voice is integral to maintaining organic integrity and the value of the USDA organic label.

We have begun to analyze the numerous recommendations and are providing you with our positions that we hope you will use as the basis for your comments. We will provide positions on additional topics in the near future. Please feel free to develop your own comments or cut and paste ours from the following web page: Top Priority Issues.

Unfortunately, the only way to make your voice heard is to submit your comments to regulations.gov. If you cut and paste our comments into regulations.gov on major issues before the NOSB (below), please put a personal note of concern in order to reflect the importance if these issues to you as an organic consumer, farmer.

Some of the major issues before the spring 2016 National Organic Standards Board include:

”¢ Inerts

Three items on the NOSB agenda concern so-called “inert” ingredients in pesticides —sunset of List 3 “inerts,” a discussion document on the prohibition of nonylphenol ethoxylates as List 4 “inerts,” and a verbal update from the Inerts Working Group. (1) The NOSB must take the sunset review of List 3 “inerts” seriously. The NOSB must do a full review of these chemicals, which it previously recommended to come off the list at the end of last year, but are likely to remain on for at least 5 more years without action at this meeting. (2) The NOSB should move as expeditiously as possible in recommending an end to the use of endocrine-disrupting nonylphenol ethoxylates (NPEs). The evidence shows the dangers of NPEs, and alternatives are available. Postponing will not prevent formulators from procrastinating. (3) The fall 2015 recommendation on the “inerts” annotation must be implemented in a way that ensures NOSB participation in the initial review and future sunset review of the chemicals.



”¢ Sanitizers

There are three proposals to list hypochlorous acid —for use in crops, handling, and livestock””and another petition for use of sodium dodecylbenzene sulfonate in handling that are under consideration. While both materials offer some advantages over currently allowed materials, the NOSB lacks a frame of reference for deciding which sanitizing agents are needed in organic production. Sanitizers do not always offer improvements in health, and I urge the NOSB to do a comprehensive survey of needs for sanitizing agents before adding more to the National List. I suggest that the NOSB investigate sanitizers approved for EPA’s Safer Chemical Ingredients List —most of which are already allowed in organic production””as alternatives to harsher chemicals.



”¢ Ancillary Substances

Ancillary substances are added to ingredients found in organic foods to achieve some effect in those ingredients –preservative, adjusting moisture, even pest control. The NOSB adopted a policy in 2013 that all ancillary substances would be reviewed according to OFPA criteria, but the Handling Subcommittee has simply been listing those ancillary substances known to be in use. Now the Handling Subcommittee is proposing to modify the policy. (1) Definitions are needed. In order to be meaningful and useful, the ancillary substances policy must define terms it uses: technical or functional effect, direct food additive, incidental food additive, food contact substance, functional class, and significant amount. (2) Each ancillary substance must be approved for each particular use. Whether the approval of ancillary substances is communicated by means of listing on the National List —which we believe to be required by OFPA””or by other means, each ancillary substance must be reviewed according to OFPA criteria. The NOSB must not categorically allow substances in a functional class that have not been specifically reviewed and it must not rubber stamp ancillary substance just because they are currently in use.



”¢ Carrageenan

I oppose the relisting of carrageenan on §205.605(a) and believe that the substance should be removed from the National List. Carrageenan should be reclassified as a synthetic. This use does not meet the requirements of the Organic Food Production Act ””carrageenan may have adverse effects on the health of consumers, its production results in adverse ecological impacts, there are alternatives to its use, and its use is inconsistent with a system of organic and sustainable production. Independent scientists have presented evidence to the NOSB demonstrating inflammatory impacts of carrageenan. Due to consumer concerns about the use of carrageenan in organic products, it has been removed from many, and every product containing carrageenan is available without it —demonstrating the lack of essentiality.



”¢ Parasiticides

In reviewing all three parasiticides together, livestock subcommittee failed to bring forward motions to remove ivermectin and moxidectin due to adverse ecological effects. This would have allowed the NOSB to consider the full range of actions that have been supported by public comment. As noted in comments from former NOSB member Dr. Karreman, the intention of the NOSB in approving fenbendazole was to allow for the removal of ivermectin and possibly moxidectin. Since such an action at this meeting would be prohibited as a substantive action not proposed for public comment, these proposals should be referred back to the subcommittee, to return with proposals that address the full range of actions supported by the available evidence.

Please go to Beyond Pesticides’ Keeping Organic Strong webpage to learn more about these and other substantive issues and provide a unique public comment.

We ask that you submit comments on as many issues and materials as you can by the April 14, 2016 deadline . For help crafting your comments, view Beyond Pesticides’ commenting guide.

Thank you for standing up to keep organic strong!

All unattributed positions and opinions in this piece are those of Beyond Pesticides.