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• Last Chance This Spring To Tell the NOSB To Uphold Organic Integrity

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Join Beyond Pesticides in commenting on priority issues that protect health and the environment for the upcoming meeting of the National Organic Standards Board (NOSB). The NOSB is receiving written comments from the public on key issues. This precedes the upcoming public comment webinar on April 23 and 25 and deliberative hearing April 29 through May 1—concerning how organic food is produced. >>Written comments must be submitted by 11:59 pm EDT April 3 through the link provided here and below! Sign up for a 3-minute comment to let U.S. Department of Agriculture (USDA) know how important organic is at the webinar by April 3. Links to the virtual comment webinars will be provided approximately one week before the webinars.  

As a means of taking on the challenges of health threats, biodiversity collapse, and the climate emergency, the review and updating of organic standards requires public involvement in the current public comment period. This is required to keep organic strong and continually improving. Organic maintains a unique place in the food system because of its high standards and the ongoing opportunity for continuous improvement through transparency and public involvement. But we will only keep organic strong and growing stronger if we participate in voicing our position on key issues to the stakeholder advisory board, the NOSB. We have identified key issues for the upcoming NOSB meeting below. 

>>Click here to submit your written comment to the National Organic Standard Board by April 3.

The NOSB is responsible for guiding USDA in its administration of the Organic Foods Production Act (OFPA), including the materials allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health. There is no other food label category that is defined and codified in federal law, fully embraces health and biodiversity protection and enhancement, offers ongoing opportunities for public input and oversight, and is enforced with an inspection and certification system. Your comments help to make our food system what we need it to be for health, regenerative practices, and sustainability of the planet. 

A draft meeting agenda is available here.  And a detailed agenda, along with the proposals, are available here. 

Written comments are due by 11:59 pm ET on Wednesday, April 3, 2024, as well as registration for oral comments. Oral comment sign-ups fill up fast! >> Sign up for oral comments here.  

The NOSB plays an important role in bringing the views of organic consumers and producers to bear on USDA, which is not always in sync with organic principles and not giving sufficient support to the critical need to end the use of petrochemical pesticides and fertilizers. There are many important issues on the NOSB agenda this Spring. For a complete discussion, see Keeping Organic Strong and the Spring 2024 Beyond Pesticides' issues webpage.  

Here are some of our high priority issues for the upcoming NOSB meeting (see others here):

• Make elimination of plastic in organic a research priority. Plastic is found in every facet of organic production and handling. Yet, the human and environmental health implications of plastic are becoming increasingly well documented. We need research into ways to replace all forms of plastic in organic production and handling.
  
  Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment. 
  
  Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products.
  
  The average liter of three brands of bottled water in the U.S. contains almost a quarter of a million bits of microplastics (of which 90% are at the nanoscale) with a majority containing unidentifiable chemicals. The number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified because they were not listed in the major chemical substance databases. When they exposed cod eggs, embryos, and larvae to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans.
  
  Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta. 
  
  

• Remove toxic nonylphenol ethoxylates from teat dips. Iodine, whose use in teat dips will be considered for relisting, is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), in the class known as alkylphenols and their ethoxylates, are strong endocrine disruptors with impacts on many species, including gender changes. A number of alternatives are available. NPEs were banned in Europe ten years ago (in all products), and China has banned dairy product imports with NPE residues above 10 ppb. There are many commercially available non-NPE iodine-based disinfectants and teat dips that can be used instead. Iodine “without alkylphenols or alkylphenol ethoxylates” should only be listed. 

• Improve the science upon which the NOSB bases decisions. The NOSB Policy and Procedures Manual (PPM) states, “A Subcommittee cannot proceed with a recommendation to list a material if it is determined that there is insufficient valid scientific information on that material's impact on the environment, human health and its compatibility with organic principles.” When proposals have been based on Technical Reviews using the current template, they have frequently contained inadequate scientific support. These shortcomings often involve ancillary substances, nanoparticles, and excluded (GE) methods. The changes proposed on the agenda will improve the NOSB's ability to make decisions based on science. 

>> Click here to submit your written comment to the National Organic Standard Board by April 3. 

The targets for this Action are the U.S. National Organic Standards Board, a federal advisory board of dedicated public volunteers from across the organic community under the U.S. Department of Agriculture's Agricultural Marketing Service.

Thank you for your active participation and engagement!

Comment to the NOSB:

Dear NOSB, 

Please consider the following: 

(1) Make elimination of plastic in organic a research priority. 

Plastic is found in every facet of organic production and handling despite adverse effects to human and environmental health. We need research to replace all forms of plastic in organic. 

Microplastics—plastic fragments less than 5 mm in size—are of increasing concern because they can cause harmful effects to humans and other organisms and act as carriers of toxic chemicals that are adsorbed to their surface. Studies on fish have shown that microplastics and their associated toxic chemicals bioaccumulate, resulting in intestinal damage and changes in metabolism. Microplastics can increase the spread of antibiotic resistance genes in the environment.  

Plastics are introduced into the environment directly from sources like plastic mulches (including biodegradable bioplastic). Soil organisms and edible plants ingest microplastic particles. Earthworms can move microplastics through the soil and through the food chain to human food. Their wide range of negative impacts on the soil include reduction in growth and reproduction of soil microfauna. They can carry toxic chemicals and can increase the spread of antibiotic resistance genes in water and sediments. Highly hazardous PFAS (per- and polyfluoroalkyl substances) are leaching out of plastic containers and contaminating food products. 

A bottled water study finds almost a quarter of a million bits of microplastics (of which 90% are at the nanoscale) with a majority containing unidentifiable chemicals. The number of individual chemical compounds varies wildly among products, ranging from 114 to 2,456 in one study. Another study analyzed components of 50 items in common use, finding many hazardous chemicals in the plastics as well as many that could not be identified. When cod eggs, embryos, and larvae are exposed to water containing microplastics, toxic effects included spinal deformities reminiscent of scoliosis in humans. 

Polyethylene was detected in carotid artery plaque of 150 out of a total of 257 patients (58.4%), with a mean level of 2% of plaque; 31 patients (12.1%) also had measurable amounts of polyvinyl chloride, with a mean level of 0.5% of plaque. Microplastic particles have been found in human lungs, blood, feces, breast milk, and placenta. 

(2) Remove toxic nonylphenol ethoxylates from teat dips. 

Iodine, whose use in teat dips will be considered for relisting, is frequently formulated as iodophors—with surfactants or complexing agents. Iodophors containing nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), in the class known as alkylphenols and their ethoxylates, are strong endocrine disruptors with impacts on many species, including gender changes. A number of alternatives are available. NPEs were banned in Europe ten years ago (in all products), and China has banned dairy product imports with NPE residues above 10 ppb. There are many commercially available non-NPE iodine-based disinfectants and teat dips that can be used instead. Iodine “without alkylphenols or alkylphenol ethoxylates” should only be listed. 

(3) Improve the science upon which the NOSB bases decisions. 

The NOSB Policy and Procedures Manual (PPM) states, “A Subcommittee cannot proceed with a recommendation to list a material if it is determined that there is insufficient valid scientific information on that material’s impact on the environment, human health and its compatibility with organic principles.” When proposals have been based on Technical Reviews using the current template, they have frequently contained inadequate scientific support. These shortcomings often involve ancillary substances, nanoparticles, and excluded (GE) methods. The changes proposed on the agenda will improve the NOSB’s ability to make decisions based on science. 

Thank you for your consideration of my comments.