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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 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 National Organic Standards Board (NOSB). We have identified key issues for the upcoming NOSB meeting below!

The NOSB is receiving written comments from the public on key issues through April 3, 2024. This precedes the upcoming public comment webinar on April 23 and 25 and the deliberative hearing on April 29 through May 1—concerning how organic food is produced. Written comments must be submitted by 11:59 pm EDT on April 3 through the "click-and-submit" form below or via Regulations.gov.

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.  

>>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. 

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.  

Some of our high priority issues for the upcoming NOSB meeting: 

• Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production. Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers. 
  
  Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don't know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.” Biosolids—fortunately never allowed in organic production—should be a lesson to remember. 

• Eliminate nonorganic ingredients in processed organic foods as a part of the sunset review. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials. 
   
• Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment. The NOSB has passed repeated recommendations instructing USDA's National Organic Program (NOP) to replace the generic listings for “inerts” that may be biologically and chemically active (currently using EPA Lists 3, 4A, and 4B “inerts”) with specific substances approved for use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.
  
  OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients, but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.
  
  A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose a hazard. The NOSB and NOP must act on “inerts” NOW and meet the standards of the Organic Foods Production Act. 

>>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!

Comments (via Regulations.gov)

I would like to address three priority issues in this comment that are of concern to me as a stakeholder in organic.

(1) Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production.

Compost made in organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List—that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers.

Both organic and nonorganic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids not known to be a source of “forever chemicals.” Biosolids—fortunately never allowed in organic production—should be a lesson to remember.

(2) Eliminate nonorganic ingredients in processed organic foods as a part of the sunset review.

Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials.

(3) Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment.

The NOSB has passed repeated recommendations instructing USDA’s National Organic Program (NOP) to replace the generic listings for “inerts” that may be biologically and chemically active (currently using EPA Lists 3, 4A, and 4B “inerts”) with specific substances approved for use. NOP must allocate resources for this project. Recent appropriations have increased for NOP, and some of this money must be used for the evaluation of “inert” ingredients to ensure compliance with the law and to maintain the integrity of the USDA organic label.

OFPA provides stringent criteria for allowing synthetic materials to be used in organic production. In short, the NOSB must judge—by a supermajority—that the material would not be harmful to human health or the environment, is necessary to the production or handling of agricultural products, and is consistent with organic farming and handling. These criteria have been applied to “active” ingredients, but not to “inert” ingredients, which make up the largest part of pesticide products—up to 90% or more.

A comparison of the hazards posed by active and “inert” ingredients used in organic production reveals that in seven of 11 categories of harm, more “inerts” than actives pose the hazard. The NOSB and NOP must act on “inerts” NOW and meet the standards of the Organic Foods Production Act.

Thank you for your consideration of my comments.