Last Chance This Fall to Tell the NOSB To Uphold Organic Integrity – Beyond Pesticides

23Sep

(Beyond Pesticides, September 23-26, 2022) Comments are due 11:59 pm EDT September 29. The National Organic Standards Board (NOSB) is receiving written comments from the public through September. This precedes the upcoming public comment webinar on October 18 and 20 and deliberative hearing October 25-27concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov by 11:59 pm EDT September 29. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October.

For a complete discussion, see Keeping Organic Strong and the Fall 2022 issues page. In the spirit of continuous improvement, we urge you to submit comments (please feel free to use our comments on the KOS page) that contribute to an increasingly improved organic production system. Here are some high priority issues for us:

> The NOSB must take a precautionary approach in view of the unknown. Peroxylactic acid (POLA) is petitioned as an antimicrobial agent to be used in processing meat. While a comprehensive review of the needs for sanitizers and disinfectants in organic processing may reveal a need for additional materials, the existing data concerning POLA is incomplete, depending mainly on patents rather than peer-reviewed research. The petition should not be allowed.

> Genetic engineering is considered an excluded method according to organic regulations. The NOSB should continue to catalog excluded methods, and their use should be excluded at all levels of productionfrom crop production through inputs in processing.

> Organic Agriculture is Climate-Smart Agriculture. The NOSB draft letter to Secretary of Agriculture Vilsack is an excellent primer on how organic agriculture responds to the climate emergency. However, the letter needs to stress the need for USDA to promote conversion to organic farming. More important to addressing the climate crisis than the questions posed by NOP are questions concerning how USDA programs can assist organic producers and those seeking to convert to organic. The draft letter addresses these as well. It also points out the resiliency of organic agriculture: Organic is the solution to mitigating climate change and responding to it.In view of the climate benefits of organic and the incentives inherent in organic marketing, the real question is whether USDA will abandon its promotion of chemical-intensive agriculture supported by the biotech/chemical industry in favor of whole-hearted support for organic agriculturebecause despite the astronomical growth in organic consumption in the U.S., conversion to organic agriculture lags behind demand. USDA could and should make adoption of organic/climate-smart practices a prerequisite for receiving the benefits of its programs.

> Biodegradable Biobased (Bioplastic) Mulch Film (BBMF) is under consideration for sunset this year. This is part of a larger issue of the use of plastic in organic production and handling. Awareness is growing about the impacts of plasticand the microplastic particles to which it degradeson human health and the environment. BBMF should not be relisted. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic production and handlingincluding packaging.

> The NOSB should use the sunset process to eliminate non-organic ingredients in processed organic foods. Materials listed in 205.606 in the organic regulations are nonorganic agricultural ingredients that are allowed to be used as ingredients as part of the 5% of organic processed foods that is not required to be organic. Materials should not remain on 205.606 if they can be supplied organically, and anything that can be grown can be grown organically. The Handling Subcommittee needs to ask the question of potential suppliers, Could you supply the need if the organic form is required? Two materials on 205.606 are up for sunset this yearpectin and casings. Both are made from agricultural products that can be supplied organically and thus should be sunsetted.

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

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Last Chance This Fall to Tell the NOSB To Uphold Organic Integrity - Beyond Pesticides