Inside Organics Blog

Weigh in on organic proposals, materials that impact your farm

By Harriet Behar, MOSES

Unlike many other government regulations, participation in the National Organic Program (NOP) is voluntary. Our process includes a robust engagement of all stakeholders. In addition, our program has a built-in mechanism for continuous improvement in which we review materials on our National List of approved or prohibited substances every five years for inclusion.

As a member of the National Organic Standards Board (NOSB), I can assure you that your opinion matters. In fact, the practical needs of operators, and their thoughts on practices and substances that should be allowed in organic, carries a lot of weight.

The final animal welfare rule for organic livestock is a good example of how the NOP modifies regulations following public comment. Organic dairy producers gave comments that some of the proposed rules were unnecessary and not based in production reality; those were changed in the final rule to be more practical and achievable. The final rule includes provisions for mobile pasture pens for chickens, based on public comment which complained there was no provision for this popular production system in the proposed rule. While the NOP notes in this rule there are still some areas that need further discussion (such as for swine and poultry species other than chickens), the regulation as proposed is well crafted and represents the majority of stakeholders.

The outdoor access for chickens represents more of a quality rather than quantity approach, allowing producers to develop systems that provide 50 percent vegetation in their outdoor areas. It is both better for the poultry and the environment when we base the rule on providing vegetation, rather than large areas of bare ground. This proposed rule illustrates a true public and private partnership, taking into account producer, environmental, and consumer concerns along with the capability of certifiers to implement and verify. I was impressed with the detail and care that went into this regulation, and I applaud the NOP for a job well done. Hopefully, this new rule will be implemented by the new administration after its review. If approved, the rule will begin to take effect in May. See the Organic Broadcaster story online for more details about this livestock rule.

The spring in-person meeting of the NOSB will be April 19-21 in Denver, Colorado. As always, we provide ample opportunity for public comment. In addition to giving in-person comments and written comments, there will be an oral comment webinar Thursday, April 13 from noon to 3 p.m. CDT. Information on how to participate in these opportunities is in the box above below.

Numerous materials are being considered as part of sunset. The NOSB needs to know if you rely on these items or think they should be removed from the National List.

The crops subcommittee will be looking at biodegradable biobased mulch, which the NOP has determined needs to be from 100 percent biological ingredients with no petroleum-based polymers. There are no products currently on the market that meet this requirement. A new Technical Review report does not provide any new information on the long-term effects in soil from decomposition of the petroleum by-products in current biodegradable mulch. The NOSB would like to hear stakeholders’ opinions on this material.

Other items up for the crops sunset discussion are various chlorine materials for sanitation, boric acid, sticky traps, copper products, humic acid, micronutrients and vitamins.

The livestock subcommittee will have the first sunset discussion on the following: chlorine materials, chlorhexidine, glucose, oxytocin, tolazine, copper sulfate, lidocaine and procaine. Since there have been numerous synthetic teat dips petitioned in recent years for addition to the National List, do we still need chlorhexidine, or are there preferable active ingredients? Is oxytocin necessary? Not all organic milk buyers allow their producers to use this material, so they can label their retail milk products as being produced with no hormones. However, in some circumstances, it could be considered a necessary component of animal health and welfare to aid with post-birthing issues in dairy cows.

The handling subcommittee also has a list of sunset materials, which can be found on the NOSB page noted in the box above.

There are a few proposals and discussion documents focused on the activities to be discussed. The crops subcommittee will have a discussion document on hydroponic, aquaponics, and aeroponic production systems, along with container production. The fall proposal on these topics did not have clear regulatory language for the NOP to implement this NOSB proposal if it passed. Also, there were issues with clarity on what the production systems were as well as what type of container growing might be allowed to carry the organic label. One of the reasons we are working on these production systems, is they were allowed by the NOP without a process for actually reviewing them as the distinct production system that they are. While some hydroponic operations now carry the organic label since they use materials that are allowed under organic, the overall production practices have not been reviewed to decide if this system is harmonious with other organic systems. This discussion document was written to address these concerns. Public comment is encouraged so we can move forward in the fall with a proposal that represents the organic community and maintains the integrity of the organic label.

The crops subcommittee has a proposal to strengthen the NOP policy on determining commercial availability of organic seed. There are many scenarios for both seed and planting stock where organic could be purchased and planted, with the practical issue of yields and regional adaption taken into account. These proposed policy improvements provide a road map producers can use to determine if an organic seed is equivalent to the non-organic one they are used to planting. Many items in this proposal also provide direction for organic certifiers, so there is consistency between them in the way they implement the important requirement to use organic seed, when commercially available.

Since the livestock subcommittee voted to lessen the withdrawal time between the use of parasiticides and the sale of organic milk or use in breeder stock last spring, it became clear that the definition of “emergency treatment” should be improved. This discussion document could lead to a proposal that would add a definition and practice standard to the organic regulation for what activities should be performed and what situations are present before livestock are treated in an emergency.

The certification, accreditation, and compliance subcommittee will have a proposal to make the NOP policy for in-field evaluation of inspectors more practical and cost effective. The subcommittee will also bring forward a discussion document to lessen the incentive for native ecosystems to be converted to organic crop production. Since there is a three-year waiting period between non-organic production and organic production, there are times that land that has never seen the plow or a chemical is transformed into cropland for the growing of organic crops, without that waiting period. At times, this land could have endangered species, or be performing an important function as a last remnant of a native or threatened ecosystem. Not all land would be considered of high conservation value. Land that had been previously cropped such as CRP land, would not be included in the disincentive that is being considered.

If you use any of these materials, or would be affected by any of the practices to be discussed during the meeting, I encourage you to take a moment and send the NOSB your thoughts. Organic is your label, and your opinion can make a difference.

Harriet Behar is the senior organic specialist at MOSES and serves on the National Organic Standards Board.

From the March | April 2017 Issue

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