Inside Organics Blog

MOSES organic specialist moves from ‘peanut gallery’ to hot seat on standards board

By Harriet Behar, MOSES

After many years of attending National Organic Standards Board (NOSB) meetings as a member of the “peanut gallery,” I sat on the other side of the table for the first time at the recent board meeting in Washington D.C. It is a big responsibility to review, discuss and recommend the practices and inputs that are allowed or not in USDA organic production. It has taken me a few months to understand and follow the procedural workings of this government board. As you might imagine, there are quite a few. I have come to the board with a few ideas of what I would like to accomplish. As organic continues to evolve, I am sure new ones will come to mind. I am also sure the main lesson I will learn on this board will be patience.

It takes some getting used to the way government entities work; there are specific words or phrases that have to be used. For instance, there is a specific definition for a “work plan” within the government, which does not accurately reflect the activities of the NOSB—so we have a “work agenda.” The various committees, where most of the work is done, are subcommittees, because technically the NOSB is the main committee. It does take some presence of mind to keep this all straight and call everything by its right name, especially when speaking at the public meeting when every “um” is present in the transcript.

At this meeting, you also have to make sure your microphone is turned off, so no one hears you muttering under your breath when a public commenter is saying something you feel is incorrect, or you want to hoot in approval to something that you like. It was a lot easier sitting in the peanut gallery, but being at the big table is more fun. At last, I have the chance to ask questions and bring what I think is practical knowledge to the discussion.

Public Comments
Since comments from the public are limited to three minutes at the public discussion, most commenters submit written comments as well. More than 4,000 pages of public comment were submitted for the spring meeting. Some were form letters from a variety of organizations, which lightened the load somewhat. To get through all those comments, I purchased an iPad mini so I could sit on the couch in the evenings reading these, rather than sitting at my computer for hours on end. I have read the public comments in the past, but not every single one!

While reading all those pages of comments before this meeting, I was struck by how passionate people are about organic food. Many people depend on the organic label to help them make food choices that literally mean life or death for themselves or a loved one, especially children with health disorders. Comments came from almost every state, from urban and rural areas, and even from around the world. It is a big responsibility to protect the integrity of organic food, provide practical tools for organic operators, and provide a safe and healthy food supply–all while working within government bureaucracy.

Materials Discussion
To illustrate this point, I’ll share the discussion we had about two materials: sodium lactate and potassium lactate. Sodium lactate is an anti-microbial used in luncheon meats, personal care products, and one commenter used it for herbal food pastes. It is referred to as a “preservative” in many food processing communications on the internet. It consists of sodium and lactic acid. Potassium lactate is used in products where the manufacturer wants to have a finished product with less salt in it. The National Organic Program has allowed these to be used for many years, since they originated from materials already on the national list of approved synthetics in processed organic food.

However, the NOP rethought this allowance, since sodium lactate and potassium lactate are different materials from their individual ingredients. The NOP asked these items to be petitioned in order to remain allowed in organic products. These materials, while newly petitioned, are actually more like sunset materials that are being reviewed because removing them would affect operators who are already relying on their use. There are other methods of processing that remove the need to use sodium or potassium lactate. There are equivalent organic products on the shelf, some with sodium lactate and some without. In conventional food, sodium nitrate is used more frequently than sodium lactate. A technical review of these two materials showed no negative human or environmental effects.

In the end, the NOSB voted to list these two materials and allow them to be used in organic food products. The vote was 12 yes, 2 abstentions and 1 no. I was one of the abstentions. The benign nature of the materials is a good argument for allowing them. However, organic products are being questioned for their inclusion of unnecessary synthetics, and I felt that if it is not absolutely essential, then we should encourage processors to find a better way. I was concerned that a retail store buyer might be negatively affected when deciding which new product to put on their shelves or a consumer deciding which item to buy. In comparing the two labels, there could be a “natural” product that did not contain sodium lactate and an organic one that did. I was concerned that the organic label would lose out to the natural label, based upon the presence of this synthetic sodium lactate in the ingredients list.

I could see that my argument against sodium lactate was not resonating with the rest of the NOSB, so I chose to abstain. There is still a chance for the marketplace to push organic food processors to remove this material, since they have organic competitors who have a “cleaner” label. One of the criteria for deciding if a material is allowed is that there is no “natural” alternative. In this case, there is: pasteurization provides the same food safety assurance as sodium or potassium lactate.

Changes for Livestock Materials
For livestock producers, there has been a significant change in the use of moxidectin and fenbendozole. The NOSB affirmatively voted to change the wait time from 90 days to less than a week between use of these parasiticides and the sale of organic milk. Fiber animals, who did not have an allowance for any use of a parasiticides, now have a proposed 90-day wait time between use and harvest of organic fiber. Organic slaughter animals cannot have parasiticides used and retain the organic label. The NOSB has stated it will be working on removing ivermectin from the approved list of materials; the wait time currently is 90 days between use and sale of organic milk.

Another change for livestock: organic animals can be treated with lidocaine or procaine with a greatly reduced wait time: 8 days for organic slaughter animals and 6 days for organic dairy animals.

Remember, these changes are not in effect until the National Organic Program reviews and prints them in the Federal Register, which can take between 12-24 months or longer. I believe that the definition of “emergency use” on an organic livestock operation will be added to our work agenda sometime this summer to further clarify these changes.

Carrageenan is a controversial food additive that will be reviewed and voted upon at the fall NOSB meeting in St. Louis. The vast majority of public comment by numbers and pages were devoted to this material, with strong arguments made by both sides. This will be a difficult vote, and however it ends up, some segment of the organic community will be disappointed. Carrageenan has triggered robust discussion, which is the hallmark of NOSB meetings.

Hydroponics, Excluded Methods
The meeting included presentations from two expert panels: one on hydroponics and another on excluded methods (GMO). The NOSB will need to decide if or in what form hydroponics might be allowed to carry the organic label in the future. We also need to develop updated definitions of excluded methods as biotechnology methods expand. I enjoyed being able to engage the speakers.

This discussion helped me and, hopefully, others better understand the issues. When the time comes to make a decision, we should be able to make an informed decision.

Harriet Behar, MOSES Senior Organic Specialist and member of the National Organic Standards Board, answers farmers’ questions about certification and organic practices. Email

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