Posted: October 25, 2016
The use of genetic engineering (GE), or genetically modified organisms (GMOs), is prohibited in organic regulations as an “excluded method”. National Organic Standards Board (NOSB) recommendations to prohibit GMOs date back to 1995, as the NOSB grappled with a way to exclude genetically engineered crops and processing inputs such as herbicide-resistant corn and soybeans, Bt cotton, and genetically engineered yeasts.
In April of 2013, the NOSB embarked on a process to update the excluded methods definition. Many new GE technologies have emerged since 1995. While the NOP definition of excluded methods is strong and provides a description that encompasses a broad swath of new and emerging technologies, more clarity is needed for purposes of interpretation and enforcement.
Adopting the NOSB Proposal this Fall is Important
NOC strongly supports the proposal that the NOSB has put forward on excluded methods and we appreciate the significant work that has gone into this proposal over a period of several years. We believe the timely adoption of the proposal is critical for the following reasons:
So where does that leave us? We believe that the organic community will be in a far better position after adopting a clear recommendation from the NOSB that further clarifies the excluded methods definition.
The NOSB Proposal
The NOSB proposal includes a set of definitions to be adopted by the NOSB as excluded methods. The NOSB is proposing multiple definitions rather than trying to create one comprehensive definition that would have to encompass all future technologies. NOC agrees with this strategy and we have thoroughly vetted these definitions. We believe they are appropriate, necessary, clearly defined, and aligned with FDA definitions. We believe that the overarching term “modern biotechnology,” developed by the Codex Alimentarius Commission (CAC), is the most important definition, since documents and standards developed by the CAC are referenced by the World Trade Organization in trade disputes involving food and constitute a globally accepted standard. The definition of classical/traditional breeding is also important to have spelled out since it hasn’t been explicitly defined before.
The Principles and Criteria section of the proposal clearly explains how techniques should be evaluated to determine if they should be allowed in organic. Organic regulations are process-based and so too is this proposed system for determining excluded genetic engineering techniques. We know that new techniques will be continuously developed so this set of principles and criteria are essential for providing clarity on not-yet-developed methods. We applaud the NOSB’s efforts to protect farmers’ and breeders’ rights to improve and save seeds used in organic production.
Finally, we support the Terminology Chart, which makes clear the specific techniques that are allowed in organic production and can be updated on a regular basis as new technologies come online.
In summary, NOC urges the NOSB to adopt this proposal in full. We encourage others in the organic community to provide public comments in support of the proposal and to convey the importance of adopting this path forward at this point in time. This update represents our collective best attempt at a comprehensive framework and list that will not place undue burdens on the NOSB or allow unintended breaches or market confusion regarding organic’s positions on these very novel, un-tested, un-regulated new genetic techniques.