NOC Comments to the NOSB emphasize the need for transparency
NOC submitted broad-ranging comments to the National Organic Standards Board on Thursday, October 4, after weeks of deliberation and careful consideration of NOSB proposals and discussion documents. NOC commented on 33 materials that are up for review as a part of the Board’s sunset process. NOC is recommending that three of these materials sunset from the National List as we’ve described in greater detail in our comments: Sodium carbonate peroxyhydrate, Fructooligosaccharides (FOS), and Sucrose octanoate esters. Additionally, NOC has raised many critical issues that we believe should be addressed for those 30 materials that we have recommended retaining on the National List. These issues include, but are not limited to:
Biologics, vaccines: NOC is requesting that the Livestock Subcommittee should further examine how to ensure consistency across certifiers and should develop a path forward to limit the use of GMO vaccines where possible. NOC urges the Livestock Subcommittee to add vaccines to its work agenda.
Phosphoric acid: As our comments on phosphoric acid demonstrate, NOC recognizes a need for the NOSB to conduct a comprehensive review of sanitizers, disinfectants, and cleaners to inform decision-making when a new material is petitioned or a material is reviewed at sunset. This comprehensive review may help identify areas where there are gaps in necessary sanitizers or disinfectants which aid crops, livestock, and/or handling operations in promotion of organic food safety.
Sucrose octanoate esters: The NOP must adopt apiculture rules, which would provide a framework for making decisions about materials used in organic beekeeping. Until such standards are developed, we have a difficult time commenting on materials for use in organic apiculture.
Flavors: NOC urges the NOSB to keep on track to move to wholly organic flavors, as laid out by the NOSB in 1995. NOC would further ask the NOSB to reiterate in their vote that they are still in support of the 2015 annotation for flavors.
Alginates: NOC is opposed to the categorical listing of alginates and want to see this broken down by source into specific allowed species. We agree with concerns regarding sustainability and overharvesting of seaweed.
Xanthan gum, gellan gum: The NOSB needs a policy that can be applied in evaluating products of fermentation –regarding both classification and compatibility with organic— so that the NOSB makes clear and consistent decisions.
NOC analyzed and took positions on 9 petitions to request that the Board add materials to the National List. We strongly urge the Board to reject all but one of the petitions. NOC supports the Crops Subcommittee’s motion to add sodium citrate to §205.601 with the annotation “For use as an anticoagulant in the production of blood meal.”
NOC commented on the unfinished implementation of the open docket, which is a tool that promotes transparency and communication between the NOSB and public stakeholders. The lack of an open docket is especially problematic combined with the National Organic Program’s decision to abandon keeping notes from NOSB subcommittee deliberations. The organic sector relies on public trust in the decision-making process and these tools are necessary to retain that trust and to ensure sound decision-making by the NOSB and NOP.
NOC has also commented on the issue of paper pots, to urge the NOSB and NOP to do all they can to allow organic producers to continue using this system.
Other key topics addressed in NOC comments to the NOSB include: prohibitions for next generation GMOs in organic (excluded methods), issues related to strengthening organic enforcement (accreditation oversight, organic data, inspector qualifications, peer review, pasture rule enforcement, origin of livestock), a request that the NOSB examine how organic production is being impacted by energy infrastructure and fracking, and a suggested path forward to eliminate antibiotics in day-old chicks.