NOC asks NOSB to ban Ammonia Extract and vote no on Biodegradable Mulch

Today, NOC submitted wide-ranging and extensive comments to the National Organic Standards Board (NOSB) in response to the proposals and discussion documents the NOSB released and will be discussing during the upcoming meeting on April 28 - 30.

The National Organic Standards Board is the citizen stakeholder board that is responsible for advising the USDA on organic standards and keeping toxic materials out of organic food and farming. Read more.

NOC drafted comments on dozens of topics – petitions, sunset materials, and issues regarding organic standards and the NOSB’s process – that are under consideration by the Board. Below, we highlight a few of the topics included in our comments. NOC’s comments are also available in full here.

Priorities for the new administration

NOC has asked the Biden Administration to advance six top priorities early in the new administration to put organic back on solid footing. The NOSB too has a role to play in advancing some of these top priorities.

Organic Agriculture and Climate Change

NOC believes the NOSB has an important role to play in solidifying organic’s role as the gold standard for climate-friendly agriculture. The organic regulations are strong because they require proper tillage, soil-building practices that sequester carbon, and pasture-based grazing for organic livestock. But the regulations need to be enforced more effectively to ensure that organic is the gold standard when it comes to climate change.

NOC is requesting that the NOSB create a work agenda item related to carbon sequestration and enforcement of soil-health provisions in the organic regulations, and that the NOSB recommend a detailed restriction on the use of highly soluble sources of nitrogen in organic agriculture. NOC is requesting that the USDA’s National Organic Program (NOP) reinstate the Organic Livestock and Poultry Practices Rule, adequately enforce the pasture rule and soil health provisions in organic, and finalize regulations on standards that eliminate incentives to convert native ecosystems.

NOSB Role and Authority

NOC disagrees with USDA’s decision to limit the NOSB workplan to issues that are already priorities of the NOP. The NOSB’s work should be driven by the public process – the NOP should not have the ability to veto critically important issues that the NOSB seeks to address. The NOSB was designed to maximize public input from a community with strong and diverse views, and deep knowledge about the meaning of “organic.” That input and the 2/3 “decisive vote” requirement ensure that NOSB proposals can only pass when they garner broad and diverse support from different stakeholder groups.

Racial Equity in Organic Agriculture

Communities of color have been hit disproportionately hard by COVID-19. These disparities compound decades of racial discrimination, including discriminatory policies at USDA that have resulted in inequitable lending and land ownership policies. BIPOC (Black, Indigenous, and people of color) individuals are underrepresented as farm and ranch owners and operators, in conventional agriculture as well as organic systems. Although BIPOC individuals represent nearly 40% of the US population, only 3% of organic producers identify as BIPOC. Addressing racial equity in organic agriculture is an important priority for NOC. The NOSB can also play a role by considering the impact of NOSB decisions on BIPOC farmers and by understanding some of the specific barriers to organic certification for BIPOC farmers.

Ammonia extract

Ammonia extract is a type of fertilizer that is applied to soils to meet the nitrogen demands of plants. Synthetic ammonia fertilizers are not allowed in organic production. Last year, the NOSB received a petition requesting that naturally derived (i.e. nonsynthetic) forms of ammonia extract also be prohibited in organic crop production.

NOC agrees that ammonia extract should be prohibited. This material should be listed on §205.602 as a prohibited nonsynthetic input. Ammonia extracts—synthetic or nonsynthetic—are harmful to soil organisms and inconsistent with organic production.

Ammonia extracts are not the only nonsynthetic nitrogen fertilizers that are inconsistent with fundamental principles of organic production.  Two widely used materials are Chilean nitrate and soybean hydrolysates. There are others and will be more.  The NOSB should take action now to regulate fertilizers that bypass the benefits from the soil fertility and crop nutrient management practices required by the organic standards and instead provide highly available crop nutrients. 

Biodegradable Biobased Mulch

NOC acknowledges that a biodegradable biobased mulch (BDM) film would be a great asset to producers; however, we continue to harbor great concerns regarding the agronomic, environmental, and health effects of the breakdown and subsequent incorporation into the soil. We do not feel that these concerns have been addressed adequately at this time. For these reasons, NOC does not support the NOSB’s proposed annotation change to allow BDM films that are at least 80% biobased by weight.

Excluded methods

Throughout decades of dialogue and debate, the organic community and NOSB have been clear in their opposition to genetic engineering in organic agriculture and the need to provide a transparent process and certainty to the organic community - including certifiers, operations, and consumers - about what is excluded, what is allowed, and why.

The NOSB must move forward with urgency, but with great care, to determine the status for the six ‘to be determined’ technologies and other GE technologies that emerge to provide clarity to all stakeholder groups. The NOSB must solicit input from scientists, plant breeders, and other organic stakeholder groups in making these determinations. In particular, failure to continue work in this area will negatively impact organic plant breeders and the organic seed industry, who need certainty to advance plant breeding efforts that meet the needs of organic operations.

NOC supports the four evaluation criteria used to determine if methods should be excluded. The NOP should codify these criteria and the 11 methods that the NOSB has determined fit the excluded methods definition by publishing a guidance document and instructions to certifiers to ensure clarity for all stakeholder groups.

Stay tuned – members of NOC’s team will be testifying to the NOSB on April 20 and 22 and will be taking part in the NOSB meeting on April 28 to 30.

Tune in to NOC’s Twitter Feed for live updates: @NationalOrganic

Some of these topics will also be discussed during the NOC Pre-NOSB Meeting on April 15th. More information and registration are available here: www.nationalorganiccoalition.org/events.