By Jessica Walden

QAI participates in the biannual National Organic Standards Board (NOSB) meetings, where proposals related to materials and organic practices are discussed and voted on or sent back to subcommittees for further development. Our staff provides statistics to the board regarding which materials are currently being used by our clients, as well as insights into industry practices. The data and insights we provide help inform board members about the essentiality of a material before they vote for its continued inclusion or removal from the National Organic Program (NOP) standards. This information also brings industry context to the board’s discussions and decisions.

The Spring 2019 NOSB meeting took place in April in Seattle, WA. The NOSB conducted its initial review of over 50 sunset materials as well as several petitions and proposals at this meeting. The sunset review process is a periodic review of materials currently on the National List intended to evaluate their continued eligibility for the National List as established by the criteria in the Organic Foods Production Act (OFPA).

There were no votes on sunset materials at this meeting. Rather, the Board collected information; hosted expert panels on several topics as a means to gather technical information to support its review on celery powder, methionine and biodegradable bio-based mulch film; and discussed various issues related to each material in preparation for the final vote on these sunset materials at the Fall 2019 NOSB meeting in Pittsburgh, PA.

The recommended changes to the National List or to the organic requirements are summarized below. This is not a full report on the entirety of the work of the NOSB at this meeting but if you are an Organic Trade Association member, you can access the full report or contact us for more information.

It is important to note that recommendations from the NOSB are not enforceable by certifiers. The NOP must accept the recommendations and then publish a proposed rule that reflects those recommendations. When the proposed rule is published, there is an additional opportunity for public comment before NOP finalizes and publishes the final rule.

Recommended Changes to the National List

The following materials are recommended by the NOSB to be removed from and/or added to the National List:

1. Oxalic acid – petition to allow in livestock production is accepted
2. Pullulan – petition to allow in processing/handling (“made with” only) is accepted
3. Collagen gel – petition to allow in processing/handling is accepted

NOSB Votes on Proposals

The following subcommittee proposals related to the National List or other organic standards issues were discussed and voted on by the NOSB:

1. Excluded methods determinations – proposed updates to NOP guidance are accepted
2. Strengthening organic seed guidance – proposed updates to NOP guidance are accepted

Other Materials, Petitions and Updates

Other materials, petitions and updates that did not result in changes to the National List include:

1. Petitions that failed:
   • Silver dihydrogen citrate – petition to allow in processing/handling is rejected
   • Allyl isothiocyanate – petition to allow in crop production is rejected
   • Ammonium citrate – petition to allow in crop production is rejected
   • Ammonium glycinate – petition to allow in crop production is rejected
   • Calcium acetate – petition to allow in crop production is rejected
2. Discussion documents (issues) sent back to subcommittee for further development:
   • Excluded methods: Induced mutagenesis and embryo transfer in livestock
   • Marine materials in organic crop production
   • Genetic integrity transparency of seed grown on organic land
   • Assessing cleaning and sanitation materials used in organic crop, livestock and handling
   • Oversight improvements to deter fraud
   • Use of excluded methods vaccines in organic livestock production
   • Paper (plant pots and other crop production aids)
3. Sunset materials that had an initial review and discussion that did not result in a vote or recommended change to the National List. NOTE: The NOSB Board will vote on these sunset materials at the Fall 2019 meeting, which takes place on October 23-25 in Pittsburgh, PA.

QAI encourages operators using any of the following materials to submit public comments here by October 3, 2019.

1. Crops:
Hydrogen peroxide, soaps, ammonium oils, horticultural oils, pheromones, ferric phosphate, potassium bicarbonate, magnesium sulfate, hydrogen chloride. From the prohibited list (602): Ash from manure burning, sodium fluoaluminate
2. Livestock:
Atropine, hydrogen peroxide, iodine, magnesium sulfate, parasiticides: fenbendazole, parasiticides: moxidectin, peroxyacetic/peracetic acid, xylazine DL-methionine, trace minerals, vitamins
3. Handling:
Citric acid, lactic acid, calcium chloride, dairy cultures, enzymes, L-malic acid, magnesium sulfate, microorganisms, perlite, potassium iodide, yeast, alginic acid, activated charcoal, ascorbic acid, calcium citrate, ferrous sulfate, hydrogen peroxide, nutrient vitamins and minerals, peracetic acid, potassium citrate, potassium phosphate, sodium acid pyrophosphate, sodium citrate, tocopherols, celery powder, fish oil, gelatin, dried orange pulp, Pacific kombu wakame seaweed (Undaria pinnatifida)