The U.S. Department of Agriculture’s National Organic Program (NOP) has published revised National List Petition Guidelines for requesting amendments to the National List of Allowed and Prohibited Substances (National List). According to NOP, the National List not only identifies “the synthetic substances that may be used and the non-synthetic (natural) substances that may not be used in organic crop and livestock production,” but designates “a limited number of non-organic substances that may be used in or on processed organic products.”
Clarifying the petition process as well as “the information to be submitted for all types of petitions requesting amendments to the National List,” the guidelines address, among other things, (i) who can submit a petition, (ii) what types of substances can be petitioned, and (iii) the criteria by which the National Organic Standards Board (NOSB) evaluates petitions. These criteria include: (i) “the potential of the substance for detrimental chemical interactions with other materials used in organic farming systems”; (ii) “the toxicity and mode of action of the substance and of its breakdown products or any contaminants, and their persistence and areas of concentration in the environment”; (iii) “the probability of environmental contamination during manufacture, use, misuse or disposal of the substance”; (iv) “the effect of the substance on human health”; (v) “the effects of the substance on biological and chemical interactions in the agroecosystem, including the physiological effects of the substance on soil organisms (including the salt index and solubility of the soil), crops, and livestock”; (vi) “the alternatives to using the substance in terms of practices or other available materials”; and (vii) “[the substance’s] compatibility with a system of sustainable agriculture.” See USDA Press Release and Federal Register, March 10, 2016.
Meanwhile, NOP has announced an NOSB meeting slated for April 25-27, 2016, in Washington, D.C., as well as an April 19 webinar to receive public comments. The agency will accept written comments or registration to make oral comments by April 15, 2016.
Tasked with developing “standards for substances to be used in organic production,” NOSB will consider reports from its subcommittees on National List substances up for sunset review in 2018, including agar- agar, carrageenan, tartaric acid, cellulose, beta-carotene extract, copper sulfate, ozone gas, peracetic acid, and calcium chloride. The board will also hear recommendations on proposals and petitions related to the following substances: sodium and potassium lactate; oat beta-glucan; hypochlorous acid; sodium dodecylbenzene sulfonate; ancillary substances for microorganisms; ash from manure burning; squid and squid byproducts; and soy wax. See Federal Register, March 16, 2016.