by Ed Maltby, NODPA Executive Director
On October 31 thru November 2, 2017, the National Organic Standards Board (NOSB) held its biannual public meeting in Jacksonville, Florida. Over the course of the three-day meeting, NOSB voted on 16 proposals and 43 Sunset Review inputs. Of the 16 proposals, 6 passed, 6 failed and 4 were tabled. Under the Sunset 2019 National List review process, NOSB recommended the removal of 4 production inputs that were judged as no longer necessary or essential in organic production and handling.
The NOSB failed to make a decision on one of the most divisive issues in the organic community and at the meeting: should crops grown in water, containers, or otherwise not in the ground be allowed to call themselves organic? The NOSB proposal to prohibit hydroponics and aquaponics practices under the USDA organic standards failed by a margin of 8 to 7 votes. As there are 15 NOSB members, 10 votes are needed to decisively pass any recommendation. In addition, the proposal to create guidelines for other soil-based container production systems failed by a vote of 8 to 7. This decision allowed the NOP to let the status quo continue and, despite the fact that there are no production practices for hydroponics, hydroponic and container operations will still remain eligible for organic certification.
Despite great efforts to reach consensus, the balance of interest remained divided. The vast majority of organic farmers insisted that only farms growing crops in soil, in the ground, can be called organic. Another group of mostly larger operations promoted inclusion for organic hydroponic and aquaponic operations provided they follow strong standards based on organic principles (whatever that may mean!). A third group advocated for prohibiting air/water-based aeroponic, hydroponic and aquaponic operations, but allowing soil-based container systems provided that certain restrictions and requirements be met. A number of commenters suggested NOSB consider a labeling approach for hydroponics, whereby hydroponics and aquaponics remain allowed in organic production, but those producers would be required to label their products as “hydroponically grown” so that consumers can have transparency on the growing methods. While not a proposal formally considered by NOSB at this meeting, a number of NOSB members appeared to see a labeling approach as an alternative compromise and expressed their wish that this topic be considered at future NOSB meetings. It is unclear whether labeling of soil-less production systems will be added to NOSB’s work plan for 2018. As clarified by NOP following the votes, USDA organic certification of hydroponics, aquaponics and container production will continue to be allowed as it has been since 2002.
The main groups that benefits from hydroponic farms being able to get organic certification are large agribusinesses. Those firms, which include Driscoll’s and Wholesum Harvest, operate gigantic hydroponic operations for their organic food. Those that will lose because of this decision are the vast majority of organic farmers who follow both the intent and the spirit of organic regulations. This is yet another case of flagrant abuse of organic regulations being allowed by a few certifiers and becoming established as an acceptable part of organic production. It becomes acceptable because of the economic volume of sales and the ability of a few companies to lobby extensively. That is the case for the current abuses of the grazing requirements in organic dairy and outside access for organic poultry operations.
Other significant topics of this meeting included a proposal to address the issue of organic fraud; a proposal on how to best strengthen the requirement for using organic seed; a proposal to eliminate incentives to convert native ecosystems to organic production; and a proposal that classifies three new genetic technologies as “excluded methods” and therefore prohibited in organic production and handling.
Below is a summary of votes and issues that directly affect organic dairy producers:
Use of Parasiticides: The Sub-committee presented a proposal for clarifying when parasiticides can be used on livestock. Currently the use is only allowed on dairy animals not for organic slaughter and only under “emergency situations.” Their attempt to define what emergency situations meant did not receive the support of many commentators and that enough public comment had been received with suggestions for improving the recommendation so it wanted additional time to refine and modify the proposal. NOSB voted to refer this proposal back to subcommittee and will revisit the issue at the spring meeting.
Hypochlorous acid: It had been petitioned as a synthetic substance for addition to the National List at §205.603 as a topical treatment for pinkeye and wounds in livestock. In light of the many non-synthetic materials available and in use by organic livestock producers for wounds and pink
eye, the Subcommittee did not think it necessary to add a chlorine-based synthetic material to the National List for the same use. NOSB voted unanimously to reject the petition that chlorine material could be used in direct contact with organic livestock.
Addition of Sulfur to the National List: A petition to add sulfur as a practice to prevent and treat external parasites, particularly on poultry, was discussed by NOSB. They voted to recommend adding sulfur to the National List for use as an external parasiticide on livestock and poultry. The recommendation will now proceed down the long path to regulation and publication on the Federal Register before it can be used by producers.
Removal of Oxytocin from the National List: There was a recommendation to remove oxytocin from the National List. Oxytocin is used in post-parturition therapy, primarily in cattle, to treat conditions such as retained placenta. It is also used illegally by organic producers when freshly calved cows do not drop their milk. There are a number of natural alternative methods to treating retained placenta and the Board voted unanimously to remove this material as part of the 2019 Sunset Review.
Removal of Procaine from the National List: Procaine is used as a local anesthetic to reduce pain when performing minor surgeries or allowed physical alterations (de-horning, castration, etc.) on organic livestock. Procaine is not currently available except when it is combined with antibiotics and no compliant procaine formulas are currently available. Commenters also stated that lidocaine can be used as an alternative to procaine. The NOSB voted 14 in favor, 1 against the proposal so Procaine will be removed from the National List as part of the Sunset Review process.
The following will be renewed as part of the 2019 Sunset Review process:
Chlorine Materials (Calcium hypochlorite, Chlorine Dioxide, Sodium Hypochlorite) – vote of 15 to zero but we will be hearing more discussion on the suitability of different sanitizers in the future.
Chlorhexidine – Used as an antimicrobial during surgery for cleansing wounds, skin, and equipment. Also used as a pre and post teat dip to aid in controlling bacteria that cause mastitis. There are numerous synthetic disinfectants currently on the National List for organic livestock production, including iodine, ethanol, isopropanol, sodium hypochlorite, and hydrogen peroxide. Not all are useful both in a surgical environment and as a teat dip, as allowed under the chlorhexidine annotation. Chlorhexidine reportedly kills mastitis-causing pathogens faster than iodine and is more persistent in its disinfection activity. Chlorhexidine is gentler on the skin than iodine, which is especially useful in northern climates where an irritated udder and teats can be especially problematic for the animals in cold winter months.
Glucose - Glucose is an essential animal health tool. It is used typically to treat ketosis, and there was universal approval for keeping this material on the National List. Since glucose is an ingredient in calcium gluconate used to treat milk fever, retaining glucose on the National List of approved synthetics also maintains this important tool for treatment of this ailment as well.
Tolazoline - Tolazoline is used in conjunction with xylazine, which is used as a sedative, analgesic (pain killer) and muscle relaxant in veterinary medicine. Tolazoline is used to reverse the effects of xylazine. Tolazoline was last reviewed in 2015 at which time the NOSB voted unanimously to renew it.
Copper Sulfate is used in livestock management specifically as a walk-through footbath to help control and prevent hoof-related diseases in dairy cattle and sheep. Some of the specific problems that can affect skin adjacent to the claw horn of dairy cattle and sheep include digital dermatitis (DD) (hairy heel warts), foot rot lesions (interdigital area and invading the subcutaneous tissue), and heel erosions.
Lidocaine is a local anesthetic which has a rapid onset of action and is short term in duration. It numbs only the area to be worked on. For example, lidocaine is used to humanely de-bud horns on calves, and for minor surgery on mature animals.
The next NOSB meeting is on Wednesday, April 25, 2018 - 8:30am to Friday, April 27, 2018 - 6:00pm at the Tucson Marriott University Park, 880 East Second Street, Tucson, Arizona. The NOSB will meet to discuss: substances petitioned for addition to or deletion from the National List of Allowed and Prohibited Substances (National List), substances due to sunset from the National List in 2020, and guidance on organic policies.
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