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NOP: Rule Revision (materials) 04-28-03 - Organic Trade Association
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NOP: Rule Revision (materials) 04-28-03

 

NOP Has Made a Good Start on Rule Revisions, But More Work Remains:

Comments of the Organic Trade Association on
Docket Number TMD-02-03,
Proposed Amendments to the National List of Allowed and Prohibited Substances


Submitted by

Tom Hutcheson,

Associate Policy Director

April 28, 2003
 

General

 

The Organic Trade Association (OTA) thanks NOP for the opportunity to comment on this first substantial revision to the national organic standards.

 

OTA applauds NOP for this rulemaking to the extent that the proposed rule amends the National List in ways consistent with the substance of National Organic Standards Board (NOSB) recommendations.  OTA urges NOP to act as expeditiously as possible on outstanding NOSB materials recommendations, including resolving any differences of opinion with any other federal agencies in a timely manner, and maintaining consistency with the substance of NOSB’s recommendations.


 

Section 205.601

 

1) Regarding the proposed 205.601(a)(3), for copper sulfate, OTA urges NOP to reflect the NOSB recommended annotation by including the language “in aquatic rice systems” from the NOSB recommendation.

 

One of the purposes of the National List is to minimize the use of synthetic materials in organic production.  One of the means to this goal is to limit not only the number of materials to those considered necessary, but also to limit the uses to which they are put.  This is an appropriate annotation, as the material was not petitioned nor recommended for general use.

 

2) Regarding the proposed 205.601(a)(5), for ozone gas, OTA approves of the proposal, based on NOSB’s recommendation.

 

3) Regarding the proposed 205.601(a)(6), for peracetic acid, OTA urges NOP to include language reflecting the substance of the language in the NOSB recommendation which states, “with documentation that alternatives including biocontrols have been tried”.

 

4)  Regarding the proposed 205.601(k), for ethylene gas, OTA approves of the proposal, based on the NOSB’s recommendation.

 

5) Regarding the proposed 205.601(m)(2), pheromones, OTA urges NOP either to include as an annotation, or to publish at the same time as the final rule as a policy guidance document, the following language from the NOSB recommendation, together with a clarifying final sentence:

 

“includes only EPA-exempt pheromone products, EPA-registered pheromone products with no additional synthetic toxicants unless listed in this section, and any inert ingredients used in such pheromone formulations that are not on EPA List 1 (Inerts of toxicological concern) or EPA List 2 (Potentially toxic inerts), Provided the pheromone products are limited to passive dispensers. Pheromone products containing only pheromones, active ingredients listed in this section, and List 4 inerts may be applied without restriction.  Any allowed inert ingredients may be used only in EPA-registered pheromones.”

 

 

Section 205.602

 

6) Regarding the proposed 205.602(g), sodium nitrate, OTA urges NOP to use the following language from the proposed rule in the Federal Register, vol. 68, No. 73, p. 18557:

 

    Sodium nitrate--unless use is restricted to no more than 20% of the

crop's total nitrogen requirement; use in spirulina production is

unrestricted until October 21, 2005.

 

OTA also urges NOP to propose to NOSB that it revisit this issue in a timely manner before October 21, 2005, and actively solicit testimony from spirulina producers regarding progress in sourcing alternate materials.

 

7) Regarding the proposed 205.603(a)(3), biologics-vaccines, OTA approves of this proposal.

 

8) Regarding the proposed 205.603(a)(4), chlorhexidine, OTA approves of this proposal together with its annotation.

 

9) Regarding the proposed 205.603(d), DL-Methionine, etc., OTA approves of this proposal together with its annotation.  OTA also urges NOP to propose to NOSB that it revisit this issue in a timely manner before October 21, 2005, and actively solicit testimony from poultry producers regarding progress in sourcing alternate materials.

 

10) Regarding the proposed 205.603(a)(8), glycerin, OTA approves of this proposal together with its annotation.

 

11) Regarding the proposed 205.603(d), trace minerals, OTA approves of this proposal together with its annotation.

 

 

Section 205.605

 

12) Regarding the proposed 205.605(a), agar-agar, OTA approves of this proposal.

 

13) Regarding the proposed 205.605(a), carageenan, OTA approves of this proposal.

 

14) Regarding the proposed 205.605(a), ethylene, OTA approves of this proposal together with its annotation.  Ethylene should be listed under 205.605(b).

 

15) Regarding the proposed 205.605(a), tartaric acid, OTA approves of this proposal.  OTA urges NOP to include tartaric acid made from malic acid in Section 205.605(b), obviating the need for a policy statement covering this issue.


 

OTA requests further rulemaking

 

OTA would like to request further rulemaking on various materials recommended by NOSB.  As above, OTA urges NOP to act as expeditiously as possible on outstanding NOSB materials recommendations, including resolving any differences of opinion with any other federal agencies in a timely manner, and maintaining consistency with the substance of NOSB’s recommendations.

 

A list of these materials to be allowed, together with their NOSB-recommended annotations, should include:

 

for crops: sodium chloride (in cotton production, with its annotation);

 

for livestock: activated carbon, bismuth subsalicylate, butorphanol, calcium borogluconate, calcium propionate, epinephrine/adrenaline, flunixin, kaolin pectin, magnesium oxide/magnesium hydroxide, mineral oil (again, together with its annotation implying allowance for internal use), peracetic acid, pheromones (livestock), poloxolone, potassium sorbate, propylene glycol, tolazoline, xylazine, and yeast derivatives;

 

for processing: activated carbon, ammonium hydroxide, calcium sulfate, calcium stearate, cellulose, cyclohexylamine, diethylaminoethanol, enzymes (animal derived), gelatin, glucono delta lactone, octadecylamine, peracetic acid, potassium hydroxide, shellac (organic, unbleached), and tetrasodium pyrophosphate.

 

 

OTA supports OMRI comments

OTA also supports all of the substantive comments of the Organic Materials Review Institute which are not inconsistent with any of the comments above.

 
 
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