NOP Is Continuing to Progress on Rule Revisions, But More Work Still Remains:
Comments of the Organic Trade Association on
Docket Number TMD-03-02,
Proposed Amendments to the National List of Allowed and Prohibited Substances
Associate Policy Director
June 2, 2003
The Organic Trade Association (OTA) thanks NOP for the opportunity to comment on this second 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 requests that NOP post OTA’s previous comment of April 28 regarding TMD-02-03 on NOP’s web site together with the other comments received.
1) Regarding the proposed 205.605(a), Calcium sulfate (mined), OTA supports the inclusion of this material, but prefers the NOSB recommended annotation, “allowed from nonsynthetic sources only”. This would include mined calcium sulfate as well as any other naturally derived form, should such a form become commercially available.
2) Regarding the proposed 205.605(a), Glucono delta-lactone, OTA supports the inclusion of this material, but prefers the NOSB recommended annotation, “produced through microbial fermentation of carbohydrates only”.
3) Regarding the proposed 205.605(b) Animal enzymes (etc.), OTA supports the inclusion of these material, and applauds NOP for using the NOSB recommended annotation.
4) Regarding the proposed 205.605(b) Cellulose (etc.), OTA supports the inclusion of this material, and applauds NOP for using the NOSB recommended annotation.
5) Regarding the proposed 205.605(b) Potassium hydroxide (etc.), OTA supports the inclusion of this material, and applauds NOP for using the NOSB recommended annotation.
6) Regarding the proposed 205.605(b) Tetrasodium pyrophosphate, OTA supports the inclusion of this material, and applauds NOP for using the NOSB recommended annotation.
OTA requests further rulemaking
As stated in OTA’s comment on April 28 to TMD-02-03, OTA would like to request further rulemaking on various materials recommended by NOSB. 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, while 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, together with its NOSB 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.
Further, OTA requests information regarding the lack of inclusion in the present proposed rule of the following processing materials recommended for inclusion on the National List by NOSB: activated carbon; ammonium hydroxide; calcium stearate; cyclohexylamine; diethylaminoethanol; gelatin; octadecylamine; peracetic acid; and shellac (organic, unbleached).
OTA supports OMRI comments
OTA supports all of the substantive comments of the Organic Materials Review Institute that are not inconsistent with any of the comments above.