The Organic Trade Association Strongly Supports OPP-00701:
Comments on EPA’s Pesticide Registration Notice: Draft Guidance for Pesticide Registrants on Pesticide Label Identification for Pesticide Products Meeting the Requirements of the National Organic Program
Docket Control Number OPP-00701
June 26, 2001
The Organic Trade Association (OTA) is the membership-based organic business association representing over 1200 businesses in all sectors of the organic industry throughout North America. OTA's mission is to encourage global sustainability through promoting and protecting the growth of diverse organic trade.
OTA strongly supports the proposal made in Docket OPP-00701 to allow registrants to obtain EPA approval of label language indicating that all ingredients (active and inert) in a pesticide product meet organic production requirements as defined in the NOP rule. This label information will assist organic growers by facilitating their assessment of pesticide product options without adding a requirement that pesticide product manufacturers meeting the NOP rule must add that label claim. This in turn may encourage increased production of pesticides consistent with the NOP rule.
OTA appreciates the work of EPA in creating and preparing this proposal and working with the National Organic Standards Board and USDA-AMS, including giving two very informative and cooperative presentations to the NOSB. OTA is pleased that EPA now recognizes the NOP standards for organic production and points out that the organic claim is a process claim, not a product claim, though the prohibition on the use of certain materials is certainly a part of that process. Organic production yields a variety of environmental benefits, and OTA hopes that EPA will continue to seek ways in which its programs can help the organic industry foster environmental health.
The organic industry has been built on a foundation of collaboration, with broad and open discussions of policy alternatives. This has resulted in a deep consensus regarding the principles of organic production: where disagreements occur, they are within the bounds of general agreement. EPA can make the most of the resources of the organic community by continuing its exemplary collegial approach.
The use of various materials remains a source of lively debate within the organic community. Open discussion, an airing of all views, and a transparent process will be essential to maintaining the good faith of the organic community in this process.
On technical matters, OTA supports the comments of the Organic Materials Review Institute.