NOP: Sunset 01-28-08 - Organic Trade Association
Organic Trade Association
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NOP: Sunset 01-28-08


RE: [Docket Number AMS-TM-07-0124; TM-07-12], National Organic Program (NOP); Sunset Review (2008); Advance notice of proposed rulemaking with request for comments.

The Organic Trade Association (OTA) thanks USDA-NOP for this opportunity to comment.  The Organic Trade Association (OTA) is a 1600-member North American business association serving all sectors of the organic products industry.

In general, OTA believes that in the absence of significant evidence supporting the removal of an item from the National List, substances should remain listed.

In the past OTA has not engaged its members directly in supporting or opposing specific materials.  OTA takes this opportunity to advocate—in the absence of significant evidence supporting the removal of an item from the National List—for the continuance of the materials in the current ANPR.

The petition process is sufficiently burdensome to eliminate the filing of frivolous petitions, and beyond that, NOSB serves as a fine filter, so only the most clearly essential materials are recommended for inclusion on the National List.  Thus, all of the materials under consideration have been demonstrated to be essential for the production of certain crops or processed product.  Because OTA supports the growth of acreage in organic production, OTA supports the further growth and development of foods that will satisfy consumer demand.  The organic market continues to grow, so consumers of organic product have demonstrated their acceptance of the use of the small number of non-organic materials on the National List.

Therefore, in the absence of significant evidence supporting the removal of an item from the National List, OTA urges USDA-NOP to continue the listing of the materials in this docket, as annotated:  For use in crop production:  copper sulfate (both for use as an algicide and as tadpole shrimp control in aquatic rice production); ozone gas; peracetic acid (both for use in disinfecting equipment, seed, and asexually propagated planting material and to control fire blight bacteria); inerts used in passive pheromone dispensers; and calcium chloride.  For use in handling: agar-agar; animal enzymes; calcium sulfate; carrageenan; glucono delta-lactone; tartaric acid (both as a non-synthetic and a synthetic material); and cellulose.

For use in crop production:

Copper sulfate is used in two ways, both highly restricted as per the annotations.  First, it is used as an algicid; second, as tadpole shrimp control in aquatic rice production.

Ozone gas is used as an irrigation system cleaner, where it serves as an alternative to chlorine.

Peracetic acid is used in two ways, both highly restricted as per the annotations.  Its first use is “disinfecting equipment, seed, and asexually propagated planting material,” its second, “to control fire blight bacteria.”  There are very few disinfectants allowed, and chlorine is not preferred for these uses.  This is very important both to the tree fruit sector and to the organic seed sector.  It is important for organic seed producers to continue to have access to peracetic acid for disinfecting their seeds because it may provide an alternative to chlorine disinfectants for some seed production.

Inerts used in passive pheromone dispensers are vital to crop producers using pheromones (scents) to attract pests to traps.  This is of special concern to farmers coping with the Light Brown Apple Moth, especially the tree fruit sector.

Calcium chloride is used as a foliar spray to treat a physiological disorder associated with calcium uptake.  This is also very important to the tree fruit sector.

For use in handling:

Agar-agar is a natural product made from seaweed which exhibits thermal set at high temperatures.  For example, it is used in icing in preassembled baked goods.  It is used in fillings, sweetened jellies, meat products, sauces, Japanese desserts such as anmitsu, and as a vegetarian gelatin substitute, a thickener for soups and ice cream, and a clarifying agent in brewing.

Animal enzymes are natural products used in making cheese.  Until the organic animal market is considerably larger than it is today, supplies of animal enzymes from organic animals will be unavailable.

Carrageenan is a natural product of red seaweed and has been used as a thickener and stabilizer for hundreds of years.  It provides a rich mouthfeel to reduced fat products.  It is a soluble fiber and provides for a range of viscosities and controls synerisis.  It exhibits unique interaction with protein.  Its applications are many and varied.  Examples include soups, jellies, ice cream, chocolate milk, frozen desserts, custards, puddings, non-dairy beverages, infant formula, confections, meats relishes and as a clarifying agent in brewing and as a vegetarian gelatin substitute.

Glucono delta-lactone serves a unique function in the processing of organic meats, primarily through assisting the activity of starter cultures.

Tartaric acid is used both in natural and synthetic forms and is used as an ingredient in baking powder.  The supply of natural tartaric acid, primarily from wine fermentation, is much too small to meet the baking needs of the organic trade.

Cellulose is used in a variety of ways.  It is used by the juice industry in paper form as a press aid.  For items such as Concord grape juice, alternate processes such as micro-filtration are not feasible.  It is also used as an anti-caking ingredient in shredded cheese and other foods, and in peelable casings for skinless sausages such as hot dogs.

Thank you very much for your consideration.

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