COMMENT
of the Organic Trade Association
on the
National Organic Standards Board draft:
“Antibiotics Used As Preservatives In Vaccines”
July 31, 2001
Submitted by
Tom Hutcheson, Policy Coordinator
Organic Trade Association
P.O. Box 547, Greenfield, MA 01302
OTA endorses the NOSB Board Recommendation for "Preservative Use in Vaccines", with the request that an annotation be added to the National List next to vaccines.
The rationale for placing the annotation next to vaccines on the National List was seen as a workable alternative to a commercial unavailability clause which the Livestock Subcommittee felt placed an undue burden on the farmer to do a yearly due diligence search for vaccines and artificial insemination materials without antibiotics. Since the National List is reviewed every five years, Subcommittee members felt that adding wording such as “antibiotics are used in vaccines and semen for preservation; the level of antibiotics permitted in vaccines by 9 CFR 114.10 is well below a therapeutic dose; they are not present for the purpose of treatment or growth enhancement of the livestock” would serve to ensure that when vaccines and AI materials without antibiotics are available, they must be used. | 
