Crops Committee – Petitioned and Sunset Materials

• Committee recommendations were made without updated Technical Reviews (TR). TRs were requested but either not received or considered inadequate.
  
  
• Committee Recommendations were made with a lack of evidence or substantiation that alternatives to these materials exist and/or are effective.
  
  
• Committee recommendations on Sunset materials were made based on evidence that was not cited in the recommendation.
  
  
• Committee recommendations were made without consideration of pertinent new information.

The Decision Making Process

The pattern we observe in the decision making process is one that tends towards removal of a synthetic because it’s a “synthetic”, rather than whether it’s essential, or whether equivalent alternatives are available.

OTA supports the decision-making process and the removal or retention of a material based on the “Force of Evidence”. It is not acceptable to growers or the organic sector as a whole to make decisions that are not based on factual evidence and thorough evaluation to all of the criteria for organic materials review. As stated in the NOSB’s Policy and Procedures Manual under the Sunset Review Process:

The review is conducted based on “Force of Evidence” as presented by Board members, public comments, and scientific data from other sources. This includes the original recommendation from the Board to list. The committee may request a third party technical review, if needed, to verify scientific evidence and claims made during public comment to the ANPR.

In several of the Crops Committee Recommendations, there has been nothing put forward in the way of new evidence about harmful affects on crops, soils or people or the availability of a proven effective alternative.

In order to demonstrate our concerns, we are providing specific examples in the named materials below:

Tetracycline (Petition to Change Annotation) & Streptomycin (Sunset)

In regards to tetracycline, alternatives were mentioned in one case but when one reads the site referenced, it’s clear that the alternative (Psuedomonos) is not a viable (equivalent) alternative. The OTA asks that the NOSB give careful consideration to the comments submitted by our expert members on the lack of equivalent alternatives.

Based on feedback from our membership, and supported by the information included in the petition for tetracycline, the removal will result in significant disruption to the organic apple and pear growing segment of the tree fruit industry. The removal will ultimately result in significantly fewer acres devoted to the growing of organic apples and/or pears in the United States.

In the case of Streptomycin, a Technical Review was not received, yet the committee states, “it has found that the case against streptomycin has grown stronger and that removal from § 205.601 should be delayed no longer”. The proposal states “that the Crops Committee was presented with evidence that streptomycin can contribute to antibiotic resistance in human pathogens when used as a pesticidein plants”. No such evidence was included with the proposal nor made available to the public.

Biological alternatives were named as well, but the source of information was not provided nor was supporting evidence of effectiveness. The committee acknowledges that they are recommending the removal without the benefit of an updated Technical review and that they will reconsider listing when updated Technical Review is available. Unfortunately, it is not within the mandate of the NOSB to do this. Once off the list, the NOSB cannot reconsider without a petition.

According to our members, Tetracycline and Streptomycin are the only substances with a proven and reliable record of fire blight control in regions where alternative control measures have lost effectiveness and/or where biological options have yet to attain a comparable level of disease control. The suggestion to use resistant varieties and rootstocks is great in principle, but doesn't acknowledge the reality that a productive orchard can live 30 to 50 years and it is likely not an economical option for growers to cut down their orchard and replant with resistant varieties. The market determines what varieties are grown, and yet there is no evaluation of whether the resistant varieties available are acceptable or in demand in the marketplace.

We acknowledge the concern about the acceptability of antibiotics in organic production and agree we should be making every effort to find alternatives. We also agree that just like the use of any synthetic, ts use should be employed as needed and with justification. Our members have explained that while growers depend on these materials, they are not using them without justification. It’s our understanding for example that Washington State growers use a fire blight risk model in order to determine if the materials in question are needed or not. The model is based on the external temperatures during bloom, as well as other factors related to the tree (tree age, recent blight history, number of blossoms, etc.).

http://www.ncw.wsu.edu/treefruit/fireblight/mdl98c.htm.

We have also received considerable feedback on the research and steps that are continuously being made to find alternatives and urge the NOSB through public comment to learn more about these efforts.

Nickel (Petitioned Item)

OTA is concerned that the Crops Committee did not have pertinent information when making their decision. The Technical Evaluation Report dated Tuesday, August 17, 2010, and compiled by the USDA Technical Services Branch for the USDA National Organic Program does not mention that American Association of Plant Food Control Officials (AAPFCO) recognizes nickel as an essential micronutrient, and deficiency can cause significant damage to certain crops.

AAFPCO is the organization in North America, including the United States, which determines the standard for micronutrients, which may be included in fertilizer sold in the various States. Membership in AAPFCO includes U.S., EPA and State control officials. AAFPCO has stringent requirements for metals in fertilizers. Attached is a pdf of the AAPFCO document Scientific Basis for Risk-Based Acceptable Concentrations of Metals in Fertilizers and Their Applicability as Standards.

In 2007, AAPFCO officially redefined its “Official Term T-9:”

“Secondary and Micro Plant Nutrients,” to include nickel in the list of recognized micro plant nutrients. Official Term T-9 now reads as follows: “Secondary and Micro Plant Nutrients – Those other than the primary nutrients that are essential for the normal growth of plants and that may need to be added to the growth medium. Secondary plant nutrients shall include calcium, magnesium, and sulfur; micro plant nutrients shall include boron, chlorine, cobalt, copper, iron, manganese, molybdenum, nickel (Official 2007), sodium and zinc. (Official 1965)"

We urge the NOSB to act on this new information.


Magnesium Sulfate (Sunset Item)
The committee received a Technical Review but considered it insufficient and sent it back with questions about the differences in natural and synthetic magnesium sulfate, availability of both, and the functionality of both forms as soil amendments and foliar sprays. The issue is in this case is whether the nonsynthetic form of magnesium sulfate can adequately fill the need of the organic industry. If the committee had substantial evidence of a suitable and effective nonsynthetic alternative, a committee recommendation for the removal of the synthetic form would be appropriate. However, there is no evidence presented. There is no scientific data and there is no new information about health effects or viable alternatives.

Magnesium sulfate was petitioned, reviewed and added to the National List according to the required material review process. If the committee does not have evidence of an alternative or new information demonstrating that the material is not compatible with organic production, a recommendation for its removal is not appropriate.

If naturally mined sources of magnesium sulfate become available in adequate quantity and quality to supply the organic industry, then, and only then, should the listing of magnesium sulfate be considered for removal from the National List.

Ethylene Gas (Sunset Item)

The committee did not present evidence that an alternative exists. OTA recognizes the comments submitted by our members and asks the NOSB to carefully consider their concerns.

Pheromones (Sunset Item)

The Crops Committee once again has not yet received a Technical Review or provided any evidence showing that there are harmful effects from pheromones (already without List 3 inerts or other “toxicants”) used in active dispensers. As we understand it, pheromones are used either for trapping or for mating disruption. By limiting organic farmers to “Passive Dispensers” the purpose of mating disruption is aborted or seriously infringed. The phrase “added toxicants” may be problematic, as it could be interpreted to prohibit use of allowed pest control substances (e.g. botanicals) in combination with pheromones.

A thoroughly done Technical Review would examine these new technologies and help the NOSB arrive at a better definition of passive at the very least, and also indicate if there is any reason to reject these new technologies before they get off the ground to benefit organic farmers. The EPA should also be engaged to weigh-in on this issue before any decision is made.

Sulfur Dioxide (Sunset Item)

The Crops Committee decision is based on a new Technical Review stating that sulfur dioxide may not be the appropriate active ingredient in smoke bombs and is not listed by EPA for use as a rodenticide. However, U.S. EPA has registered rodent control smoke bombs with the active ingredients sulfur, charcoal carbon, and sodium nitrate or potassium nitrate (saltpeter).

Neither the Committee nor the Technical Review indicates any alternative methods, which are feasible on a commercial scale for the control of underground rodents. Predator species should be encouraged, but without the option of smoke bombs organic producers may be subject to gopher population cycles that are not able to be kept in check with biological controls (predators) alone.

The Committee does not suggest what substance(s) would need to be petitioned as the active ingredient(s). If one or all of the ingredients or the general category of “smoke bombs” would have to be petitioned for inclusion on the list, the process of approval may take longer than the Sunset date of October 21, 2012 and will leave farmers without adequate controls of underground rodents.

Since the sulfur dioxide resulting from igniting the combination of the ingredients in the smoke bomb is clearly the substance that kills the rodents, it should be considered the active ingredient for this purpose.

The recommendation does not suggest that this use of sulfur dioxide fails any of the materials review criteria. And, this allowance is consistent with that included in Canada’s regulation.

In support of the other commenters, one possible solution is that instead of delisting, the listing could be amended to read “sulfur dioxide – produced by the ignition of smoke bombs for underground rodent control only.”


The Farmer’s Toolbox is Limited

OTA supports the goal and dedicated efforts of moving away from synthetics in favor of cultural, mechanical, biological, and natural farming methods, however the removal of a material before an alternative is economically and effectively viable will injure the organic industry. Furthermore, the removal of a material in order to motivate the creation of an alternative is a reckless approach. There are other steps that need to be taken in a sensible and economical approach as we work towards the development and use of nonsynthetic alternatives These steps range from USDA supported on-farm research and grants to the integrated stepwise approach that should be practiced by each certified producer.

In all considerations, OTA would like to reiterate and remind the NOSB of following steps outlined in the NOSB Policy and Procedures manual:

• The NOSB committee begins review of the a material with the intent of providing arecommendation to the entire Board for the material’s removal, renewal or renewal with the addition of an annotation.
  
  
• The review is based on Force of Evidence” as presented by Board members, public comments, and scientific date from other sources.
  
  
• This includes the original recommendation from the Board to list.