As we envision it, the substance used to unclog the drip irrigation lines
would probably fall into the "non-active" category of production aids, as
long as there was no other function (like supplemental crop nutrition from
phosphoric acid) involved. In that case, the grower would still have to
choose a non-synthetic (such as mined baking soda or
vinegar--organically produced would be first choice, but not essential) to
achieve the necessary purpose. If there was no suitable non-synthetic
(natural) product available for the purpose, a synthetic substance could
be used. Since baking soda is already on the Proposed National List as
an allowed non-agricultural ingredient in organic foods, the issue of
whether the source was mined or not would not be of great
consequence to the certifiability of the system.
We did it this way to avoid "clogging up" the National List process with
things that are really and truly inconsequential to the integrity of the
organic product and to the environment, such as spreader-stickers, etc.
There are plenty of more substantive concerns that the NOSB should be
spending its time considering.
Details such as these will be addressed in the context of the Program
Manual, which will have to be developed in consultation with the people
who have to live by and work with the regulations.
Grace Gershuny
USDA National Organic Program staff
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