Hello,
Under OFPA, there is no "nonactive production aid" allowed to be considered
for use in organic farming. The USDA National Organic Program staff have
developed the concept to allow the introduction of innumberable number of
synthetic substances in organic farming.
Under OFPA, all natural substance are permitted unless they are specifically
prohibited by use or application. Any natural irrigation emitter unclogger is
acceptable under OFPA.
Ms Gershuny" 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."
My comments: There is no need to clog up the National List with synthetic
substances. All synthetic substances used in farming are prohibited under
OFPA but in the twenty categories listed under Section 2118(c)(1)(B)(i) One
of them is equipment cleansers. On further thought a synthetic substance used
to unclog an irrigation emitter could be labeled an equipment cleanser, though
I do not think that was the intention of the OFPA drafters. If we take OFPA
literally it states any active synthetic substance used as an equipment
cleanser must be petitioned by specific use and application, reviewed and
evaluated by the NOSB and recommended to the Secretary for final review and
evaluation to be acceptable for use. Worth a try.
The USDA/NOP staff and their adminstrators have massaged OFPA into a rotten
tomato rationalize that all is done for consideration of the NOSB members,
expansion of organic farming markets and to clarify "organic" to the consumer.
OFPA is lucidly clear. It will take us, the consumer, organic farmer and
handler to read the law and insist on its integrity being upheld. It is
criminal to ask organic farmers to continue to innovate, build markets and
supply, participate in NOSB meetings for 5 years and have to correct an ill-
informed, being kind with our words, organic-rats, who refuse to follow the
Act of Congress.
Please offer your comments.
Best, Eric Kindberg
§2118 NATIONAL LIST.
(a) IN GENERAL. The Secretary shall establish a National List of approved and
prohibited substances that shall be included in the standards for organic
production and handling established under this title in order for such
products to be sold or labeled as organically produced under this title.
(b) CONTENT OF LIST. The list established under subsection (a) shall contain
an itemization, by specific use or application, of each synthetic substance
permitted under subsection (c) (1) or each natural substance prohibited under
subsection (c)(2).
(c) GUIDELINES FOR PROHIBITIONS OR EXEMPTIONS. (1) EXEMPTION FOR PROHIBITED
SUBSTANCES. The National List may provide for the use of substances in an
organic farming or handling operation that are otherwise prohibited
under this title only if
(A) the Secretary determines, in consultation with the Secretary of Health and
Human Services and the Administrator of the Environmental Protection Agency,
that the use of such substances
(i) would not be harmful to human health or the environment;
(ii) is necessary to the production or handling of the agricultural product
because of unavailability of wholly natural substitute products; and
(iii) is consistent with organic farming and handling;
(B.) the substance
(i) is used in production and contains an active synthetic ingredient in the
following categories: copper and sulfur compounds; toxins derived from
bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed,
vitamins and minerals; livestock parasiticides and medicines and production
aids including netting, tree wraps and seals, insect traps, sticky barriers,
row covers, and equipment cleansers;
(ii) is used in production and contains synthetic inert ingredients that are
not classified by the Administrator of the Environmental Protection Agency as
inerts of toxicological concern; or
(iii) is used in handling and is non-synthetic but is not organically
produced; and
(C) the specific exemption is developed using the procedures described in
subsection (d).
Date: Sun, 22 Feb 1998 22:16:00 -0500
From: Grace J Gershuny <Grace_J.Gershuny@usda.gov>
Subject: Organic National List and irrigation emitter clogging -Reply
I don't know whose posting that was giving an interpretation of how this
situation would be handled under the proposed USDA regulations, but
since someone has broached it I'm gonna jump in.
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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