dave’s notes . . . . . . . . . . 2 materials liquid fertilizer ... · sample of nortech gold...

8
Materials News and Information for the Organic Community Winter 2010 The Compost Conundrum Farming in a Contaminated World NOSB Meeting Report November 3–5, 2009, Washington, DC T he National Organic Standards Board recommended allow- ing GMO vaccines and excipients, and expanding the allowed uses for chlorhexidine and xylazine in live- stock applications. Discussion top- ics included nanotechnology and inert ingredients in pesticides. Overall, the commiee voted on 18 materials. Of these, there were three crops materials, five livestock materials and ten pro- cessing materials. For more detail on these materials, see page 7. e Board passed several other recom- mendations concern- ing retailer certification guidance, animal welfare, bivalve aquaculture, clarifica- tions to various sections of the Board Policy & Procedures Manual, and Standards for personal body care products. is last recommen- dation was meant to spur action on the development of new standards by allowing the NOP to set a clear direction on the issue. Miles McEvoy stated that the Program will take the IN THIS ISSUE Dave’s Notes 2 Liquid Fertilizer 3 New OMRI Staff 3 Materials Q&A 4 NOSB Recommendations Chart 7 Calendar 8 Compost continued on page 6 review NOSB continued on page 7 By Matt Sircely T he discovery of bifenthrin and DDE residues in three brands of compost in Cali- fornia has prompted materials reviewers, organic certifiers and compost producers to quickly prepare input toward developing guidelines at the National Organic Program (NOP). Still at a formative stage, the projected NOP guidelines may include tolerance levels and strengthened testing protocols for organic inputs such as compost. Routine pesticide residue screening at a produce distribution point, followed with testing by the California Department of Food and Agricul- ture (CDFA), revealed the contaminants in a sample of wheatgrass blended with the compost it was growing in. When the first sample of Nortech Gold compost tested positive in August, the grower then sourced other composts: Grover’s Wonder Grow Compost and, subsequently, Feather River’s Clean City Compost. When both the sec- ond and third products tested positive for residual contamination, the CDFA swiſtly re- sponded by disallowing the use of the three iden- tified products in organic agriculture. “OMRI has removed Nortech Gold Compost from our list and is in the process of investigating the other two composts,” says Renee Mann, OMRI’s Review Program Manager. “Because we afford due process to our clients, we allow time for them to be notified of our investigation, and to prove that their product is, in fact, compliant with the NOP Rule. For that reason, two of the three products are still on OMRI’s list, but those two are under investigation.” e three identified compost producers all draw their feedstocks from urban yard waste through California’s ambitious green waste recycling Testing by the CDFA revealed contaminants in wheatgrass blended with compost. OMRI-647 winter2010 nl.indd 1 1/10/10 12:01 PM

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Page 1: Dave’s Notes . . . . . . . . . . 2 Materials Liquid Fertilizer ... · sample of Nortech Gold compost tested positive in August, the grower then sourced other composts: Grover’s

MaterialsNews and Information for the Organic Community Winter 2010

The Compost Conundrum Farming in a Contaminated World

NOSB Meeting ReportNovember 3–5, 2009, Washington, DC

T he National Organic Standards Board recommended allow-

ing GMO vaccines and excipients, and expanding the allowed uses for chlorhexidine and xylazine in live-stock applications. Discussion top-

ics included nanotechnology and inert ingredients in pesticides.

Overall, the committee voted on 18 materials. Of these,

there were three crops materials, five livestock materials and ten pro-cessing materials. For more detail on these materials, see page 7.

The Board passed several other recom-

mendations concern-ing retailer certification

guidance, animal welfare, bivalve aquaculture, clarifica-

tions to various sections of the Board Policy & Procedures Manual, and Standards for personal body care products. This last recommen-dation was meant to spur action on the development of new standards by allowing the NOP to set a clear direction on the issue. Miles McEvoy stated that the Program will take the

IN THIS ISSUEDave’s Notes . . . . . . . . . . 2

Liquid Fertilizer . . . . . . . 3

New OMRI Staff . . . . . . . 3

Materials Q&A . . . . . . . . 4

NOSB Recommendations Chart . . . . . . . . . . . . . . . 7

Calendar . . . . . . . . . . . . . 8

Compost continued on page 6

r e v i e w

NOSB continued on page 7

By Matt Sircely

T he discovery of bifenthrin and DDE residues in three brands of compost in Cali-fornia has prompted materials reviewers, organic certifiers and compost producers

to quickly prepare input toward developing guidelines at the National Organic Program (NOP). Still at a formative stage, the projected NOP guidelines may include tolerance levels and strengthened testing protocols for organic inputs such as compost.

Routine pesticide residue screening at a produce distribution point, followed with testing by the California Department of Food and Agricul-ture (CDFA), revealed the contaminants in a sample of wheatgrass blended with the compost it was growing in. When the first sample of Nortech Gold compost tested positive in August, the grower then sourced other composts: Grover’s Wonder Grow Compost and, subsequently, Feather River’s Clean City Compost. When both the sec-ond and third products tested positive for residual contamination, the CDFA swiftly re-sponded by disallowing the use of the three iden-tified products in organic agriculture.

“OMRI has removed Nortech Gold Compost from our list and is in the process of investigating the other two composts,” says Renee Mann, OMRI’s Review Program Manager. “Because we afford due process to our clients, we allow time for them to be notified of our investigation, and to prove that their product is, in fact, compliant with the NOP Rule. For that reason, two of the three products are still on OMRI’s list, but those two are under investigation.”

The three identified compost producers all draw their feedstocks from urban yard waste through California’s ambitious green waste recycling

Testing by the CDFA revealed contaminants in wheatgrass blended with

compost.

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2 OMRI Materials Review

OMRI is a 501(c)(3) nonprofit organization created to benefit the organic community and the general public. Its mission is to provide professional, independent, and transparent review of materials and processes to determine their suitability for producing, processing, and handling organic food and fiber. OMRI is a member of the Organic Trade Association and of the International Federation of Organic Agricultural Movements.

BOARD OF DIRECTORSOfficers:

Chair: Ramkrishnan P. Balasubramanian Vice-Chair: Katherine Withey Secretary: Mark Whalon Treasurer: Bob Scott

Members: Cissy Bowman, Jenneke DeJong, Jake Lewin, Salvatore (Sandy) Parco, Jennifer Ryder Fox, Eric Sideman, Bill Stoneman, and Catherine (Anne) Wells

STAFFExecutive Director: David DeCou Review Program Manager: Renee Mann Technical Director/Quality Manager:

Lindsay Fernandez-SalvadorMarketing and Communications Coordinator:

Amy Bradsher Information Technology Specialist: Brian Basor Application Specialist: Amber Lippert Product Review Coordinators:

Tina Jensen Augustine, Andrea (Gwen) Ayres, Jennifer M. Schomp, Deder Siedler, and Annie Amos

Review Program Assistants: Jean Schauerman, Andria Schulze

Program Asst/Project Asst: Ashley WrightRenewals Coordinator: Cindy Coachman Bookkeeper: Melody Carr Administrative Specialist: Blyss Hansen

OMRI Materials Review is published quar-terly by OMRI. Volume 12, Issue 1. Except for reprinted or copyrighted articles, subscribers may reprint OMRI articles, provided that OMRI is given as the source. Reasonable efforts are made to provide useful and accurate information, but the editors and OMRI cannot assume any liability for errors or omissions.

Assistant Editor: Keith L. ProctorDesign: Slub Design, www.slubdesign.com

OMRIP.O. Box 11558 Eugene, OR 97440-3758, USAP: 541.343.7600 • F: [email protected] • seeds.omri.org

I have participated in the organic industry for 25

years now and once again I have witnessed a year full of change and unan-ticipated events. January began with deep concern for the integrity of the liquid fertilizer industry. Spring was full of expectation for a US-Canadian or-ganic equivalency agreement. Summer revisited the issue of pesticide residues in compost. Fall saw a new Deputy Adminis-trator at the NOP. As we approach winter, more concerns have been raised at the re-cent NOSB meeting. Clearly these are is-sues with which OMRI has a deeper con-nection than others.

A consistent aspect of these issues is the difference in understandings between or-ganic consumers and those people more intimately involved with the details of the organic certification system. Consumers have casual impressions and opinions re-garding certification but seldom have time to understand all the details and compro-mises involved. One example is the liq-uid fertilizer situation. Prior to the NOP prohibition of the Port Organic products, OMRI had investigated and prohibited them. However, because we use a system described as “due process,” we could not announce the prohibition until the 30-day appeals period had expired. It was during this period that the FBI raided the Port Organic facility and the NOP issued its prohibition. In some ways we acted soon-er than the NOP, but from a consumer’s point of view we did not. Our due process system is aimed at protecting manufactur-ers and allowing them their day in court.

During the pursuant hearings by the California Senate Food and Agriculture Committee in February, there was steady demand for lab analyses and inspections. The politicians wanted simple answers to

a complex situation. Currently no single lab test can consistently and conclusively determine if a fertilizer is made from al-lowed materials. Several different tests can give a strong indication but the science is not there yet. Inspections are also a great tool, but they are just observations made on one day for a few hours. What happens at other times can only be inferred from records. How might an inspector ascer-tain that a purchased ingredient is actually what it claims to be? This line of question-ing is never-ending and yet it must end somewhere.

The issue of pesticide residues is per-haps our greatest concern. As long as compost makers are not using prohibited materials, the issue comes down to this: Should we allow compost feedstock with residues? Consumers will often say no. But we live in a world that is not pure. Labora-tories can routinely test to parts per billion and beyond, but at those levels just about anything might be found. Yard clippings, the apparent source of the problem, can and will contain the residues of pesticides used on the yard. Do we want to prohibit yard clippings in organically acceptable compost? Do the small amounts of resi-dues present a real problem? Do we expect all inputs used on organic farms to be per-fectly clean? What are the consequences for the organic industry and for recycling and sustainability if we draw a line too harshly on these questions? OMRI is only in a position to ask these questions. Con-sumers usually expect simple answers, but our answers often create more questions. Organic production is generally expected to use sustainable methods. However, if we draw an impermeable line between organic farming and recycled urban yard waste, then we might also be drawing the same line between organic farming and sustainability itself.

Farm, Recycle, Sustain By Dave DeCou

DAVE

’S NOTES

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Winter 2010 3

By Keith L. Proctor

I n the wake of the liquid fertilizer ingre-dient problem within the organic in-

dustry earlier this year, OMRI is inspecting brand name input materials and product manufacturing locations in order to verify their conformance to National Organic Program (NOP) standards: specifically, the criteria for liquid fertilizers with nitro-gen content greater than 3%, per the Feb-ruary 20, 2009, NOP notice (www.omri.org/ACAFertilizerNotice2009-02-20.pdf).

Beginning a few years ago, some growers and certi-fiers became con-cerned at the abun-dance of liquid fertilizer products with nitrogen con-tent greater than 3% marketed to organic growers. In January 2009, California Certified Organic Farm-ers (CCOF) issued a new Liquid Fertil-izer Approval Policy to its certified clients. CCOF’s policy was taken largely verbatim by the NOP and reissued in their Febru-ary 20 notice to certifiers. This notice in-cluded a “100-yard distance” requirement, which the NOP later removed in a Policy Statement on December 14, 2009. The NOP directly named two products that were no longer in compliance: Marizyme and Agrolizer, both manufactured by Port Organic, Ltd. The notice stated that the NOP was “no longer confident” that these

“products can be shown to be compliant with the NOP regulations.”

In July 2009, the liquid fertilizer prob-lem grew larger still when another set of products, Summit 14, 10 and 7 Organic Nitrogen Soil Supplements made by Sum-mit Organic, Inc., was specifically prohib-ited from organic production due to what the NOP called a lack of “sufficient infor-mation to support … compliance with the NOP regulations.”

Inspections

The standards for OMRI’s new third-party materials in-spection process include new audit-able procedures on ingredient sources, arrival, storage, handling, equip-

ment cleaning, flushing, lockouts, product conveyance, transportation infrastructure, records of in and out balance and devia-tions, results of unannounced inspections, and nitrogen content where appropriate.

As the NOP indicated in their statement concerning Summit Organic products, the lack of sufficient information to support compliance is a standard by which they can and will judge a product. OMRI has always provided greater due process in our reviews than is apparent in the Summit case, but the lack of necessary information provided by suppliers can also be a trigger

Liquid Fertilizers OMRI Inspection Update

Welcome New StaffStaff Changes at OMRI

A s part of our effort to improve and expand our services, OMRI has

hired several additional staff members.

Review Program Assistants

Andria Schulze holds a B.S. in Geol-ogy from Rensselaer Polytechnic Institute where she researched the accumulation of PCBs in the Hudson River. She has profes-sional experience in many areas including quality assurance in the food industry, laboratory analysis, and geotechnical as-sessment. She is also an award-winning short fiction writer. Andria can be reached at extension 112 or at [email protected].

Administrative Specialist

Blyss Hansen holds a B.A. in Commu-nications from the University of Wyoming with emphasis on human and multime-dia communications. She has over ten years experience working with the pub-lic and over three years experience in the nonprofit sector. Blyss has completed in-ternships in the public relations and edu-cation fields and most recently served as the Director of Operations and Develop-

Staff continued on page 5

NEED ORGANIC SEEDS?THE OMRI SEEDS DATABA SE MAKES IT E A SY TO FIND ORGANIC SEEDS

FOR ANY ORGANIC FARM OR GARDEN.

Fast, Easy and Free • Search Multiple Sources • Printable Results

WWW.OMRI.ORG/SEEDS

Liquid Fertilizer continued on page 5

Growers and certifiers

became concerned at the

abundance of liquid fertilizer

products with nitrogen

content greater than 3%…

REQUE ST FOR F UNDINGThe Organic Trade Association is lead-

ing a fundraising effort to support an innovative research project focused on preventing fertilizer fraud. The project aims to develop a means of detecting the use of synthetics in fertilizers for organic production. Already partially funded by the California Department of Food and Agriculture, the project re-quires another $40-80,000 in matching funds. Contact Jane Sooby of the Organ-ic Farming Research Foundation at 831-426-6606, [email protected].

In an industry facing increased test-ing and inspections, this project will pro-vide an invaluable tool for eliminating fraud and protecting organic integrity.

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4 OMRI Materials Review

The OMRI Generic Materials List says that rockwool is synthetic and thus prohibited for use in organic agriculture. After doing some research, it looks to me like it is made from a natural basaltic rock. Why does OMRI consider it synthetic?

R ockwool, also called mineral, rock, or slag wool, is one of the most pop-

ular growing mediums in hydroponics op-erations due to its versatility and water re-tention characteristics. It is manufactured from melting basaltic rock and spinning the molten rock into fibers. After spinning, a binder is added to the fibers and they are compressed and cured into large slabs, which can be later cut up into convenient sizes and shapes. This process changes the functional properties of the basaltic rock to make the final substance an exceptional substrate for water and air exchange. This process is also the main reason that rock-wool is considered synthetic.

NOP Rule §205.105(a) prohibits the use of “synthetic substances and ingre-dients, except as provided in NOP rule §205.601 or §205.603.” OMRI uses the definition of “synthetic” as it appears in NOP Rule §205.2, as well as the March 2006, NOP-proposed decision tree to de-

termine if a given substance is synthetic or nonsynthetic. When using the decision tree to determine if the manufacturing process renders rockwool synthetic, three questions apply:

1. Does the substance contain any syn-thetic substances not on the National List? Maybe; various binders are used in the manufacturing of rockwool, which could be either synthetic or nonsynthetic. The binder would need to be disclosed to know for sure.

2. Has the substance been transformed into a different substance via a chemical change? No; basaltic rock undergoes a physical change from solid rock to fibrous strands through heat and mechanical processes.

3. Are any important function-al properties of the substance al-tered by the manufacturing pro-cess? Yes; basaltic rock has little water and air retention capacity, while rockwool has exceptional water and air retention capacity.

Answering “Yes” to any of these three questions means the substance is synthetic. Since the answers to ques-tions 1 and 3 are “Maybe” and “Yes,” rock-wool is classified as synthetic and thus pro-hibited for use in organic agriculture.

According to NOP Rule §205.603(f), synthetic excipients need to be identi-fied by the FDA as “Generally Recog-nized As Safe” (GRAS). My client wants to use an excipient that was identified as GRAS but it doesn’t appear in the FDA’s GRAS database or the applicable regulations. How can I determine if a substance is GRAS?

GRAS, or “Generally Recognized As Safe,” is a system in which sub-

stances are found to be safe for use in food. There are two ways that a substance is determined to be GRAS. The first way is through the affirmation process with the FDA. You can find a list of the direct and indirect food additives that the FDA has confirmed as GRAS under 21 CFR Part 182, Part 184 and Part 186. The FDA also maintains the GRAS Inventory Notice Database, which contains a list of submit-ted petitions and affirmations by the FDA of GRAS substances.

Another way that a substance is deter-mined to be GRAS is through “self-affir-mation,” which is undertaken by private organizations who review specific techni-cal information about the substance. There are several private organizations that self-affirm GRAS substances for companies, including the Flavor and Extract Manu-facturing Association (FEMA). The FDA considers GRAS a voluntary program, and

M A T E R I A L S Q & A

Rockwool, Synthetic or Not?

FDA GRAS

CROP

S

CROP

S

L IVE

STOCK

by Lindsay Fernandez-Salvador

The final decision as to whether a specific use or application of any given input is permitted on a particular operation is the responsibility of the accredited certification agent.

now the majority of new substances are found to be GRAS by self-affirmation. The FDA publicly accepts self-affirmed GRAS substances as de facto FDA-approved GRAS substances.

According to NOP Rule §205.603(f), synthetic substances are allowed as excipi-ents in livestock drugs as long as they are

identified by the FDA as GRAS. OMRI has not yet determined whether the NOP considers “self-affirmation” GRAS as equivalent to FDA GRAS affirmations contained in official regulations. We wel-come any suggestions or insight into this matter to help us come to a decision. E-mail [email protected].

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Winter 2010 5

Q&A SEND YOUR QUE STIONS Email or mail your materials questions to OMRI. OMRI wishes to help address common questions about the organic standards. If we select your question for the FAQ section of the newsletter, then you will be notified prior to printing it. Email [email protected] with ‘FAQ’ as the subject or mail your question to: OMRI, Newsletter FAQ, PO Box 11558, Eugene, OR 97440.

Sorbitan MonostearateA processor wants to use a baker’s yeast that lists sorbitan monostearate as a component of the yeast. Is sorbitan monostearate synthetic?

S orbitan monostearate is a synthet-ic ester that is commonly used in

the manufacture of food and health care products

as a surfactant with emulsifying, dispers-ing, and wetting properties. It is used in yeast manufacturing to protect the yeast from excess drying and also helps rehy-drate the yeast cells. Most of the baker’s yeast on the market contains sorbitan monostearate. Sorbitan monostearate does not appear under §205.605(b) of the National List as an allowed synthetic substance in processed products labeled as “organic” or “made with organic in-gredients.” However, many Accredited

Certifying Agencies (ACAs) do not consider sorbitan monostearate as

an ingredient or processing aid. Rather, some ACAs consider it

an incidental component of an allowed ingredient, and so it is not subject to the criteria of the NOP Rule. Other ACAs believe that since baker’s yeast can be produced without sorbitan monostearate, yeast containing this synthetic sub-

stance would not be allowed in organic processed products.

Producers should check with their ACA for prior approval before using

yeast with sorbitan monostearate.

PROC

ESSING

ment for a science museum in Wyoming. Blyss can be reached at extension 100 or at [email protected].

Application Specialist

Amber Lippert holds a B.S. in agricul-ture from Oregon State University and credit towards a Masters of Agriculture Education. Her professional experience includes work on organic and transitional farms in Oregon and Washington as a producer, administrator and manager for five years. As a student volunteer, Amber spent four months studying regenerative agriculture on two farms in Costa Rica and Nicaragua. Prior to joining OMRI, Amber worked in environmental educa-tion where she developed curricula for K-12 and coordinated habitat restoration projects. Amber can be reached at exten-sion 105 or at [email protected].

Staff continued from page 3

Liquid Fertilizer continued from page 3 for removal from the OMRI Products List.

The legal authority on which the NOP is based gives the NOP the power to super-vise certifiers and enforce the standards, but it does not provide direct authority over input manufacturers and suppliers. Such rules must be enforced via certifiers and other third-party reviewers such as OMRI and WSDA.

Until early December 2009, OMRI had a list of inspected manufacturers and sup-pliers on the OMRI Web page (www.omri.org). The products on this list fell into two categories: those in compliance (in green) and those with incomplete information (in yellow). OMRI has since removed that list and completed its compliance reviews of liquid fertilizer products. Now a prod-uct is either currently in compliance with the February 20, 2009, NOP directive (and therefore OMRI Listed) or no longer OMRI Listed.

This has been and continues to be a complex and confusing issue for many in the organic world. Please contact your certifier with any questions that pertain to this topic and your certified operation.

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6 OMRI Materials Review

program. Starting in 1989 with mandates to divert half of landfill waste to recycling by 2000, and now targeting cuts in green-house gas emissions from landfills, the program’s supply of inputs to organic agri-culture has helped fuel its success.

The discovery of pesticide residues in compost derived from green waste sparked a meeting of stakeholders and government agencies in Sacramento. While compos-ters sounded the alarm over contaminants in the municipal waste stream and asked for a grace period in anticipation of regu-latory guidance, the NOP began looking into establishing tolerance levels for un-avoidable residual environmental con-tamination.

In late November, the Accredited Cer-tifiers Association formed a committee around the subject. The National Organic Standards Board (NOSB) intends to ad-dress the issue at its upcoming meeting in April 2010, although the NOP may issue guidance sooner.

NOP rules allow for trace levels of cer-tain pesticide residues on organic food, but there is currently no rule for allowance in organic inputs. DDE, a degraded form of DDT, is a widespread environmental con-taminant that takes decades to break down.

Bifenthrin, a synthetic pyrethroid, has been applied in conventional agriculture since the 1990s. In recent years, bifenthrin has emerged in dozens of over-the-coun-ter products marketed to kill ants and turf insects in household applications. “All of those yard trimmings are finding their way to composting facilities, and [the preva-lence of bifenthrin has] been growing substantially over the last few years,” says Neil Edgar of Edgar and Associates, who represents compost producers statewide in Sacramento.

Manufacturers guarantee that bifenthrin is not taken up by plants. It is not soluble in water, but tightly binds to soil and moves with sediment runoff. California’s Depart-ment of Pesticide Regulation has been undergoing a re-evaluation of bifenthrin since 2006, mostly because of widespread

stream bed contamination and toxicity to fish and aquatic microorganisms. Now, the inquiry will reportedly expand to consider the persistence of bifenthrin throughout the composting process.

“Ordinarily, we can break down any or-

ganic hydrocarbon, which is the base of most insecticides and herbicides, in the compost process and we always have,” said Mark Grover of Modesto, Calif., one of the affected compost producers. “But the only thing that breaks bifenthrin down is sunlight.”

There is broad agreement that more re-search is needed on bifenthrin and other persistent contaminants. In the meantime, the Washington State Department of Ag-riculture (WSDA) Organic Food Program has established guidelines for internal use while awaiting clarification from the NOP. The interim guidelines for inputs mirror those for organic produce, tying the al-lowed contamination threshold to 5% of the lowest EPA tolerance for any conven-tional crop, says Lisa Brines, Materials Re-view Specialist at WSDA, stating that the guideline is “pretty strict in terms of the amount that’s allowed.”

Emily Brown-Rosen, Policy Director at Pennsylvania Certified Organic, says that while additional research would in-form the setting of tolerance levels, initial steps are best made cautiously. “Maybe if we could get more university research, then we could eventually have a thresh-

old for inputs that is more science-based rather than precautionary- and regula-tory-based.” She and other certifiers are also assessing the cost burden of any ad-ditional testing protocol on inputs from risk-prone sources.

Steve Thun, owner and Laboratory Di-rector of Pacific Agricultural Laboratory in Portland, Ore., includes both bifen-thrin and DDE in a halogenated pesti-cide screen priced at $160. The microbial activity and nutrients in compost make low detection more difficult, and screen-ing for a higher number of chemicals at once generally increases the detectable threshold as well. Chlorpyralid falls un-der another testing category altogether, priced at $175. “[Testing is] expensive so you don’t want to do more than you need to,” Thun explains. “But if producers know that there’s testing, that can help steer practices.”

Meanwhile, Mark Grover is already re-searching how to reduce the bifenthrin levels in his finished compost by length-ening the process and exposing it to more sunlight. “The things that we’ve tested have generally been about one tenth of one part per million (ppm) of bifenthrin. It’s coming on the grass, mostly. Through the compost process, we found that we can get it down to 0.06% of one ppm, which is almost insignificant. But you can’t get it down to zero hardly. It’s almost im-possible.”

Will Bakx of Sonoma Compost doubts that blending alternate feed stocks would fully mitigate the bifenthrin issue, even as food waste is a rapidly growing component of California’s green waste stream. When he speaks of solutions, Bakx remembers how certifiers banded together to curb the prevalence of chlorpyralid when the herbicide first appeared in inputs contain-ing straw in 2002. “We specifically asked CalDPR at that point to monitor new ap-plications for pesticides so that they would pose no threat to the composting industry, and here we are. To me, there’s a real regu-latory flaw,” he says. “It’s a situation that needs to be corrected quickly.”

Compost continued from page 1

NOP rules allow for trace

levels of certain pesticide

residues on organic food,

but there is currently

no rule for allowance

in organic inputs. DDE,

a degraded form of DDT,

is a widespread environmental

contaminant that takes

decades to break down.

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Winter 2010 7

recommendation into consideration and respond to the Board before the Spring 2010 NOSB meeting.

Materials Committee

The majority of public comments sup-ported the prohibition of nanotechnology in organic production. However, the Board did not want to prohibit natural materi-als that can be found in nanoparticle size, such as homogenized milk. They discussed how to define nanotechnology and how to prohibit nanotechnology, or some types of nanotechnology, in organic production.

Crops Committee

The Crops Committee did not support moving all of the currently allowed List 4 inert ingredients, which are exempt from a tolerance, onto the National List. Howev-er, the committee also acknowledged that it would be too time-consuming to conduct a full review of the 800 inerts that are exempt from a tolerance. They recommended ask-ing pesticide manufacturers for a list of in-ert ingredients currently in use. The NOSB would then review each inert ingredient. The NOSB is expected to vote on this doc-ument at the Spring 2010 meeting.

The recommendation to expand per-acetic acid’s use and allow it for plant disease control did not pass. The Com-mittee felt that peracetic acid could have a negative impact on soil ecology. However, the Committee recommended annotating the current listings to allow its use in hy-drogen peroxide formulations. The Com-mittee also passed a recommendation to re-list hydrogen chloride because alter-native materials do not exist to de-lint cot-ton. Mechanical means do not work well, as they tend to break the seed and create damage from heat.

Livestock Committee

The NOSB did not recommend the ad-dition of eprinomectin to the National List because other parasiticides are al-ready listed. There was a recommenda-tion (although not a petition) to allow all

vaccines produced by excluded meth-ods (GMOs). There were many reasons for this suggested change, the most com-pelling of which concerns the welfare of organic animals. Increasing numbers of vaccines are available only in GMO form, and the Board did not want to prevent the use of such vaccines for organic animals. Ultimately, the Board approved a revised recommendation, changing §205.105 to state “(e) Excluded methods, except for vaccines. Provided that vaccines manufac-tured without the use of excluded meth-ods be used, if commercially available.”

The Board passed a recommendation from the Livestock Committee to clarify the excipients listing on the National List. The Committee agreed that this clarifica-tion is needed to allow the expansion of the use of excipients in health care prod-ucts and not just animal drugs that are used to treat existing problems. The Board also expanded the allowed uses for both chlorhexidine and xylazine to include non-emergency health care applications.

Joint Materials & Handling Committee

The joint Materials and Handling Com-mittee presented its final recommendation on how the NOSB should define materi-als. This includes clarification of the pro-

cesses that cause a nonsynthetic material to become synthetic, and what is agricul-tural versus nonagricultural. One Board member did submit a minority opinion to disallow the use of synthetics in extracting nonsynthetic materials. The original rec-ommendation is very detailed, and can be viewed at: www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5079553&acct=nosb

The recommendation, with minor changes, was passed by the Board with a vote of 12-1-0-2 (1 opposed, 2 absent). Part of the recommendation requires that a guidance document be developed and published at the same time that the recommendation is implemented by the NOP. This will help the NOSB and public understand the new definition. The NOSB will develop the guidance document.

Future Work

The next meeting will be held in Cali-fornia in April 2010. The Crops Commit-tee will review ethylene glycol, polycap-rolactone, distilled tall oils, ethylene dda, difluoroethylene, terpenes and pgml. The Handling Committee will discuss glucos-amine, pectin, the expanded uses of cal-cium acid pyrophosphate and sodium acid pyrophosphate.

NOSB continued from page 1 Table of Votes on Petitioned Substances

Material NOP Rule (§) Outcome Vote*

Manganese Sulfate Monohydrate 205.601(j)(6)(ii) Already on the National List 13-0-0-2

Hydrogen Chloride 205.601(n) Re-listed 12-0-0-3

GMO Vaccines 205.105(e) Revision to 205.105(e) 11-2-0-2

Eprinomectin 205.603 Not added to the National List 13-0-0-2

Excipients 205.603(f) Revision of annotation 13-0-0-2

Chlorhexidine 205.603(a)(6) Revision of annotation 13-0-0-2

Xylazine 205.603(a)(23) Revision of annotation 13-0-0-2

Egg White Lysozyme 205.605(a) Re-listed 13-0-0-2

L-Malic Acid 205.605(a) Re-listed 13-0-0-2

Microrganisms 205.605(a) Re-listed 13-0-0-2

Activated Charcoal 205.605(b) Re-listed 13-0-0-2

Cyclohexylamine 205.605(b) Re-listed 10-2-1-2

Diethylaminoethanol 205.605(b) Re-listed 09-2-1-3

Octodecylamine 205.605(b) Re-listed 09-3-1-2

Peracetic Acid 205.605(b) Re-listed 13-0-0-2

Sodium Acid Pyrophosphate 205.605(b) Re-listed 13-0-0-2

Tetrasodium Pyrophosphate 205.605(b) Re-listed 13-0-0-2

*in favor – opposed – abstain – absent

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Page 8: Dave’s Notes . . . . . . . . . . 2 Materials Liquid Fertilizer ... · sample of Nortech Gold compost tested positive in August, the grower then sourced other composts: Grover’s

8 OMRI Materials Review

COMING IN 2010 OMRI’S NEW WEBSITE

Advanced Search Features • Individual Subscriber Accounts • Online Generic Materials ListHundreds of Materials Answers • Organic Seeds List • Downloadable Forms

CURRENT CUSTOMERS AND SUBSCRIBERS WILL RECEIVE A POSTCARD WITH LOGIN INFORMATION.

January 19-21 Indiana Horticultural Congress & Trade Show, Indianapolis, IN. The Indiana Horticultural Congress is an educa-tional gathering designed to meet the needs of fruit, vegetable, wine, organic and specialty crop growers and marketers in Indiana and surrounding states. www.inhortcongress.org *

January 20-23 Ecological Farming Conference, Pacific Grove, CA. The 30th Annual Ecological Farming Conference will cover top-ics including marketing, livestock, crop production, labor, energy and more. www.eco-farm.org *

January 20-23 Practical Tools and Solutions for Sustaining Family Farms Conference, Chattanooga, TN. Southern SAWG’s conference will provide you with the practical tools and solutions you need to be successful in your farming enterprise, your com-munity foods projects, and your advocacy and outreach work. www.ssawg.org

January 22-24 NOFA-NY’s 28th Annual Organic Farming & Gar-dening Conference, Saratoga Springs, NY. This year’s conference is titled “Circles of Caring” and features full-day workshops for the whole family. www.nofany.org

January 28-31 Guelph Organic Conference, Guelph, Canada. The 29th annual event includes 35 paid workshops, a free trade show and organic food expo, and numerous organic trade meet-ings. www.guelphorganicconf.ca *

January 24 -27 US Composting Council’s 18th Annual Confer-ence & Trade Show, Orlando, FL. This is the largest conference and exhibition in North America for the composting, wood waste, and organics recycling industry. www.compostingcouncil.org

February 4 -6 19th Annual Farming for the Future Conference, State College, PA. This PASA flagship event will take place over five days. It is the primary mode for fostering community among PASA’s broad and diverse membership. This year’s theme will be “The Sustainable Challenge: Providing for a Livable Tomorrow.”

February 9-11 World Ag Expo, Tulare, CA. World Ag Expo is the world’s largest annual agricultural exposition with 2.6 million square feet of exhibit space, over 1,600 exhibitors and an esti-mated 100,000 attendees. www.worldagexpo.com *

February 13-14 31st Annual Ohio Ecological Food & Farm As-sociation Conference, Granville, OH. This year’s theme is “Growing with Integrity, Eating with Intention.” This event will feature over 50 workshops, a kids’ conference, and keynote speakers Ann Cooper and Joel Salatin. www.oeffa.org

February 13-15 NOFA, Vermont, Winter Conference, “Celebrat-ing the Heart of Organic,” Burlington, VT. This event is expected to attract more than 1,500 visitors and will feature keynote speak-ers LaDonna Redmond and Jack Lazor as well as a visit from US Secretary of Agriculture Tom Vilsack. www.nofavt.org *

February 25-27 Upper Midwest Organic Farming Conference and Organic University, La Crosse, WI. The largest organic farming conference in the country is organized annually by MOSES. This year’s event will include over 60 workshops and more than 140 exhibitors. www.mosesorganic.org *

February 25 “State of Organic Seed Symposium,” LaCrosse, WI. Organic Seed Alliance has partnered with MOSES, National Organic Coalition, and OFRF to host a one-day event at the 2010 Organic Farming Conference on the day of the “Organic University” sessions. Learn more at www.seedalliance.org/Advocacy/ workingsymposium or email [email protected] *

C A L E N D A R

* OMRI staff will attend, present, or exhibit at this event. Compiled from a variety of sources. OMRI welcomes your calendar suggestions. Email to [email protected].

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