Comment Period for NOSB Substance Review Still Open–Make Your Voice Heard

Response times may be slow due to the wildfires affecting Santa Cruz County and Covid-19. Organic compliance deadlines and inspections will be delayed for businesses affected by these crises. Read the latest updates on the Northern California wildfires, and visit our Covid-19 webpage to find pandemic-specific information »

Los tiempos de respuesta serán lentos debido a los incendios forestales afectando al condado de Santa Cruz y COVID-19. Los plazos de cumplimiento orgánico y las inspecciones se retrasarán para los negocios afectados por estas crisis.  Lea las últimas actualizaciones sobre los incendios forestales del norte de California y visite nuestra página web de Covid-19 para encontrar información específica a la pandemia »

Your feedback is needed!

Over the course of its next two meetings, the National Organic Standards Board (NOSB) will review several of the fertilizers, pest control products, livestock treatments, processing aids, and ingredients currently allowed for use by certified organic operations, which are recorded in the National List of Allowed & Prohibited Substances (National List). These production and handling inputs will be reviewed and voted on by NOSB based on their Sunset timeline (renewal date), and may not be renewed if new information indicates these substances are incompatible with organic production.

It’s critical that organic stakeholders weigh in by the Thursday, March 30 comment deadline and explain whether these inputs are consistent with and necessary for organic production, or whether there are other effective natural or organic alternatives available. The information you provide now will inform the vote NOSB will take at the fall 2017 meeting in Jacksonville, Florida.

To help facilitate the comment process, OTA has created a survey system for collecting feedback from certified farms and processors. The information collected will significantly help NOSB identify the inputs that should be renewed or removed from the National List. Below are links to electronic surveys that can be used to submit feedback on each individual input currently under NOSB review. Each survey is confidential, and contains about 10 short questions that will take an estimated five to 10 minutes to complete. The information collected will be passed along to NOSB via OTA’s comments.

2019 Sunset Review Inputs Reviewed In 2017

The National List inputs listed below are undergoing a reorganization process that will result in a more evenly distributed Sunset Review workload over the five-year Sunset Review cycle. The process is the result of an NOSB recommendation unanimously passed at the fall 2016 NOSB meeting. Please note that as explained in the NOSB recommendation, National List inputs that are reviewed early under the reorganization plan should be allowed to sunset on their original timeline. For example, if NOSB votes to remove a National List item under the 2019 review cycle that was originally under the 2017/2022 Sunset Review cycle, the removal of the item from the National List would not occur until 2022. This situation applies to all of the inputs listed below except biodegradable bio-based mulch.



Algicides, sanitizers, pest, weed, and disease control materials

  • Chlorine materials (calcium hypochlorite, chlorine dioxide, sodium hypochlorite): Used to disinfect tools, prevent spread of diseases, and increase food safety of organic products. For pre-harvest use, residual chlorine levels in the water in direct crop contact or as water from cleaning irrigation systems applied to soil must not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act, except that chlorine products may be used in edible sprout production according to EPA label directions. Submit feedback.
  • Herbicides, soap-based: For use in farmstead maintenance (roadways, ditches, right-of-ways, building perimeters) and ornamental crops. Submit feedback.
  • Biodegradable bio-based mulch film: As defined in §205.2: Must be produced without organisms or feedstock derived from excluded methods. §205.2: A synthetic mulch film that meets the following criteria: (1) Meets the compostability specifications of one of the following standards: ASTM D6400, ASTM D6868, EN 13432, EN 14995, or ISO 17088 (all incorporated by reference; see §205.3); (2) Demonstrates at least 90% biodegradation absolute or relative to microcrystalline cellulose in less than two years, in soil, according to one of the following test methods: ISO 17556 or ASTM D5988 (both incorporated by reference; see §205.3); and (3) Must be bio-based with content determined using ASTM D6866 (incorporated by reference; see §205.3). Submit feedback.
  • Boric acid: Used for structural pest control, but cannot come into contact with organic food or crops. Submit feedback.
  • Sticky traps/barriers: Used to monitor for pest population issues in organic fields. Submit feedback.
  • Copper sulfate: Used for pest and disease control and as a fertilizer to correct copper deficiencies in soil. Submit feedback.
  • Coppers, fixed: Used for disease control. Submit feedback.

Fertilizers, soil amendments, and crop production aids

  • Humic acids: Used as a fertilizer and soil amendment. Submit feedback.
  • Micronutrients – (i) Soluble boron products, (ii) Sulfates, carbonates, oxides, or silicates of zinc, copper, iron, manganese, molybdenum, selenium, and cobalt: Used as a fertilizer when testing shows deficiencies. Submit feedback.
  • Vitamin B1, C, and E: Used as a fertilizer and soil amendment. Submit feedback.




  • Chlorine materials (calcium hypochlorite, chlorine dioxide, sodium hypochlorite): Used for sanitizers and disinfectants. Residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act. Submit feedback.
  • Chlorhexidine: Used as an antiseptic and teat dip when alternatives have lost efficacy. Submit feedback.
  • Glucose: Used to treat ketosis and hypoglycemia. Submit feedback.
  • Oxytocin: Used in post-parturition therapeutic applications (e.g., retained placenta). Submit feedback.
  • Tolazoline: Used to reverse the effects of Xylazine after surgical procedures. Submit feedback.
  • Copper sulfate: Used as hoof bath to treat foot conditions. Submit feedback.
  • Lidocaine: Used as a local anesthetic. Submit feedback.
  • Procaine: Used as a local anesthetic. Submit feedback.



  • Attapulgite: Used as a processing aid and functions as a natural bleaching clay for the purification of vegetable and animal oils. Submit feedback.
  • Bentonite: A colloidal clay (aluminum silicate) that has a high swelling capacity in water. Used as a filtering aid, and as a thickener and colorant in wine. Submit feedback.
  • Diatomaceous Earth (food filtering aid only): Used for filtering numerous organic food and beverage products. Submit feedback.
  • Nitrogen: Keeps cans rigid in still juice. Excludes oxygen from sealed containers. Used in flash freezing of foods. The nitrogen dissipates into the air after freezing and does not remain in the food product. Submit feedback.
  • Sodium carbonate (baking soda): Used in prepared pancake biscuit and muffin mixes; a leavening agent in baking powders; in various crackers and cookies; to adjust acidity in tomato soup, pastes, and beverages; in syrups for frozen products; in confections and self-rising flours. Used also as a neutralizer for butter, cream, and ice cream. Submit feedback.


  • Acidified sodium chlorite: Used as a secondary direct antimicrobial food treatment and indirect food contact surface sanitizing. Under consideration by FDA as a sprouting seed disinfectant. Submit feedback.
  • Chlorine materials (calcium hypochlorite, chlorine dioxide, sodium hypochlorite): For disinfecting and sanitizing food contact surfaces and as a sanitizer in the handling and processing of organic crops. Submit feedback.
  • Carbon dioxide: Used in the storage of grains for pest control, for freezing of foods, accelerated cooling, beverage carbonation, extraction of essential oils and extracts, and controlled atmospheric packaging. Submit feedback.
  • Magnesium chloride (derived from sea water): Coagulant in tofu manufacturing. Firming agent in canned vegetables. Submit feedback.
  • Potassium acid tartrate: Used in many types of organic baked goods as a leavening agent. Used as part of aluminum-free baking powder, along with sodium bicarbonate and cornstarch. Submit feedback.
  • Sodium phosphates (for use only in dairy foods): Used as an emulsifier in organic cheese products. Submit feedback.


  • Casings (from processed intestines): Processed intestines of hogs, cattle, and sheep. In most instances the casing is consumed with the product, however in some cases the casing is removed. Submit feedback.
  • Konjac flour: Used as a gelling agent and stabilizer/thickener, its functional properties are similar to those for food ingredients such as gelatin, pectin, modified starches, and vegetable gums. Also classified by USDA-APHIS as a binder in meat and poultry products. Submit feedback.
  • Pectin (non-amidated forms only): Used as a stabilizer and thickening agent. Used in jams and jellies. Also in fruit preparations for yogurt and bakery fillings. Can be used in salad dressings, malted milk beverages, and frozen fruit products. Submit feedback.

Upcoming NOSB Meeting & Agenda

The next (NOSB) meeting will be April 19-21, 2017 in Denver, Colorado, at the Sheraton Denver Downtown Hotel. Reservations may be made online. The meetings are open to the public, and no registration is required, except to sign up for oral comments. Reserve an oral comment slot.

The primary purpose of NOSB meetings is to provide an opportunity for organic stakeholders to give input on proposed NOSB recommendations and discussion items. The meetings also allow NOSB to receive updates from USDA’s National Organic Program (NOP) on issues pertaining to organic agriculture. The meeting will be open to the public.

The final deadline to submit written comments and sign up for oral comments will be Thursday, March 30, at midnight Eastern time.

Mission and Structure of NOSB

NOSB was created through the Organic Foods Production Act, a sub-section of the 1990 Farm Bill. The board is charged with the task of assisting the Secretary of Agriculture on which substances should be allowed or prohibited in organic farming and processing. This 15-person citizen advisory board brings together volunteers from around the United States. It is made up of four farmers/growers, two handlers/processors, one retailer, one scientist, three consumer/public interest advocates, three environmentalists, and one USDA-accredited certifying agent.

Contact OTA Staff with Questions or Concerns:


This article was submitted by the Organic Trade Association.

The Organic Trade Association (OTA) is the membership-based business association for organic agriculture and products in North America. OTA is the leading voice for the organic trade in the United States, representing over 8,500 organic businesses across 50 states. Its members include growers, shippers, processors, certifiers, farmers' associations, distributors, importers, exporters, consultants, retailers and others. Organic products represented include organic foods, ingredients and beverages, as well as organic fibers, personal care products, pet foods, nutritional supplements, household cleaners and flowers. OTA’s Board of Directors is democratically elected by its members.

OTA’s member organic businesses work together through networking, advocacy, and other initiatives to encourage and protect organic farming practices, and to share messages about the positive environmental and nutritional attributes of organic products with consumers, the media, and policymakers.