gram Handbook—instructions—establishes or clarifies best practices for conducting business as it relates to NOP activities. Instructions relating to certification
cover, among other topics, recordkeeping requirements, measures for reinstating
certification after an operation is suspended and “five steps for getting certified,”
a guide to help those who are looking at joining the organic industry.
As the scope of regulatory clarification expands, so will the handbook. This
means more opportunity for the organic community to provide input as guidance
documents are, in accordance with USDA Good Guidance Practices, open for
public comment prior to being finalized. The NOP solicits public input for draft
guidance documents by posting notices in the Federal Register. Most recently it
invited the public to submit comments on draft guidance concerning:
• compost and vermicompost in organic crop production
• wild crop harvesting
• outdoor access for organic poultry
• commingling and contamination prevention in production and handling
• use of the “made with organic” claim
• nutrient vitamins and minerals used in
processed organic food products
All members of the organic community
can keep up with announcements about
the availability of these documents and
other items by signing up for the NOP Or-
ganic Insider, a new subscription-based
email service. By signing up, recipients can
select the type of information they receive,
including items about organic standards,
accreditation and international activities,
compliance and enforcement measures,
the National Organic Standards Board,
training events and the Organic Certifica-
tion Cost Share program.
While the NOP lays the groundwork to
clarify its positions concerning the organic
rules, it is also collaborating with organiza-
tions that already have excellent resources
in place to meet the organic community’s
need for regulatory guidance. In Sep.
2010, the program established a working
partnership with the National Center for
Appropriate Technology’s National Sus-
tainable Agriculture Information Service
(ATTRA). The goal was to create helpful
compliance materials. As a result, practical
resources outlining certification and com-
pliance activities will be available to organic
operations and their certifiers, who can
refer to them as voluntary guides. For
example, a new publication titled “Un-
derstanding the NOP Access to Pasture
Rule” will provide additional informa-
tion for organic ruminant operations.
Other practical materials will include
organic system plan templates, docu-
mentation forms, certification work-
books, inspection report forms and
compliance checklists. For immediate
reference, users can search through re-
sources created from a previous NOP
collaboration with ATTRA at
www.attra.ncat.org/organic.html.
The Age of Enforcement
As the rules are clarified and NOP’s
position is more transparent, excuses
Know the Rules
This year several new rules were passed by the NOP in addition to the pasture
rule. First, in July 2010, a final rule addressed the use of tetracycline and sulfurous acid
in organic production. Tetracycline is a synthetic substance derived from soil bacteria
and has been allowed in organic crop production for the control of fire blight in apples and pears for many years. The final rule allows another form of tetracycline
(oxytetracycline hypdrochloride) to be used, however, all forms of tetracycline will be
removed from the list as of Oct. 21, 2012. The rule also adds sulfurous acid to the National List. This provision allows organic producers to utilize sulfurous acid to improve
water quality prior to using irrigation water on organic crops.
Second, in August 2010, the NOP published an interim rule (with request for comments) extending the use of synthetic methionine in organic poultry production until
Oct. 1, 2012. It established the following maximum levels per ton of feed based on
current industry practices: 4 pounds for laying chicken, 5 pounds for broiler chickens,
and 6 pounds for turkeys and all other poultry.
The NOP has also proposed amendments based on recommendations by the
NOSB. If adopted, the amendments would add the following substances to the National List, along with any restrictive annotations:
• microcrystalline cheesewax for organic crop production to §205.601;
• acidified sodium chlorite for organic processing to §205.605(b);
• and dried orange pulp and Pacific kombu seaweed for organic processing to
§205.606, as long as organic forms are commercially unavailable.
It would also amend the annotation for unbleached lecithin in §205.606(o)
and remove bleached lecithin from §205.605(b).
Most recently, the NOP amended the National List, adding the following materials: (1) aqueous potassium silicate for use as an insecticide and for plant disease control in organic crop production, ( 2) sodium carbonate peroxyhydrate for use as an
algaecide in organic crop production, ( 3) gellan gum as a nonsynthetic allowed for use
in organic handling, ( 4) fortified cooking wine, Marsala and sherry, for use in organic
handling as a nonorganic agricultural ingredient only when not commercially available
in organic form, and ( 5) tragacanth gum for use in organic handling as a nonorganic
agricultural ingredient only when not commercially available in organic form. The rule
also removes glycerine oleate as a synthetic inert ingredient allowed in organic crop
production.
