Organic Processing Vo1.8 #1 - January/February 2011

yeast must be organic if its end use is for human consumption; non-or-
ganic yeast may be used when equivalent organic yeast is not available.
Growth on petrochemical substrate and sulfite waste liquor is prohib-
ited.”
Additionally, “lecithin, bleached” was successfully petitioned to be
not recommended for re-listing on 205.606.

One controversial group of materials the NOSB may be tackling in depth soon is flavors. At the October meeting, flavors were recommended to be re-listed, however, the Board called to form a task force to consider some of issues that surround this category so that by the next sunset some can be resolved. Currently, flavors are listed on 605(a), which mean that they have to be “natural” according to the FDA definition. Some would like to see the listing—or at least a listing for agriculturally based flavors—in Section 606, so that if an organic version of a flavor is commercially available, it would have to be used. However, because some organic flavors use 605(a) flavors in their own 5 percent of non-organic ingredients, the issue is complex.

(continued from page 23)

set review. Companies can then choose either to reformulate, or, if reformulating is not possible, submit comments to NOP as part of the Federal Register process. They can also submit comments to NOSB to make sure the Board knows that a material is, or is not, essential to the trade.

OTA also prepares comments on behalf of the trade, and offers members the opportunity for feedback on those comments. OTA publicizes calls for comments through its News Flash, U.S. Government Affairs Forum, and NOSB Report. Additionally, OTA staff serve as resources on how and when to file comments.

Preparing for Sunset 2012

There are a number of actions companies can take to prepare for Sunset 2012. As a first step, organic manufacturers should examine their product formulations and identify materials that are up for sun-

Crops: (601)

(a) (1) alcohols ethanol isopropanol ( 2) chlorine materials calcium hypochlorite. chlorine dioxide. sodium hypochlorite.

( 7) soap-based algicide/de-mossers
(b) mulches
newspaper or other recycled paper
plastic mulch and covers
(c) as compost feedstocks
newspapers
(f) as insect management
pheromones
(g) as rodenticides
(1) sulfur dioxide
( 2) vitamin D3

(i) as plant disease control
tetracycline
(j) as plant or soil amendments
( 4) lignon sulfonate
( 5) magnesium sulfate
(k) as plant growth regulators
ethylene gas
(l) as floating agents in postharvest
handling
(1) lignon sulfonate
(1) EPA List 4—inerts of minimal concern

(n) seed preparations hydrogen chloride

Crops (602)

(g) sodium nitrate

Livestock (604) None

Still to Review Before 2012 Deadline

The following materials are up for sunset in 2012, but have yet to undergo review by the NOSB. If these materials are important to your product—or if you know of a commercially available organic alternative—make sure to petition the NOSB or sign up for public comment before the 2011 Spring Meeting:

Livestock (603)

(a) as medicine ( 15) magnesium hydroxide ( 21) poloxalene

Handling 605(a) enzymes potassium iodide

Handling 605(b) Nutrient vitamins Nutrient minerals Potassium iodide Tocopherols

In Conclusion

The sunset review process is an integral part of the organic regulatory system. It helps ensure that materials needed for organic production and processing continue to be included on the National List, and that those materials that are no longer needed (e.g. because organic alternatives have been developed) are removed.

In this sense, the sunset process also serves as a call to action to all organic processors and producers to communicate their need for materials on the National List. Without such communication, they risk having a material sunset and thereby losing the ability to use it. At the same time, the sunset process affords producers and processors a unique opportunity to shed light on new organic alternatives to listed materials and spur the growth of a new segment of the organic marketplace. o