USDA National Organic Standards Board 

Materials Subcommittee 

Research Priorities Proposal 

Fall 2022 

Executive Summary 

Overall: The National Organic Standards Board (NOSB) presents an annual list of research priorities for 

organic food and agriculture. The NOSB requests that integrated research be undertaken with 

consideration of the whole farm system, recognizing the interplay of agroecology, the surrounding 

environment, and both native and farmed species of plants and animals.

Livestock

1. Determine the efficiency of natural parasiticides and methodologies, including but not limited to,

nutritional programs, use of herbs, essential oils, homeopathic remedies, Diatomaceous Earth, and

the genetic pool of laying hens in controlling A. galli and H. gallinarum in laying and replacement

chickens intended to become hens.

2. Evaluate natural alternatives to DL-Methionine in a system approach for organic poultry feed

program.

3. Evaluate ways to prevent and manage parasites in livestock, examining breeds, geographical

differences, alternative treatments, and pasture species.

4. Develop a dairy program to address climate change mitigation strategies where milking capabilities

are not hindered, and effective forage rotations are maximized.

5. Develop balanced organic livestock rations that incorporate high percentages of diverse, regionally

adapted grain crops to reduce the reliance on corn and soybeans and allow farmers to realize more

marketing opportunities for a robust crop rotation.

Crops 

1. Examination of decomposition rates, the effects of residues on soil biology, and the factors that

affect the breakdown of biodegradable bio-based mulch film.

2. Conduct whole farm ecosystem service assessments to determine the economic, social, and

environmental impact of farming systems choices.

3. Organic no-till practices for diverse climates, crops, and soil types.

4. Develop cover cropping practices that come closer to meeting the annual fertility demands of

commonly grown organic crops.

5. Development of systems-based plant disease management strategies (including specific

considerations related to copper use in organic rice production) are needed to address existing and

emerging plant disease threats.

6. The demand for organic nursery stock far exceeds the supply. Research is needed to identify the

barriers to expanding this market, then develop and assess organic methods for meeting the

growing demand for organically grown nursery stock.

NOSB Proposals & Discussion Documents October 2022 43 of 152
7. Strategies for the prevention, management, and control of problem insects and weeds. 

8. Factors impacting organic crop nutrition, and organic/conventional nutrition comparisons. 

9. Side-by-side trials of approved organic inputs, both synthetic and natural, and cultural methods, 

with a request for collaboration with the IR4 project. 

10. Impartial evaluation of microbial inoculants, soil conditioners, and other amendments is needed as 

there is little objective evidence upon which to assess their contribution to soil health. 

11. More research, extension, and education are needed to fully understand the relationship between 

on-farm biodiversity and pathogen presence and abundance. 

12. Elucidate practices that reduce greenhouse gas emissions and that contribute to farming systems 

resilience in the face of climate change. 

Food Handling and Processing 

1. Sanitizers: Effective alternatives of sanitizers, effect on occupational human health and 

environment, effectiveness of rotational use strategies with the sanitizers currently on the National 

List 

2. Effect of various types of food packaging on organic products, including suitable alternatives to BPA 

(Bisphenol-A) for linings of cans used for various products, plastic use, antimicrobial nanoparticle 

surface coatings of packaging. 

3. Research on the creation of an overarching ancillary ingredient review process for materials used in 

processing and handling vs reviewing ancillaries as part of the petition or sunset review process, 

including cost/benefit of each process. 

4. Alternatives to conventional celery powder for curing organic meat. 

5. Research on best practices for identifying potential vectors of heavy metal contamination in organic 

systems, including strategies for effective testing in soils, water, organic processing, etc. that could 

lead to the identification and prevention of heavy metals transgression in organic systems.

6. Evaluation of the essentiality of 205.605(a), 205.605(b), and 205.606 substances and the suitability 

of organic alternatives in applicable food formulations via laboratory testing, sensory evaluation, 

and/or market analysis. 

Coexistence with GE and Organic Crops

1. Outcome of genetically engineered (GMO/GE) material in organic compost. 

2. Evaluation of public germplasm collections of at-risk crops for the presence of GE traits, and ways to 

mitigate small amounts of unwanted genetic material in breeding lines. 

3. Develop, then implement, methods of assessing the genetic integrity of crops at risk to quantify the 

current state of the organic and conventionally produced non-GMO seed. 

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4. Techniques for preventing adventitious presence of GE material in organic crops, and evaluation of 

the effectiveness of current prevention strategies. 

5. Testing for fraud by developing and implementing new technologies and practices. 

General 

1. Examination of the factors influencing access to organically produced foods. 

2. Production and yield barriers to transitioning to organic production to help growers successfully 

complete the transition. 

NOSB Proposals & Discussion Documents October 2022 45 of 152
National Organic Standards Board

Materials Subcommittee Proposal

2022 Research Priorities

Fall 2022

INTRODUCTION 

The National Organic Standards Board (NOSB) presents an annual list of research priorities for organic 

food and agriculture. The NOSB’s Livestock, Crops, Handling, and Materials/GMO Subcommittees 

proposed an updated set of priorities at the Fall 2021 board meeting. The Board requests input from 

stakeholders on the 2022 research priorities and will review those comments for the Fall 2022 proposal.

BACKGROUND 

The list of priorities is revisited each year by the NOSB. The list is made meaningful by input through the 

written and oral public comments shared with the Board, through the expertise of the Board itself and 

through interactions throughout the year with those engaged in some dimension of the organic farm to 

fork continuum. When the NOSB has determined that a priority area has been sufficiently addressed, it 

is removed from the list of priorities. Priorities are also edited each year to reflect the existing need 

more accurately for new knowledge. 

The NOSB encourages collaboration with and between laboratories, federal agencies, universities, 

foundations and organizations, business interests, organic farmers, and the entire organic community to 

seek solutions to pressing issues in organic agriculture and processing/handling. 

The NOSB encourages integrated, whole farm research into the following areas:

Livestock

1. Efficiency of Natural Parasiticides and Methodologies – Nutritional programs, use of herbs, essential 

oils, homeopathic remedies, Diatomaceous Earth, and the genetic pool of laying hens in controlling A. 

galli and H. gallinarum in laying and replacement chickens intended to become hens – among other 

interventions – may be helpful in ensuring flock health. Ongoing research into the usefulness and 

viability of such innovations is consistent with NOSB action.

2. Evaluation of Methionine in the Context of a System Approach in Organic Poultry Production - 

Methionine is an essential amino acid for poultry. Prior to the 1950’s, poultry and pigs were fed a plant 

and meat-based diet without synthetic amino acids such as methionine. One former NOSB member 

stated, in §205.237(5) (b), “We have seemingly made vegetarians out of poultry and pigs”. As the 

organic community moves toward reducing, removing, or providing additional annotations to synthetic 

methionine in the diets of poultry, a heightened need exists for the organic community to rally around 

omnivore producers to assist in marshaling our collective efforts in finding viable alternatives to 

synthetic methionine and to help find approaches for making them more commercially available. 

Continued research on the use of synthetic methionine in the context of a systems approach (nutrition, 

genetic selection, management practices, etc.) is consistent with the NOSB unanimous resolution passed 

at the La Jolla, California, Spring 2015 board meeting. A systems approach that includes industry and 

independent research by USDA/ARS, on farms, and by agricultural land grant universities is needed for 

(1) evaluation of the merits of natural alternative sources of methionine such as herbal methionine, high 

methionine corn, and corn gluten meal in organic poultry production systems; (2) evaluation of poultry 

breeds selection that could be adaptive to existing organic production systems – inclusive of breeds 

NOSB Proposals & Discussion Documents October 2022 46 of 152
being able to adequately perform on less methionine; (3) assessment of management practices for 

improving existing organic poultry welfare under different conditions; and (4) with the European Union 

as a case study, assess how it is that EU farmers manage the methionine needs of their flocks in the 

absence of synthetic methionine use. Research findings and collaborations under various climates, 

housing types, geographical regions, and countries should be noted and researched, where applicable. 

Certainly, the fruition of these types of research topics could take years to achieve the expressed NOSB 

resolution; however, an aggressive and/or heightened research focus could lead to findings that can 

positively impact the organic poultry industry and the organic brand. The continued focus on 

methionine with a systems approach is imperative and necessary. The key research areas should include 

the efficacy and viability of alternatives such as: herbal methionine, corn gluten meal, potato meal, 

fishmeal, animal by-products, and other non-plant materials. Additional research on the more promising 

alternatives to bring them into commercial production is also encouraged. Additionally, management 

practices impacting the flock’s demand for methionine should be included, such as flock management 

practices, access to pasture, and pasture management.

3. Prevention and Management of Parasites - Livestock production places large numbers of cattle, 

sheep, goats, poultry etc. into relatively close contact with each other on fields and in barns. Organic 

production does not allow antibiotic use and requires that livestock be raised in a manner which 

approximates the animal’s natural behavior. The organic farmer can use synthetic parasiticides in an 

emergency but not prophylactically. Synthetic parasiticides have many limitations. Even if prophylactic 

treatment with parasiticides were possible, it is clear that parasite immunity to chemical control will 

inevitably occur. Thus, prevention of parasites is critical. 

The research question on prevention and management of parasites must be systems-based. What farm 

systems, bird and animal breeds, herd or flock management systems have shown the best results with 

parasite control over the last twenty years? What regional differences are there in the US in parasite 

prevention? Are there specific herbal, biodynamic, diatomaceous earth, or other treatments that have 

been proven to work overtime? What are the parasite-resistant breeds? Are there plant species in 

pastures, hayfields, and scrublands that could be incorporated into the annual grazing system to reduce 

the spread of parasites or to provide prevention through the flora, fauna, and minerals ingested? Which 

pasture management systems appear to be best for parasite prevention in various parts of the country? 

Are pasture mixes being developed that include plants known to prevent parasites in various breeds? 

4. Develop a dairy program to address climate change mitigation strategies where milking capabilities 

are not hindered, and effective forage rotations are maximized. - To further acknowledge the central 

role the certified organic industry will play in the fight against climate change, an opportunity exists to 

both empower the economic resilience of organic dairy farmers while harnessing the soil building 

potential of diverse perennial and annual forages, we encourage the research community to dedicate 

resources to the following need: 

A. Identify an index of dairy cattle genetics to which producers could breed their existing herds 

and achieve a minimum of 12,000 lbs. of milk production per year on 100% forage diets. In 

considering the genetics selected, also identify animals bred for longevity as the more lactations 

on a cow, the more spread out the fixed costs of raising her as a heifer becomes. 

B. To assist dairy farmers in having the tools to consider a forage-based rotation for their herds, 

research and identify crop rotations that have three functions: produce high quality forage, 

maximize soil building, and result in the most profitable outcome for the dairy producer. 

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5. Develop balanced organic livestock rations that incorporate high percentages of diverse, regionally 

adapted grain crops to reduce the reliance on corn and soybeans and allow farmers to realize more 

marketing opportunities for a robust crop rotation. - The US organic livestock demand and 

consumption of organic corn and soybean meal in feed rations exceeds US production. To help 

encourage farmers to utilize robust crop rotation programs that are specific to their geographical region, 

give livestock producers more product availability/flexibility of ingredients, and reduce the dependence 

on corn and beans, there needs to be proven equitable rations in all livestock segments that include 

alternative energy and protein sources

Crops

1. Biodegradable Bio-based Mulch Film - Biodegradable mulch was recently approved by the NOSB but 

did not specify a required percentage of biologically derived (i.e., bio-based) content. In 2015, NOP 

issued a Policy Memo that states that certifiers and material organizations should review biodegradable 

mulch film products to verify that all (100%) of the polymer feedstocks are bio-based. This requirement 

makes bio-based mulches unavailable to organic producers because petroleum-based polymers are 

present in these mulch films. In order to provide a recommendation to the NOP addressing the 

presence of petroleum-based polymers in these mulches, the answers to the following questions are 

important to develop more clarity on mulch films and possibly develop an additional annotation to 

address producer needs for biodegradable mulch films even if petroleum-based polymers are used:

• How rapidly do these mulches fully decompose, to what extent does cropping system, soil type, 

and climate mediate decomposition rates, and does the percentage of the polymers in the 

mulch film affect the decomposition rate? 

• Are there metabolites or breakdown products of these mulches that do not fully 

decompose? Do any of these mulches fully decompose?

• Do breakdown byproducts influence the community ecology and ecosystem function of soils, 

plants, and the livestock that graze on crops grown in these soils? 

• As fragments degrade, do they pose a problem to terrestrial and aquatic wildlife? What are the 

environmental fates of micro- and nano-plastic fragments resulting from biodegradable mulch 

film degradation, and what hazards do they present to organisms that they interact with on the 

way to that fate?

• Do the residues of these films accumulate after repeated use? 

• Are the testing protocols in place to insure decomposition standards?

 

2. Ecosystem service provisioning and biodiversity of organic systems - How do organic systems impact 

ecosystem service provisioning, both on-farm and off-farm through the materials and inputs sourced 

and used for production? For example, life-cycle analysis of environmental costs and benefits of inputs 

used for organic production, such as manure, seaweed, and fish-based soil amendments, would be 

beneficial. Additionally, what is the impact of diversified and agroecologically designed organic farming 

systems on biodiversity and ecosystem services within the farm and in its surroundings? Can farmmapping be performed to quantify the impact of the location of a farm (in a broader landscape) and the 

arrangement of fields and non-crop habitat to enhance biodiversity and ecosystem service provisioning?

3. Organic No-Till and Minimum Tillage - Organic no-till can increase soil health and provide for 

increased biodiversity. Organic no-till preserves and builds soil organic matter, conserves soil moisture, 

reduces soil erosion, and requires less fuel and labor than standard organic row crop farming. 

Farmers are employing several different approaches to organic no-till. Some are using a roller-crimper 

to terminate cover crops for in-place mulching. They then transplant or seed directly into the cover crop 

NOSB Proposals & Discussion Documents October 2022 48 of 152
mulch. Others are utilizing polyethylene sheets (silage tarps) to prepare land for no-till planting. This 

approach often involves termination of a cover crop, as with the roller-crimper systems, but seemingly 

as often, or more frequently, is utilized to prepare fallow ground (for stale seed bedding, termination of 

crop residue and subsequent incorporation via soil fauna), or in conjunction with large applications of 

compost or other sources of organic matter. 

Increased research is needed to develop organic no-till systems that function for a wide variety of crops 

in diverse climates and soil types. Annual crops such as commodity row crops and specialty crops, as 

well as perennial crops such as tree fruits, berries, and grapes would all benefit from these organic notill practices. Research areas that could be covered include:

• Development of plant varieties that have specific characteristics, such as early ripening, to aid in 

the effectiveness and practicality of organic no-till.

• What combination of mulch crops and cultural systems sustain crop yields, provide soil health 

benefits, and suppress weeds? 

• How does organic no-till influence pest, weed, and disease management?

• What potential pest problems can be caused or exacerbated by cover crops used as mulches, 

and how can those problems best be managed?

• In perennial cropping systems, such as fruits, what are the benefits or drawbacks of using this 

mulching system on weed, pest, and disease management, as well as soil fertility?

• What are the biodiversity benefits to living and/or killed mulches, and how does this contribute 

to pest, weed, and disease management?

• Do these systems affect the nutrient balance of the soil and subsequent fertilization practices, 

including use of outside inputs?

• Based on the improved soil health, when there is less soil disturbance and more plant 

decomposition resulting in higher organic matter, how does this system affect soil microbial life 

and nutrient availability, and does this then result in crops that are less susceptible to disease 

and pests?

• Research is needed on seeds, specifically for good cold germination, rapid emergence and 

establishment, seedling vigor, nutrient uptake efficiency, and overall weed competitiveness to 

crop cultivar development goals for organic conservation tillage systems. 

• How can reduced tillage weed management be improved, including development of new tools 

and techniques that provide greater weed control for less soil disturbance?

Finally, organic farmers use whole-farm planning when deciding what will be done in each of their 

fields. Research that assesses the ecosystem benefits of reducing tillage in patches (field-level) across a 

farm is also needed. For example, the relative benefits of reducing tillage are greater in areas prone to 

surface water runoff. Research is needed to “inform” where reduced tillage practices are likely to have 

their greatest impact.

4. Managing Cover Crops for On-Farm Fertility - Growing cover crops and green manures is a 

foundational practice on many organic farms. In addition to conserving soil, increasing water holding 

capacity, and providing weed suppression, cover crops supply important plant nutrients and increase 

soil organic matter. As farmers seek to grow their own fertility, more research is needed on the efficacy 

of relying primarily on cover crops to meet production needs, particularly for horticultural crops. At 

present, there is inadequate data on the nutrient benefits of different cover crop mixes and how those 

benefits vary according to species mix, mowing practices, tillage regimes, subsequent planting time of 

the cash crops, and importantly the preceding practices that define the legacy of individual fields. 

NOSB Proposals & Discussion Documents October 2022 49 of 152
5. Disease Management - Disease management in organic fruit and vegetable production relies on a 

systems approach to succeed, but even with current systems plans in place, growers frequently struggle 

to manage commonly occurring blights and citrus greening. The NOSB underscores the need for 

systems research that addresses solutions to these and related diseases that are workable for farmers, 

that reduces adverse health effects on farmers and fieldworkers, and that also limits adverse effects on 

the soil and water in which the crops grow. To this end, we call for systems research that identifies 

disease resistant material while at the same time identifying biological controls that limit the use of 

copper-based compounds where possible. 

Specifically, targeted research is needed to identify management practices and less toxic alternative 

materials for a wide range of crops. More research is needed on many of the crop/disease 

combinations, including: 

• Comprehensive, systems-based approaches for managing individual crops in a way that 

decreases the need for copper-based materials, including researching crop rotations, sanitation 

practices, plant spacing, and other factors that influence disease. 

• Breeding plants that are resistant to the diseases that copper controls. 

• Developing alternative formulations of materials containing copper so that the amount of 

elemental copper is reduced.

• Developing biological agents that work on the same diseases that copper is now used on. 

• Evaluating plant nutritional strategies to mitigate the impacts of plant diseases. 

• Research on scum and algae control in rice and whether sodium carbonate peroxyhydrate or 

other materials are suitable alternatives in an aquatic environment. 

• Soil management and crop cultivar development for enhanced beneficial crop-root microbe 

partnerships that protect organic crops from soil borne and foliar pathogens.

• Alternatives to antibiotics (tetracycline and streptomycin) for fire blight control, particularly in 

pears and apples.

Specifically related to organic rice production and the ongoing concern about copper usage related to 

that crop (although not exclusive to it), more research is needed on disease management that:

1) supports a systems-based approach to reduce the needs of copper materials;

2) addresses a breeding component for disease resistance (where copper is used);

3) addresses alternate formulations to help reduce elemental copper;

4) speaks to developing biological agents to (hopefully) displace copper with a softer alternative;

5) evaluate plant nutritional strategies to lessen disease impacts.

6. Identify Barriers and Develop Protocols for Organic Nursery Stock Production

The demand for organic nursery stock far exceeds the supply. Research is needed to identify the 

barriers to expanding this market, then develop and assess organic methods for meeting the growing 

demand for organically grown nursery stock. That work could include but is not limited to assessing 

phytosanitary rules for shipping plants and quantifying the production and demand for organic 

rootstock. Research has shown that application of the correct ectomycorrhizal inoculants to roots can 

substantially (50% or more) enhance establishment and early growth of woody perennial horticultural 

crops. How can fine tuning the use of mycorrhizal inoculants make organic nursery stock production 

easier and more profitable, thereby helping to close the demand/supply gap? Research centered on 

development of practical organic methods for the nursery industry to implement is needed, including:

• Disease and insect control materials that are allowed under organic standards and may be 

accepted under specific phytosanitary regulatory requirements. 

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• New materials for controlling pests addressed by phytosanitary rules that show promise of 

compatibility with National List review criteria. 

• Alternative protocols for phytosanitary certification of nursery stock that are based on 

outcomes (such as testing or inspection) rather than requirements for use of synthetic materials 

during production. 

7. Management of Problem Insects and Weeds - There is a large pool of research on the control of 

insects and weeds using organic methods. Many controls use a systems approach and are quite 

effective. However, some arthropod pests including new invasive species, are problematic, and in 

several cases the organic control options are very limited or nonexistent. The organic community needs 

more information on their biology, life cycle weak points, and natural enemies to implement targeted 

and systemic management.

Examples are:

• spotted wing drosophila 

• brown marmorated stinkbug 

• Spotted lanternfly

• Swede midge

• Leek moth

• Corn rootworm beetle (northern and western)

• Cutworms (army, western bean, etc.)

• and others

 

Weed management is one of the greatest challenges to successful organic crop production. 

Development of integrated organic management strategies that effectively control weeds in specific 

cropping systems without excessive tillage continues to be a top research priority for organic producers. 

For instance, Canadian thistle, pigweed (including invasive palmer amaranth and waterhemp), wild 

sunflower, giant ragweed, cocklebur, and other perennial weeds can be very difficult to control in 

reduced tillage systems. 

Research into new technologies such as electroshock weeders, interrow mowers, camera-guided 

cultivators, laser-weeders incorporating AI (artificial intelligence) and robotics, propane flamers, etc. is 

critical to success in field crops, whereas tarping, solarization, and a new generation of hand tools have 

great potential in small- to medium-scale vegetable crops. For large scale vegetable as well as row-crop 

producers, strip tillage and compatible weed management tools including row cleaners, finger weeders, 

and high residue cultivators can combine reduced tillage and cover crops into one practice set.

Future cropping systems will utilize multiple elements of soil, crop, pest, and weed management. The 

integration of tools such as weed-suppressive cover crops and rotations, livestock grazing, flaming,

beneficial insect habitat, intercropping, etc. into annual and perennial cropping systems needs more 

research.

8. Nutritional Value of Organic Crops - How do organic soil health and fertility practices - crop 

rotations, cover crops, compost and other organic or natural mineral amendments, etc. - affect the 

nutritional value or “nutrient density” of organically produced crops? How do organic production and 

shipping methods (including methods of production, handling, and time in transport) influence the 

nutritional quality, taste, palatability, and ultimately preference for organic vegetables and fruits? There 

is a lack of sound, rigorously conducted studies of this kind. How can growers and handlers retain 

nutrition through post-harvest handling and transportation? Additionally, can providing organic 

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producers information on soil biology and soil nutrient composition help improve nutrition? Finally, 

more studies are needed examining how organic crops compare to conventional crops with regards to 

nutritional value.

9. Side-by-Side Efficacy Comparisons Between National List Allowed and Petitioned Synthetic Inputs 

Versus Non-synthetic Alternative Inputs or Practices - During its five-year review of sunset materials on 

the National List and in the evaluation of newly petitioned materials, the NOSB often lacks sufficient 

information of the effectiveness of these materials as compared with other synthetics on the National 

List, natural materials, and cultural methods. Side-by-side trials with approved organic inputs, both 

synthetic and natural, and cultural methods to evaluate efficacy would strengthen the review process 

and provide growers with valuable information in pest and disease management decisions. The NOSB 

specifically requests collaboration with the Minor Crop Pest Management Program Interregional 

Research Project #4 (IR4) to include materials on the National List in their product trials. Such studies 

would help inform the NOSB review process of sunset materials and to determine if materials are 

sufficiently effective for their intended purpose, particularly when weighed against the natural and 

cultural alternatives. It should be noted that growers commonly rely on a mix of cultural practices and 

both non-synthetic materials and materials from the National List to produce crops of marketable 

quality and sufficient yield for profitability; it is understood that such studies would serve as a starting 

point and would form part of the comprehensive material review process.

10. Evaluation of Microbial Inoculants, Soil Conditioners, and Other Amendments – Vendors of organic 

amendments now offer a large and growing array of microbial inoculants, organic soil conditioners, and 

other materials claimed to improve soil health, crop vigor and quality, and combat weeds, pests, and 

diseases. There is an urgent need for impartial evaluation of these materials to help producers decide 

which products to use and to avoid unnecessary expenditures on products that are unlikely to yield 

benefits. 

11. Pathogen Prevention - Third-party food safety auditors believe that some biodiversity-maintenance 

strategies employed by organic farmers may increase the risk for introduction of human pathogens on 

the field. While some research has been conducted disproving this hypothesis, more research, 

extension, and education are needed to fully understand the relationship between on-farm biodiversity 

and food safety – and this research must be communicated to third-party food safety auditors and 

incorporated into their audits.

12. Climate Change (Reducing Greenhouse Emissions and Sequestering Carbon) - A growing body of 

research demonstrates that organic farming can help prevent anthropomorphic climate change, and 

some strategies employed by organic farming can also help with resilience to current climate challenges 

such as drought and flooding. Although a number of researchers are examining this issue, additional 

work is needed to pinpoint specific strategies that organic farmers can take to reduce greenhouse gas 

emissions and respond to current climate challenges threatening the future of our food security. 

Handling

1. Chlorine Materials and Alternatives - Chlorine materials currently allowed for use in organic 

agriculture are widely used in farming and handling to clean and disinfect equipment, surfaces, and 

produce. There have been some concerns raised about these materials and their impact on the 

environment and human health when/or if they form trihalomethanes and other toxic 

compounds. Chlorine materials are also acutely toxic to workers. New sanitizers and disinfectants are 

regularly petitioned to the NOSB for addition to the National List. FDA regulations on food safety (Food 

Safety Modernization Act) and best management practices for cleaning in handling operations both 

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require a suitable level of cleanliness and disinfection to prevent pathogens from entering the food 

supply.

Producers and handlers are looking for alternatives to chlorine while continuing to provide a safe 

end-product to their customers and the consumer. Addressing food safety while adhering to the 

fundamental organic principles involving human health and environmental impact is a concern.

The organic industry needs better information on how either alternative materials or appropriate 

chlorine materials are best suited for a specific use and control measure. This is especially important in 

determining if the industry can move away from the use of chlorine compounds in the future.

Points of consideration for future research activities:

• Comparison of alternatives to chlorine such as: citric acid, hydrogen peroxide, ethanol, 

isopropanol, peracetic acid, and ozone. How would each compare to the different 

chlorine materials for specific uses? The strengths and weaknesses would need to be 

considered.

• Potential human health and environmental impacts of each chlorine material versus the 

possible alternative materials listed above. Are there ways that these impacts can be mitigated 

and still allow the material to work as needed?

• Determination of which of the above-mentioned alternatives would NOT be a suitable 

substitute for chlorine. What specific uses and/or conditions would this apply to?

• Identification of practices that could be used to help reduce the formation of trihalomethanes 

in those specific situations where chorine is the best material to use.

• Could the rotation of materials for cleaning and disinfecting help lower the risks from 

chlorine materials and still be effective in providing the desired control of pathogens?

• Research on the absorption of chlorine by produce from its use in wash tanks, including 

information about the amount of time of exposure, would help inform understanding of 

human exposure to chlorine and health risks. Are residues from produce washing a 

persistent residual effect or temporary (if temporary – how long is it a viable residue), and 

would it be harmful if consumed at these levels?

• Can research projects that emphasize and reinforce collaboration between researchers, 

agencies that regulate sanitizers and food safety, and NOP be designed with the goal of 

developing an alternative process for evaluating sanitizers and sanitation practices for use by 

organic operations? 

• Is there a measurable transfer of sanitizer residue to organic food following the sanitization of 

food contact surfaces? If residues are not found, is it even necessary for the National List to 

regulate surface/environmental sanitizers? (This topic should not be limited to only National List 

materials, but should also include sanitizers such as quaternary ammonia compounds.) 

• What amount of sanitizer/disinfectant remains on the surface of various organic products after 

a processing or packing step that includes direct treatment with a sanitizer? Does that include a 

water bath containing water treated with a sanitizer? 

• Could the development of robust, post-harvest handling standards better identify which 

sanitation, disinfectant, or treatment practices have an impact on organic integrity? Could 

expanded handling standards assist in regulating and enforcing the use of sanitizers instead of, 

or in addition to, the National List? 

• Could restructuring the National List to separate sanitizers from ingredients and processing aids 

create a pathway to development of an alternative set of evaluation criteria for sanitizers? 

• What would the impact on handlers and processors be if any one of the sanitizers were 

removed from the National List? 

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2. Alternatives to Bisphenol A (BPA) - The Handling Subcommittee is examining the issue of whether to 

prohibit BPA in packaging materials used for organic foods in light of direct evidence that these uses 

result in human exposures and mounting evidence that these exposures may be harmful. There is a 

need for increased research about alternatives for the linings of cans and jars used for organic products 

that do not result in human exposures and health risks.

Materials/GMO

In previous years, the Materials Subcommittee has prioritized the Reduction of Genetically Modified 

Content of Breeding Lines (2013) and Seed Purity from GMOs (2014), issues which are currently being 

addressed through a comprehensive stream of work on Excluded Methods. The following research 

priorities are among the areas that the Excluded Methods work continues to elevate: 

1. Fate of Genetically Engineered Plant Material in Compost - What happens to transgenic DNA in the 

composting process? Materials such as cornstalks from GMO corn or manure from cows receiving rBGH 

are often composted, yet there is little information on whether the genetically engineered material and 

traits break down in composting process. Do these materials affect the microbial ecology of a compost 

pile? Is there trait expression of Bt (bacillus thuringiensis) after composting that would result in 

persistence in the environment or plant uptake? 

2. Integrity of Breeding Lines and Ways to Mitigate Small Amounts of Unwanted Genetic Material - 

Are public germplasm collections that house at-risk crops threatened by transgenic content? Breeding 

lines may have been created through genetic engineering methods such as doubled haploid technology, 

or they may have had inadvertent presence of GMOs from pollen drift. The extent of this problem needs 

to be understood. 

3. Assess the Genetic Integrity of Organic Crops at Risk - Develop then implement methods of assessing 

the genetic integrity of crops at risk to quantify the current state of the organic and conventionally 

produced non-GMO seed. Such assessments are needed on the front (seed purchased by farmers) and 

back end (seed harvested from a farmer’s field) of the production chain as well as on points of 

contamination in the production chain. 

4. Prevention of GMO Crop Contamination: Evaluation of effectiveness - How well are some of the 

prevention strategies proposed by the NOSB working to keep GMOs out of organic crops? For instance, 

how many rows of buffer are needed for corn? How fast does contamination percentage go up or down 

if there are more or fewer buffer rows? Other examples could be whether cleanout of combines and 

hauling vehicles reduces contamination using typical protocols for organic cleaning, whether situating 

at-risk crop fields upwind from GMO crops can reduce contamination, and what the role may be of 

pollinators in spreading GMO pollen. Lastly, research is needed on a mechanism to provide conventional 

growers incentives to take their own prevention measures to prevent pollen drift and its impact on 

organic and identity-preserved crops. This is policy research rather than field research but is equally as 

important. 

5. Testing for Fraud: Developing and implementing new technologies and practices - New 

technologies, tests, and methodologies are needed to differentiate organic crop production from 

conventional production to detect and deter fraud. Testing to differentiate conventional and organic 

livestock products, for example omega 3 or other indicators, is also needed. Additional tools to identify 

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fraudulent processed and raw organic crops require research to combat this problem. Current 

methodologies include pesticide residue testing, in field soil chemical analysis, and GMO testing. Areas 

in need of further testing methodology include phostoxin residues, fumigant residues, carbon isotope 

rations for traceability, validating nitrogen sources using nitrogen isotope rations, or other experimental 

testing instruments that can be utilized to distinguish organic raw and/or processed crops from 

conventional items. Additionally, there is a need to develop rapid detection technologies for adaptation 

to field-testing capacities. 

General

1. Increasing Access to Organic Foods - What factors influence access to organically produced foods? 

Individual-based studies are needed to assess the constraints to accessing organic food. Research should 

be funded that builds on an understanding of constraints by asking what community, market, and 

policy-based incentives would enhance access to organic foods. 

2. Barriers to Transitioning to Organic Production - What are the specific production barriers and/or 

yield barriers that farmers face during the three-year transition period to organic? Statistical analysis of 

what to expect economically during the transition is needed to help transitioning growers prepare and 

successfully complete the transition process. 

Subcommittee Vote:

Motion to accept the proposal on the 2022 NOSB Research Priorities 

Motion by: Wood Turner

Seconded by: Brian Caldwell

Yes: 5 No: 0 Abstain: 0 Recuse: 0 Absent: 2 

Approved by Wood Turner, Materials Subcommittee Chair, to transmit to NOSB, August 9, 2022

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