FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _____6-3-06___________________

Subject: Sunset Review - 205.601 Synthetic substances allowed for use in organic crop 

production 

Chair: Kevin O’Rell 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: _XXXXXX_ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

See attached Recommendation for Renewal of Streptomycin and Tetracycline as Synthetic 

substances allowed for use in organic crop production on 205.601, category use (i) as plant 

disease control. 

NOSB Vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 7 

No – 4 

Abstain – 1 

Absent – 2 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

NOSB Sunset Material Vote 

Response by the NOP:
NOSB- Crops Committee 

Streptomycin and Tetracycline - Sunset Recommendation 

Final NOSB Recommendation 4/20/2006

 

I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

(i): As plant disease control. 

III. Committee Summary: Several commentors were proponents of keeping 

Streptomycin and Tetracycline for fire blight control in apples and pears on the 

National List. Upon subsequent Crops Committee contacts with these commentors 

as well as several organic pear growers and crop consultants in Washington and 

California, it is clear that there is extensive support for the continuation of these 

materials on the list. The fire blight disease is deadly to pear trees and all of the 

growers and consultants surveyed had tested the alternative materials listed in 

the TAP report. All had the opinion that the alternate materials mentioned were 

very much below the efficacy of Streptomycin and Tetracycline and did not prevent 

fire blight to a high enough degree to keep trees from succumbing to the disease. 

One commentor noted streptomycin and oxytetracycline for removal from the list, 

mentioning two of the alternative materials alluded to above (Blight Ban and Serenade) 

as viable control options. Some commenters objected to any synthetics being used in 

organic production. 

 Reviewing the Technical Evaluation Reports for these two materials shows that 

both materials are created by Streptomyces soil bacteria through natural processes 

and are produced in commercial quantities through a fermentation process with 

subsequent chemical processes to isolate and purify the substance produced by the 

bacteria. Tetracycline (oxytetracycline calcium) is presumed to undergo a chemical 

change from the natural oxytetracycline to calcium oxytetracycline. It was unclear to the 

reviewer if streptomycin undergoes a chemical change during the manufacturing 

process. Assuming that the manufacturers comply with applicable water and air 

regulations, it is unlikely that environmental contamination will result from the 

fermentation processes. When applied as directed for fire blight control in apples 

and pears, both materials are unlikely to contaminate the environment. If used in 

accordance with NOP regulations for the intended purpose, it is unlikely that either 

material would cause detrimental chemical interaction with other substances used in 

organic farming or cause any adverse chemical or biological interactions in the 

agro-ecosystem. Both materials have the potential to be toxic to some microorganisms 

in the soil, although one study on streptomycin showed that commercial rates of 

application to soil did not have significant effect on total bacterial and fungal numbers 

in the short term(several weeks). Streptomycin is known to be toxic to algae and the EPA 

requires pesticide products containing it to be labeled as potentially hazardous to 

aquatic plants and not to be applied to water or in areas where surface water is present. 
EPA determined that both materials are practically non-toxic to birds, freshwater 

invertebrates, and honeybees. Streptomycin is slightly toxic to fish, oxytetracycline is 

not. Both carry the lowest level rating for acute toxicity (EPA Category IV). Decades 

of use of these materials in humans has shown many beneficial effects mixed with 

some negative side effects (skin sensitivity to sunlight, allergicity, etc.). Neither material 

seems to be persistent or concentrated in the environment as used in these two crops. 

EPA concluded that streptomycin and oxytetracycline pose no significant dietary 

exposure risk due to lack of detectable residues and long preharvest intervals on pears 

(30 days) and apples (50 days). In actual practice in Washington state, the usual interval 

between the last application (bloom time) of tetracycline calcium on organic pears and 

harvest is 90 + days depending on the variety. 

A wholly natural substitute product mentioned in the report is noted above along with 

one other that was noted by a commentor. Other already allowed substances that could be 

substituted are peracetic acid and copper materials such as Bordeaux mix. The tendency 

for fruit scarring and cracking from copper use on apples and pears (especially Bosc) is 

well documented and avoided by pre-bloom use only, whereas the bloom period is the 

usual time of fireblight infection. No known crop labeled formulation of peracetic acid is 

available at this time. 

 

IV. Committee Recommendation: 

Recommendations based upon comments received- 205.601(i) 

The Crops Committee recommends renewal of the following substances to the use 

category: 

(i) As plant disease control. 

(10) Streptomycin, for fireblight control in apples and pears only. 

(11) Tetracycline (oxytetracycline calcium complex), for fireblight control only. 

Moved: Kevin Engelbert Second: Jeff Moyer 

Committee vote: 2-1 2 absent (Delgado, Ostiguy) 

NOSB vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 7 

No – 4 

Abstain – 1 

Absent – 2