United States Agricultural 1400 Independence Avenue, S.W. 

Agricultural Department of Marketing Room 2642-S, Mail Stop 0268

Marketing Agriculture Service Washington, D.C. 20250-0268

Service

January 16, 2019

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

FROM: Jennifer Tucker, Ph.D.

Deputy Administrator

National Organic Program (NOP)

SUBJECT: Response to National Organic Standards Board Recommendations (Fall 2019

Meeting)

Background

This memorandum responds to the nine recommendations the National Organic Standards Board 

(NOSB) made to the Secretary at its meeting in Pittsburgh, Pennsylvania, October 23-25, 2019.

Summary of Recommendations and AMS Responses

• Petitioned Substances and Related Recommendations. The NOSB recommends two

amendments to the National List of Allowed and Prohibited Substances (National List). This 

section of the U.S. Department of Agriculture (USDA) organic regulations includes synthetic 

substances allowed in crop and livestock production, nonsynthetic substances prohibited in 

crop and livestock production, and non-organic substances allowed in organic handling.

Substance Section of 

Organic 

Regulations

NOSB Recommendation

Fatty alcohol (C6, 

C8, C10, C12 

Naturally Derived)

Crops

§ 205.601

Classified as synthetic; recommended for 

addition to the National List with annotation -

For sucker control on organic tobacco crops. 

Potassium 

hypochlorite

Crops

§ 205.601

Classified as synthetic; recommended for 

addition to the National List with annotation:

Chlorine materials - For use in water for 

irrigation purposes. 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.
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

Page 2

AMS Response: AMS is reviewing the NOSB’s two National List recommendations listed

above.

• Research Priorities. The NOSB recommends 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.

Building upon the 2018 list of research priorities, the NOSB added four new proposed 

research priorities in 2019:

Crops: Ecosystem service provisioning and biodiversity of organic systems

Crops: Managing Cover Crops for On-Farm Fertility 

Crops: Identify Barriers and Develop Protocols for Organic Nursery Stock Production

Materials/GMO: Assess the Genetic Integrity of Organic Crops At Risk

AMS Response: AMS is reviewing the NOSB’s recommendation and will share it with 

USDA research agencies as appropriate.

• Excluded Methods: Induced Mutagenesis and Embryo Transfer in Livestock proposal. 

The NOSB recommends the NOP add the following to the table of excluded methods in the 

NOP excluded methods guidance:

1. Induced mutagenesis - Developed via use of in vitro nucleic acid techniques.

2. Embryo transfer, or embryo rescue, in animals. Use of hormones not allowed in 

recipient animals.

AMS Response: AMS is reviewing the NOSB’s recommendation.

• Genetic Integrity Transparency of Seed Grown on Organic Land. The NOSB

recommends the NOP provide an “Instruction to Certifiers” regarding seed integrity. The 

purpose of this instruction is to have certifiers inform their producers that GE contamination 

of seed or planting stock is being tested regularly by those suppliers who are at risk for GE 

contamination of their products. Producers are encouraged to discuss GE contamination with 

suppliers willing to share the results of the GE testing they are currently doing but typically 

do not disseminate, unless requested by the buyer of the product.

AMS Response: AMS is reviewing the NOSB’s recommendation.

• Use of Excluded Method Vaccines in Organic Livestock Production. The NOSB 

recommends the following change to the National Organic Program Final Rule §205.105 (e) 

(Changes to the current rule noted in bold). (e) Excluded methods, except for vaccines: 

Provided, That, vaccines produced through excluded methods may be used when an 

equivalent vaccine not produced through excluded methods is not commercially available.

AMS Response: AMS is reviewing the NOSB’s recommendation.

• Policy and Procedures Manual (PPM) updates. The NOSB recommends several updates 

to various sections of the PPM. These changes include clarifying existing language about 

officer elections, adding duties to the NOSB Secretary’s role, and codifying the optional 

process of developing a petition discussion document as part of the review process.
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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AMS Response: AMS will incorporate the changes and post the updated PPM on the AMS 

website.

• Sunset Review - Recommendations for Removal. The NOSB recommends that dairy 

cultures and alginic acid (§§ 205.605) be removed from the National List. Both substances 

are currently due to sunset on March 15, 2022. The NOSB completed their sunset review of 

these substances early to distribute the sunset review workload (see NOSB’s Fall 2016 

recommendation). The Board requested that substances undergoing early sunset review 

remain on the National list until their sunset date (for sunset dates see NOP 5611 National 

List Sunset Dates).

Substance Section of 

Organic 

Regulations

NOSB Recommendation

Dairy cultures Handling

§ 205.605

Remove from § 205.605

Alginic acid Handling

§ 205.605

Remove from § 205.605

AMS Response: AMS is reviewing the Board’s recommendations to remove both dairy 

cultures and alginic acid from §§ 205.605 of the National List.

• Sunset Review - Not Recommended for Removal. The NOSB completed its sunset review 

of the following substances (listed below). The Board did not recommend removing these 

substances from the National List.

Substance National List Section Use

Hydrogen peroxide 205.601 (a) Crops

Hydrogen peroxide 205.601 (i) Crops

Soaps, ammonium 205.601 Crops

Oils, horticultural (Narrow range oils) 205.601 (e) Crops

Oils, horticultural (Narrow range oils) 205.601 (i) Crops
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Pheromones 205.601 Crops

Ferric phosphate 205.601 Crops

Potassium bicarbonate 205.601 Crops

Magnesium sulfate 205.601 Crops

Hydrogen chloride 205.601 Crops

Ash from manure burning 205.602 Crops

Sodium fluoaluminate 205.602 Crops

Atropine 205.603 Livestock

Hydrogen peroxide 205.603 Livestock

Iodine 205.603 (a) Livestock

Iodine 205.603 (b) Livestock

Magnesium sulfate 205.603 Livestock

(Parasiticide) Fenbendazole 205.603 Livestock

(Parasiticide) Moxidectin 205.603 Livestock

Peracetic acid 205.603 Livestock

Xylazine 205.603 Livestock

DL - Methionine 205.603 Livestock

Trace Minerals 205.603 Livestock

Vitamins 205.603 Livestock

Acids, Citric 205.605 Handling 
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Acids, Lactic 205.605 Handling 

Calcium chloride 205.605 Handling 

Enzymes 205.605 Handling 

L-Malic acid 205.605 Handling

Magnesium sulfate 205.605 Handling

Microorganisms 205.605 Handling

Perlite 205.605 Handling

Potassium iodide 205.605 Handling

Yeast 205.605 Handling

Activated charcoal 205.605 Handling

Ascorbic acid 205.605 Handling

Calcium citrate 205.605 Handling

Ferrous sulfate 205.605 Handling

Hydrogen peroxide 205.605 Handling

Nutrient vitamins and minerals 205.605 Handling

Peracetic acid 205.605 Handling

Potassium citrate 205.605 Handling

Potassium phosphate 205.605 Handling

Sodium acid pyrophosphate 205.605 Handling

Sodium citrate 205.605 Handling
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Tocopherols 205.605 Handling

Celery powder 205.606 Handling

Fish oil 205.606 Handling

Gelatin 205.606 Handling

Orange pulp, dried 205.606 Handling

Seaweed, Pacific kombu 205.606 Handling

Seaweed, Wakame (Undaria 

pinnatifida)

205.606 Handling

AMS response: AMS thanks the NOSB for their review of these substances due to sunset.

Summary

AMS acknowledges and sincerely appreciates the many hours NOSB members provided in 

developing its recommendations. AMS supports NOSB’s vital role in representing the diversity 

of the organic community and ensuring organic integrity.

AMS thanks Harriet Behar for her service as NOSB Chair and looks forward to working with the 

new NOSB leadership.

AMS also thanks four NOSB members whose terms end in January 2020: Harriet Behar, Tom 

Chapman, Lisa de Lima, and Ashley Swaffar. The program appreciates the dedication and hard 

work, and wishes the departing members well.