Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, January 10, 2012, 1 pm ET 

Attending: Katrina Heinze (Chairperson), Jay Feldman, Calvin Walker and Jennifer Taylor (Vice-chairperson) 

Absent: Wendy Fulwider, John Foster, Tina Ellor NOP Staff: Lisa Brines and Lorraine Coke New Members: Harold

Austin and Zea Sonnabend 

Project Point Person Status Target Meeting 

Materials Review Process KH In progress TBD

Petition Guidelines

(tentative)

? TBD

Materials classification MC / LB TBD

Petition tracking KH / LB In progress Ongoing

Technical Report tracking KH / LB In progress Ongoing

Sunset 2013 KH / LB In progress Fall 2011 / Spring 2012

Agenda: 

o (15 minutes) Update work plan – Below is the work plan that I communicated at the Savannah 

meeting. Given the transition I thought we should spend some time making sure I’ve captured 

everything and it makes sense

Materials WorkPlan – obviously finalizing will be dependent on the new chair & committee

• Research Framework:

o Review the public comments received on the discussion document

o Finalize the framework and bring back to spring meeting with a starting list and proposal on the ‘big idea’ 

priorities

o Items for the list collected at the Fall 2011 meeting:

 Fire blight control in organic pear and apple production. Alternatives for use of tetracycline and 

streptomycin

 Alternatives for copper sulfate in rice production

• Aquaculture Materials

o Provide ongoing feedback to AWG to enable development of petitions that are sufficient for our two 

“trial” balloon petitions

o Develop TR requests based on the sufficient petitions

o Provide feedback and work with NOP to enable development of TR’s that the committee deems to be 

sufficient

o Evaluate the materials to our criteria; optimize process for rest of petitions so we are ready when NOP 

begins work on the standards

• Classification –will work with NOP at their request

• Update evaluation criteria checklist with policy committee to reflect our recent discussions that a section for a 

narrative was needed.

• On WorkPlan but not intended for next meeting

o Materials Review – Process Improvement -- As discussed in the Materials Committee update, we are 

planning to collaborate with the other committees and the NOP to improve our processes with our initial 

plans to focus on the 

 Evaluation checklist so it better reflects the different type of material actions we consider

 TR request form so we can customize TR’s better to individual material situations

 Define what a good TR looks like

o Materials
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

 Take from the table petition (September ’08?)

 Materials never on the table (see CCOF comments) (Katrina note – Zea is very familiar with this 

topic)

• (10 minutes) Review Materials Update from December – Any outstanding items from any committees?

• (20 minutes) Aquaculture – Decide how committee wants to proceed and determine next steps. If time, 

we could look at the vitamin petition that Lisa just sent.

Discussion:

Review of work plan - Jennifer will confirm with John on any possible overlap with Handling committee work 

plan

Next steps: some need for clarification on aquaculture materials and what is needed in materials petitions

Background – carbon dioxide and vitamins/minerals petitions for aquaculture (need to clarify so AWG has 

guideline for how to submit future materials)

Specific to research framework – at Savannah tried to take note on topics to be added (fire blight and 

alternatives for copper sulfate in rice production). Any others? These seem to be the most contentious. 

Suggestion to add methionine as well. 

Wish list: take from the table petition (in early NOSB history – materials considered by the Board then “tabled” 

and nothing ever happened, 2-3 years ago the MC brought rec to take all those materials and bring them back 

into consideration, intent was to go back to petitioners and see if any interest still exists, assumption was that 

very few would receive affirmative response, resolution could be to write rec to take no further action – these 

materials are still in “limbo,” this process would help to clear the books); and materials never on the table

(materials that had been “in review” but never made it to a board meeting, determining this list would be a bit 

harder, suggestion to take list that CCOF provided during public comment and go from there). 

is it understood that these materials are not part of normal petition process? 

There are 7 items on list, all went through petition process, none are in use currently. There are a couple on 

the “take from table” (i.e. soy protein isolate) list that were delayed/tabled due to materials classification 

document. 

Important to have process in place before these materials are brought up again. 

How important are these?

Materials review process (or classification?): where are we with this? Where is the NOP with this? The NOP is 

currently working on draft guidance in regards to classification. This will take a while due to process. 

one member sees this as two parts (difference between classification policy and rec on 

“significance/insignificance”) – how are these different? The sig/insig rec did not pass the Board and the NOP is 

trying to draft guidance with consideration of this. Should the MC take classification up again (on workplan)?

suggestion to let NOP work on guidance first and then the Board can submit clarification/questions after 

initial work is completed 

time for “how you would execute this?” rather than having the MC try this again

another question from a committee member about whether the Board will have opportunity to 

comment/provide feedback before final guidance or draft to public is completed

intent of NOP is to include participation/feedback from MC in this process

Monthly materials update:

Won’t be a Jan update b/c no sig change since Dec

Background – this list is maintained by Lisa B. and is updated monthly to keep track of materials review process

Crops – 2 items

-tr for pheromones (need finalized asap b/c EPA list 3 interts)

-Suff review for oxidized lignites
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

Livestock – 2 items

-review of TR on GMO vaccines 

-suff review on TR for methionine

Handling – 

-might be helpful to combine suff review and TR reviews

Materials - 

revised petition for AWG on vitamins and minerals in aquaculture

Question on whether there is a better way to make committee more efficient in review of materials?

Opinion from resigning Materials Chair – the process has improved over the last 5 years and the monthly 

materials spreadsheet has been very helpful in tracking the process

Aquaculture:

How to resolve issue on aquaculture materials? Uniqueness of water issues wasn’t fully addressed.

Previous review of aquaculture materials by last Board missed discussion of this materials review process. There 

will be no Board members from that time on the 2012 Board. The MC/Board could decide to discuss/decide it all 

again. Suggestion that existing members review/read old transcripts. Jeff Moyer and Jennifer Hall were 

(previous Board members) heavily involved in the discussion and they may be good resources.

Next Calls: 

February 14, 2012

February 28, 2012

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, February 14, 2012, 1 pm ET 

Attending: Jennifer Taylor (Chairperson), Zea Sonnabend (Vice-chairperson), Jay Feldman, Wendy Fulwider and

Calvin Walker 

Absent: John Foster

NOP Staff: Lisa Brines and Lorraine Coke 

Project Point Person Status Target Meeting 

Research Priorities ? In progress TBD

Aquaculture Materials 

Review Process

Jay? In progress Spring 2012?

Material Evaluation

Checklist

Zea? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Agenda: 

1. Welcome and member introduction

2. Issues to be discussed during meeting: 

• Aquaculture/received revised petition for vitamins for aquaculture use,

• Development of Working Group that will identify research priorities/needed research areas and cultural 

and management strategies including varietal selections, etc. for successful sustainable organic farming,

• Expert participation/discussion of issues during telephoned meetings,

• Development of approach for Tabled Issues/Policy Committee issue?

• Development of discussion document on extractants.

3. Other Issues 

4. Issue assignment and deadlines 

5. NOP update 

Discussion:

Welcome to committee members – introduction from Zea Sonnabend (new member)

Aquaculture:

The committee has been asked to re-examine the aquaculture materials 

The committee submitted a discussion document during last meeting and did receive some materials. There was 

a previous petition from 2011. The first doc was received in January 2011, but committee didn’t start working on 

it until later in spring. In August 2011 the committee submitted questions regarding petition sufficiency. 

Responses were not received until January 2012, but the MC had met with members from the AWG before that 

to discuss. No petitions have been posted to the NOP website at this time.

MC has to review response from sufficiency questions and determine whether they have been addressed. 

Committee needs to determine the adequacy of the checklist, the sufficiency of the responses, etc. These are all 
materials that are on the materials list for terrestrial use, but need to determine whether questions/review are 

sufficient to determine uses in aquatic medium.

Lisa has done a review of the petition and has

Clarification – mention of “revising” questions on checklist. It is not that the questions need to be revised (they 

are based on OFPA), but they need to be applied to aquaculture context. 

An example – one question has to do with toxicity/environmental contamination and this would be different for 

aquaculture materials (i.e. how they may contribute or not contribute to contamination based on type of use)

Questions:

-What should we expect to be doing on aquaculture by the next Board meeting?

would be nice to have more guidance on review of aquaculture materials

One issue is that occasionally the responses from the petitioner are very simple. On the issue of manufacturing

processes – the response was that it is “proprietary information”

-Is there a process to get clarification/verification of these answers from the AWG?

Yes, the MC has authority to request TR. It would not likely be ready by the spring 2012 meeting.

Calvin is on the AWG – he will review and 

-Did the NOP approve aquaculture in ponds or the ocean?

The use of the materials would be broad. There has been no defined area of accepted aquaculture. Unclear 

how you could regulate the application of these materials in open systems. This could be restricted by the NOSB 

in an annotation.

Zea will review checklist and get back to the committee with comments at next meeting.

The questions on current checklist come from OFPA and the NOP regulations – may not make sense to change 

the questions.

What is the MC’s goal in terms of the Board meeting in the spring?

Any sense of where the committee should be by the spring? 

The purpose of doing the material review process and petitions from AWG is that they have an additional 20-25 

materials for review. Important to make sure that the Board is ready to receive all these materials. The AWG 

would like the Board to move forward on this process, but it is important to ensure that the Board is ready.

The nutrient and vitamins petitions/reviews are more of a priority in terms of materials.

If we do trial balloons on some of the more innocuous materials and then do review on a microbial mateirals 

that is essential to the system. The entire system could hinge on one material. Shouldn’t the committee know 

the entire range of materials that the AWG will be submitting. Wouldn’t it make sense for the committee to 

start with some of the “tougher” materials and work backwards? The tougher ones are also the key one – they 

may be more critical to the viability of these systems. Suggestion from another Board member to review 

materials on a case-by-case process. Are we going to go through the process of requesting TRs and possibly 

waste resources (concern on funding and prioritization). Supplemental TRs will be needed on certain materials 

because they will have different impacts in aquatic systems. 

Will there be an agenda for the March 13 meeting?

Yes, the MC will prepare questions in advance. They will have the AWG on the call for 30-45 minutes.

Expert on aquaculture – Chair will invite to participate on next call

Additional items/tabled items – will be addressed by Policy Committee

Tabled items can be brought up again, or “untabled” by the Board, but the Board does not currently have a 

policy on how they deal with issues that have been postponed and gone unaddressed for a period of time

Policy committee should evaluate this type of situation and determine process
Some of these materials on the list are currently in use

The materials should be assigned to the appropriate/relevant committee to decide what to do/how to proceed

If there are lingering policy issues, then maybe PDC should take that issue as part of their work plan 

Next Calls: 

February 28, 2012 – prepare questions for the March 13 call with AWG. Presentation from expert?

March 13, 2012 – conversation with AWG

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, February 28, 2012, 1 pm ET 

Attending: Jennifer Taylor (Chairperson), Zea Sonnabend (Vice-chairperson), Jay Feldman and Calvin Walker 

Absent: Wendy Fulwider and John Foster

NOP Staff: Lorraine Coke 

Project Point Person Status Target Meeting 

Research Priorities Zea Discussion document (fall, 

2011); In progress

TBD?

Aquaculture Materials 

Review Process

Jay? In progress Spring 2012?

Material Evaluation

Checklist

Zea? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Agenda: 

A.) Review of minutes from last meeting and approval/addition to minutes.

B.) Issues to be discussed during meeting (30 min):

• Aquaculture

• Review and discussion

• Expert participation

 Identify issues, concerns, questions

 AWG will meet on March 13, 2012 MC call.

 Experts

• Other Issues (10 min) 

C.) Issue assignment and deadlines (5 min) 

D.) NOP update (5 min) 

Discussion:

Discussion of items to include on agenda for today’s meeting

-Research Priorities Document: it was a discussion document in fall, 2011 – needs further development to 

become a formal recommendation. Possible to submit to NOP as a recommendation/letter that would be sent 

to appropriate agency within USDA? This sort of “priority report” could be sent to the NOP each year with 

updated research priorities. This item will tentatively be on the spring 2012 agenda.

Review of minutes from last meeting 

Minutes were reviewed and approved by the committee members

Issues 
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

Extractants – were discussed at NOSB meeting in Seattle

-NOSB had proposal that would allow for extractants as long as they were not above allowable levels or 

tolerance levels, the NOSB did not pass with 2/3 vote, committee was told that this issue would be taken up by 

the NOP, question regarding the process. Will this process be discussed with committee/NOSB? Uncomfortable 

that Board will not fulfill its duties and not be part of this process. From perspective of NOSB’s responsibilities 

– it is important to be involved in evaluation of these materials. There is responsibility to review process/input 

of that chemical’s (extractant) production. Issue is more on “insignificant residues” issue that was discussed in 

Seattle. 

Aquaculture – a document was sent around to committee “new comments and questions” this is based on trial 

petition on vitamins. This was based on questions that went out in July regarding sufficiency. There is some 

frustration because the committee is not getting clear answers. 

-The AWG may feel that vitamins are vitamins and they are allowed on national list (for livestock). Assumption 

that MC/NOSB should just accept these as a “class” of materials? Is this a good use of the MC’s time? If it is 

allowed on National List for terrestrial use, then should it be allowed in aqua-based systems? 

-Maybe it is helpful to have a discussion on a revised checklist that would be more specific for these types of 

materials used in open water systems. Some suggestions were sent to the AWG, but they were not addressed 

completely. Because these materials are petitioned in a group, there are more questions/complications in 

reviewing these items. 

-Should the TR address just one type of system (i.e. open vs. closed aquatic system)? One MC member 

suggested that the TR should address both systems at once and then the MC can make recommendation based 

on that information. 

Next Calls: 

March 13, 2012 – conversation with AWG (30 min), finalize agenda items for spring, review research priorities 

recommendation (draft)

March 27, 2012 – 

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, March 8, 2012, 1 pm ET 

Attending: Jennifer Taylor (Chairperson), Zea Sonnabend (Vice-chairperson), Jay Feldman and Calvin Walker 

Absent: Wendy Fulwider and John Foster

NOP Staff: Lorraine Coke 

Project Point Person Status Target Meeting 

Research Priorities Zea & Calvin Discussion document (fall, 

2011); In progress

Spring 2012?

Aquaculture Materials 

Review Process

Jay? In progress Spring 2012?

Material Evaluation

Checklist

Zea? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Draft proposal Spring 2012

Agenda: 

AWG call - Identify questions/issues

• Review:

 +Draft Discussion Paper on Extractants and Solvents

 +Draft Recommendations on Significant Residues

Discussion:

AWG call - Identify questions/issues

-requested by the AWG – some concerns regarding the pace of the review of aquaculture materials

-assumption that no items will be put forth at the spring NOSB meeting (i.e. no rec for any specific aquaculture 

material)

-committee previously responded to both petitions submitted by AWG (asked for clarification/additional 

information) – current status is that AWG will want to know if response to questions on vitamins petition are 

sufficient 

still some concerns of terrestrial vs. aqua uses

concern over synthetics/non-synthetic – documentation on commercial availability?

-rather than ask for TR, the MC could ask AWG to edit the petition and include some of this additional 

information

-reason MC is not asking for TR at this time is that this group of vitamins is already approved for 

livestock/terrestrial use in the regulations

-this trial balloon does not evaluate open/closed systems enough

-committee had previously mentioned that it would prefer to review individual materials/substances rather than 

groups of substances, may be helpful to remind the AWG about this
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

-MC may have discussion with other groups/individuals regarding organic standards in Europe

-feeling among many committee members that more information would be helpful

Questions:

-Comfortable that vitamins are on list for livestock, and would be ok with approving them for closed system for 

aquaculture, but what would happen to these vitamins in an open system? 

-Would AWG prefer the committee/Board to review open and closed systems together (this could be a slower 

process) or should they review open/closed separately?

-What about synthetics/non-synthetics when the petitioned items are grouped? How do you get at issues of 

commercial availability, alternatives, etc.? 

-Were there other documents that raise issues/questions related to this? Are there other documents that the 

MC members should review?

Draft discussion document on extractants/solvents

-this issue came from previous NOSB meeting

-some overlap with handling committee

-this will be developed into a discussion document for the spring meeting

-gums water-extracted only, hexane extractions, alkali extraction, etc. – many volatile solvents used in extracting

-important to lay out some of the issues surrounding the use of tese materials

-controversy over definitions of these materials (suggestion to use boiling point to define volatility)

-have to explain what would be effected by these materials (agriculture, non-agricultural, etc.) 

-what is meaningful amount of volatile synthetic solvent?

-is there a good explanation for not having uniform process/method for dealing with these?

Draft recommendation on significant residues

-identified by Board in 2009 as an issue

-language regarding significant levels of residues under classification of materials policy

-when this was adopted, there was work on this that was not finished

-proposal is a definition of “significant” and making determination on detectable residual amounts

-given previous vote of Board in 2009, this needs to be addressed by the Board again

-MC members should review this and discuss by email, prior to next meeting

-the guidance for classification of materials (as drafted in 2009) is in work plan – will it address these issues? 

-common practice used in materials in 205.601 is that synthetic solvents can be used to extract products as long 

as they are removed in the end

-committee has discretion to move forward on issues that they feel need addressing

-is it waste of time for MC to be addressing this issue? – one concern is that it will be difficult to reach consensus 

(therefore NOP moved forward on draft guidance)

-should consider language in previous recommendation and whether the NOSB will be able to get consensus 

based on this new language that is being proposed

-different regulatory language regarding other materials may be helpful to review

Research priorities document

-what are the next steps forward?

-how does this translate into an actual agenda item for the next meeting?

-previous MC idea was to develop this into a recommendation for guidance

-was a process issue before – still trying to figure out the most important/relevant issues
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

-try to figure a range of research topics

Next Calls: 

March 13, 2012 – conversation with AWG (30 min), finalize agenda items for spring, review research priorities 

recommendation (draft)

March 22, 2012 (3 pm EST) – 

March 27, 2012 – 

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, March 13, 2012, 1 pm ET 

Attending: Jennifer Taylor (Chairperson), (Vice-chairperson), Jay Feldman, Zea Sonnabend, John Foster and

Calvin Walker

AWG: George Lockwood, Ron Hardy, Ralph Ellston, Sebastian Belle

Absent: Wendy Fulwider 

NOP Staff: Lorraine Coke, Michelle Arsenault and Melissa Bailey

Project Point Person Status Target Meeting 

Research Priorities Zea & Calvin Discussion document (fall, 

2011); In progress

Spring 2012?

Aquaculture Materials 

Review Process

Jay & Calvin In progress Spring 2012?

Material Evaluation

Checklist

Zea? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Draft proposal Spring 2012

Agenda: 

• AWG telephone call and discussion

• Review:

 +Draft Discussion Paper on Extractants and Solvents

 +Draft Recommendations on Significant Residues

• Other Issues

Discussion:

AWG discussion

-Introduction of AWG members on the call

-Original questions were sent out in July – the NOSB got responses back in January; mostly regarding process 

issues 

-Revised petition for vitamins was sent to MC and now ready to move forward with TR or to proposal stage if no 

TR is requested by committee

-Trace elements will be next, then biologics, trace minerals, sanitizers, etc.

-Anticipating a final rule sometime in the future (NOP is not officially working on this project at this time, there is 

a group at the USDA that is being formed), therefore would like to move these forward to next step

MC has discussed petitions and revisions – some questions still lingering

-distinction between open and closed 

-clarification on how vitamins are fed/administered to aquatic species (usually fed in pellets, at low quantities, 
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

and would “benefit” wild fish if they accidentally ate them)

-according to one AWG member – there are no known adverse effects to other fish, plants or the environment 

-food is expensive, therefore more economically feasible to feed only amounts consumed (if any feed does 

escape, then wild fish benefit, feed dissolves or there are some systems that include zones where food is 

collected/gathered if there is excess that was not consumed) 

-also use “demand feeders” (in trout farming) and fish trigger release mechanism – this is very efficient

-in net pen/open systems there are also demand feeders, but there are also feed broadcasting systems with 

computer monitor/Doppler system to sense any wasted or uneaten feed

-food conversion (amount of feed given relative to weight gain) is monitored and is highly efficient

Another issue that has come up is TR review on vitamins – whether this is needed

-National Academy of Sciences – nutrient requirements for domestic animals (this has been expanded to fish)

-2011 – most recent update was released and reviews all nutritional requirements for fish

-these vitamins are essential in diet

-in terms of 3rd party review, there are documents/academic papers that verify need for vitamins in aquatic 

species

What countries have good aquaculture certification/monitoring program?

-Soil Association in UK has some regulations/guidelines

-Natureland in Germany has guidelines for some species (shrimp, specifically)

-EU standards are somewhat confusing and the US has better standards

-New Zealand and Australia have standards, but not as comprehensive as the U.S.

-Canada is developing standards

Is there direct dissolving vitamins in the water?

-For plants – vitamins are dissolved in the water, not for fish (fish are fed directly through feed)

-in case of open system – there is requirement to grow other animals (like shellfish) or kelp to help control 

vitamins that are released in water (multi-trophic system) 

-pre-mix has .5-1.5% vitamins in the feed (this would be ppm if not consumed by fish and dissolved in water)

Are there differences relating to different materials and their possible contamination/applications?

-most materials that will be petitioned are added directly to feed (often in small quantities) 

-sanitizers/disinfectants are used on the farm, but they are not intentionally discharged into water/environment

-presumption that a whole group of feed ingredients, disinfectants, sanitizers, etc. will all need to be approved 

for aquatic systems – many of the AWG members agreed that there is a group of materials that are essential to 

aquatic systems and all will need to go through process

Discussion after the AWG left the call

Plan for this petition moving forward?

-not urgent to develop a recommendation on this (or other aquaculture materials) at the next meeting

-bring update to spring meeting and possible recommendation for fall 2012 meeting

-still not clear on whether to move forward and request a TR or not

How do you review this without knowing the system that it will be used in?

-because rulemaking has not happened, it is hard to proceed in this scenario

-historically – have assumed that rulemaking will follow decisions made pre-rule
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

Next Calls: 

March 13, 2012 – conversation with AWG (30 min), finalize agenda items for spring, review research priorities 

recommendation (draft)

March 15, 2012 (2 pm EST) – wrap-up discussion on AWG

March 22, 2012 (3 pm EST) – Extractants and Solvents, and Significant Residues

March 27, 2012 – 

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, March 13, 2012, 1 pm ET

Attending: Jennifer Taylor (Chairperson), Zea Sonnabend (Vice-chairperson), Wendy Fulwider, Calvin Walker and 

Jay Feldman 

Absent: John Foster 

NOP Staff: Lorraine Coke, Michelle Arsenault and Lisa Brines

Project Point Person Status Target Meeting 

Research Priorities Zea & Calvin Discussion document 

(presented at fall 2011

meeting); In progress

Spring 2012?

Aquaculture Materials 

Review Process

Jay & Calvin In progress Spring 2012?

Material Evaluation

Checklist

Zea? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Discussion document Spring 2012

Agenda: 

• Recap of AWG discussion

• Review:

 +Draft Discussion Paper on Extractants and Solvents

 +Draft Recommendations on Significant Residues

• Other Issues

Discussion:

Most of the committee members have not reviewed the documents

-some sent around comments by email

Discussion on significant residues document

-to the extent that something is showing up as a “synthetic,” need to understand what materials are used

-important to define “significant” because previous policies mention significant levels

-a lot of chemicals are used, but are not detected (therefore not required to review)

-are there other approaches to deal with “known” (or detectable) synthetics

-this issue has been moving around the Board for several years

-in April 2011 the NOSB proposed a policy to define and detect thresholds for “synthetic” materials in organic 

products

-one committee member was concerned that trying to define “significant” with the word “known” does not 

make sense
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

-another committee member commented that nothing that should prevent a Board from defining something as 

“detectable”

-there is a need to define processes for reviewing these materials – in the last policy the Board put forth an idea 

that would allow for a particular

-aim to create a proposal that develops procedures for ACAs and MROs to do this process themselves

-one comment suggested that the definition of “known” that is too much of a stretch and the policy will not 

work on the ground

-level of detection is a good thing, currently MROs have 

-no guidance explaining explicit levels of what is ok and what is not (100 ppm vs. 200 ppm – at what point is it 

“detectable” and would it become a “significant” detection)

-there is a level of inconsistency regarding amounts of “allowable” substances

-if the laboratory comes back with a detectable amount, would it trigger the Board to review that particular 

product? Even if there are guidelines, then the Board may decide that there are certain levels that mean a 

particular material should be reviewed.

-no predetermination when a substance detected that it would be allowed/not allowed

-suggestion that the questions around this document be folded into the extractants/solvents document

-another suggestion to convert this document to a discussion document for spring meeting and prepare a 

proposal for the fall meeting – more feedback from the public and suggestions on how to address this

-should clarify in proposal whether the NOSB has the authority to review significant levels of “synthetic” 

materials

Questions:

-How do MROs deal with different levels of a substance when detected – when is it “significant” and how would 

an MRO know? there are some guidelines regarding particular materials, but some materials do not have 

health/safety guidelines

Discussion on extractants/solvents

-suggestion to fold in “significant” discussion document into this document

-there was a question/comment about “volatile synthetic solvents”

-there is a clause in the OFPA, but not consistent application

-important to clarify and once this happens, there may be items from the national list that have to be reviewed 

again

-this is only dealing with materials on the national list now (synthetics on the crops list and non-org 

agricultural/synthetic allowed materials for handling)

-on page 4 – agricultural item that has been turned into a synthetic (suggestion to elaborate in this section) 

-on page 7 – suggestion to make separate question on non-synthetics (focus on 205.601 materials)

-additional questions to clarify different types of extractants – trying to create categories or require individual 

review on product to product basis?

-have to be careful/duty under classification document – need to be clear 

Next Calls: 

March 22, 2012 (3 pm EST) – further discussion on Extractants and Solvents and Significant Residues, further 

discussion on AWG (next steps with petition), discuss Research Priorities document

March 27, 2012 – vote on documents

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee

Tuesday, March 22, 2012, 3 pm ET 

Attending: Jennifer Taylor (Chairperson), Zea Sonnabend (Vice-chairperson), John Foster, Calvin Walker and Jay 

Feldman 

Absent: Wendy Fulwider 

NOP Staff: Lorraine Coke, Michelle Arsenault and Lisa Brines

Project Point Person Status Target Meeting 

Research Priorities

Proposal Document

Zea & Calvin Discussion document (was 

presented at fall 2011

meeting); Draft proposal In 

progress

Spring 2012?

Aquaculture Materials 

Review Process

Jay & Calvin In progress Spring 2012?

Material Evaluation

Checklist

Zea? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Discussion document Spring 2012

Agenda: 

1.) Review and approval/ or addition to minutes from last call. 

2.) Issues to be discussed during meeting (40):

• Extractants and Solvents Discussion Paper

• Significant Residues in Classification of Materials

• Research Priorities Proposal Document

• Aquaculture Discussion Document

3.) Other Issues (05)

Making the deadlines.

 Call for next week?

4.) NOP update (05)

Discussion:

Review/approve minutes from last call

Minutes were reviewed and approved.

Extractants/solvents discussion document

Review/discussion on the latest draft of the document. The name of the title was changed and several edit 

swere made.
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

Solvent def: synthesis for combining materials can be a “solvent,” not intent of paper to prohibit all solvents, 

but just solvents that use synthetic extractants.

Should we make a distinction between volatile (not toxic) solvents and other types of solvents.

The numbering system in the document needs to be edited. 

How should volitlie synthetic solvents be defined especially in relation to the regulations?

Should we make a distinction between different types of solvents?

Distinction in types of solvents is important – water is a “solvent”

More of a discussion of types of solvents is important 

The first question in the questions needs to relate to part 1

Add supercritical carbon dioxide to the chart

Is there a way to highlight the section regarding the public’s comments?

What is the relevance of volatility as it applies to what we are doing? Is it really an issue around manufacturing 

or worker exposure around manufacturing? Is it a term that just gets people excited? not likely that a 

consumer will deal with this directly. Would we have the same questions if the word “volatile” weren’t there?

-it is related to exposure

-it is not often referred to by the NOSB

-it is in the regulation

-important to calm down the reactions to extractions (like hexane extraction)

-would be helpful to resolve this confusion around the word/definition

On page 3, whether a substance would change a material from agricultural to non-agricultural (sometimes a 

preference when placed on the National List – on 205.606 re

Jay made a motion to approve as a discussion document to present at the meeting. Calvin Seconded. Vote: 5-

yes, 1-absent.

Next steps: Jay will make changes and circulate the document one more time. Hope to vote on it next week.

Significant residues in classification of materials discussion document

Review of comments from committee members.

Whether a material should be “reviewable” – what is the “trigger” that pushes a material forth for review by the 

Board

Change “synthetic impurity” to “synthetic residue” is acceptable

Would not want to lose this sense of “legal responsibility”

It would be helpful to have things expressed a little more plainly

This document is moving forward as a discussion document to receive public comments

Would the committee be ok with moving this document forward if changes are made to the tone, clarity, etc.?

Feeling from some board members that this document needs to be trimmed down and refined

Next steps: will review, make edits , and circulate to the committee. Plant to vote on it next week.

Research priorities proposal document 

The discussion document from last fall did not receive many comments on regulations.gov

Did not insert the same background info. from the last discussion doc b/c seemed reparative

Some edits to the content where it wasn’t very clear – some changes from committee members

-the materials committee will collect research suggestions from other committees
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

-research priorities is a priority for more than just the materials committee

-work with other agencies to better understand what the priorities are in organic agriculture

-have to balance the ability to make demands on other peoples’ time (to attend additional agencies sessions)

 -creating a list will take place annually at the fall meeting

-in area where the examples are cited, could alternatives and cultural management perspectives be 

incorporated (so add a bullet point to ask question about cultural practices and the whole system)

-would a question on market reception/research be appropriate as well? 

-also add “private foundations” and “research foundations’ to the list of funders

Future calls:

March 27 (1pm EDT)- review and vote on Research Priorities Proposal, review and vote on significant residues 

discussion document, discuss next steps on aquaculture

March 28 (3pm EDT) – 

March 30 (noon – 1 EDT) –If needed

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee Meeting Notes

Tuesday, March 27, 2012, 1:00 ET 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), John Foster (JFo), Calvin 

Walker (CW) and Jay Feldman (JFe) 

Sitting in: Barry Flamm (BF) 

Absent: Wendy Fulwider (WF)

National Organic Program (NOP) Staff: Michelle Arsenault and Lisa Brines

Work Plan 

Project Point Person Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW Discussion document (was 

presented at Fall 2011

meeting); Draft proposal In 

progress

Spring 2012

Aquaculture Materials 

Review Process

JFe & CW In progress Spring 2012?

Material Evaluation

Checklist

ZS? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Discussion document Spring 2012

Agenda: 

• Approve Minutes from March 22 

• Review and discuss:

o Extractants and Solvents Document/Jay

o Significant Residues in Classification of Materials Document/Jay

o Research Priorities Recommendation Document/Zea and Calvin

o Aquaculture Presentation/Jay 

• NOP update: Review status of outstanding petitions or technical reports. Lisa Brines, National List 

Manager

• Other Issues:

Two additional calls scheduled as necessary before April 02 deadline for proposals:

Wednesday/March 28 at 3:00-4:00pm and

Friday/March 30, Noon-1:00pm

 
Discussion:

Minutes from March 22 were reviewed and approved as received. 

Extractants/solvents discussion document

Sent final doc on extractants and solvents via email. Added language about supercritical CO2 with footnote. Also 

moved order of questions based on previous discussion. The discussion doc was voted on during last meeting, so 

would like to verify that this is acceptable prior to forwarding to NOP office. 

Significant residues in classification of materials discussion document

Changes were sent via email and the committee feels it’s a good solid document now. The committee is looking 

forward to getting some good input from public. Would like to see this move toward a proposal for the fall 

meeting. Prior to sending this to committee for review, two members had a conversation about the definition of 

“harm” which they found to be very productive and useful. The committee agreed that this document be on the 

Spring agenda but did not vote on it last meeting. Motion by JFe to submit this as a discussion doc for the Spring 

meeting. Seconded by Jennifer. All in favor. (5 yes, 0 opposed, 1 absent) 

Research priorities proposal document 

Draft was sent to committee but the text was not fleshed out. Edits and changes that other members suggested

were made. Comments with regard to the issue about region specific limits to fire blight? Question about 

preventing growth in areas with fire blight- not a question that can be answered with research. Member offered 

that they thought this proposal and this issue is very important and will add great value to the organic 

community. 

ZS moved to put this forth as a proposal. Seconded by CW. Yes: 5 No: 0 Abstain:0 Absent: 1 Recuse: 0 

This now provides the committee with three discussion docs for the Spring meeting, and one presentation about 

aquaculture. 

Aquaculture Presentation/JFe

Presentation will be oral and about 5 minutes long

Other Issues: NOP update (10)

All technical reports (TR) for Spring 2012 meeting have been posted on the NOP website, with the exception of 

pheromones.

NOP would like members to start thinking about Technical reports for Fall meeting. Will send out updated 

spreadsheet April 6, with reminders for outstanding items for Spring. 

Lingering questions about FePO4 (Ferric Phosphate) and updated TR. Does board need to put forth a formal 

request for new TR? Should Agricultural Research Service (ARS) do initial review before we send it out for new 

TR? NOP would like to figure out the path forward and get back to Crops Committee. 

ZS will send Research Priorities doc to members. 

Future calls:

March 28 (3pm EDT) –Extra meeting-cancelled

March 30 (noon – 1 EDT) –cancelled

April 10 (1pm EDT) 

April 24 (1pm EDT)

Milestone Deadline

Spring 2012 Agenda Finalized Friday, March 23, 2012

Committee Proposals Due Monday, April 2, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to 

or removal from the National List. They do not represent official National Organic Program (NOP) policy or 

regulations. Please see the NOP website for official NOP policy, regulations, and status of substances used in 

organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee Meeting Notes

Tuesday, April 10, 2012, 1:00 EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), John Foster (JFo), Calvin 

Walker (CW), Jay Feldman (JFe), Wendy Fulwider (WF)

National Organic Program (NOP) Staff: Michelle Arsenault and Lisa Brines

Work Plan 

Project Point Person Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW Discussion document (was 

presented at Fall 2011

meeting); Draft proposal In 

progress

Spring 2012

Aquaculture Materials 

Review Process

JFe & CW In progress Presentation Spring 2012

Material Evaluation

Checklist

ZS? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Discussion document Spring 2012

Agenda: 

• Approve Minutes from March 27 (sent 04 06 12)

• Review Extractants and Solvents Document (JFe)

• Review Significant Residues in Classification of Materials Document (JFe)

• Review Research Priorities Recommendation Document (ZS, CW)

• Discuss Aquaculture Presentation (JFe)

 

Preparation for Spring Meeting

• Identify needs for presentation

• Evaluation of comments

• Discussion and inter-committee communication

• Preparatory meetings on Monday May 21 

Discussion:

• Minutes from March 27 (sent 04 06 12) not reviewed yet. Will approve at a later date. 

• Extractants and Solvents Document for spring meeting (JFe). No additional comments or updates.
• Significant Residues in Classification of Materials Document (JFe). No additional comments or 

updates. Research Priorities Recommendation Document (ZS, CW). No additional comments

• Aquaculture Presentation at spring meeting (JFe). Intention is to summarize current status, and would 

like to enlist help from other committee members. Committee asked to clarify status of Technical Report 

(TR). NOP indicated that there was no request for TR for specific aquaculture petitions yet, so no 

contractor has been assigned. Presentation at meeting will include # of petitions pending, determination

for sufficiency, need for TR. A member requested that the Committee schedule a date for decision (for 

sufficiency) before board meeting. A streamlined TR would be useful in an effort to move things

forward. JFe is still looking for someone to address the committee about the aquaculture systems and 

how they work (i.e. open net systems vs. closed systems, etc.). 

• Chair asked if there were any needs for presentations at Spring Meeting. None. 

• With regard to evaluation of public comments Chair would like to find an effective way to review and 

respond.

• Inter-committee communication. ZS offered that if and when the Research Priorities doc gets passed it 

should be interfaced with the Policy Development Committee (PDC). How do we do this? Will talk about 

partitioning time at the meeting when the public comment period has closed and there’s a better idea 

of how many comments there are 

• Preparatory meeting on Monday May 21 at 6pm

Next Scheduled MC Calls 

• April 24 (1pm EDT) – Continue aquaculture discussion; review public comment received on MC 

documents for May meeting

• May 8 (1pm EDT) – Review public comment for NOSB meeting

Milestone Deadline

Public Comment Period April 9 - May 3, 2012

Informal prep meeting May 21, 6pm (in Albuquerque)

Spring 2012 NOSB Meeting

 

May 22 – 25, 2012
Note: Committee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Committee (MC) Meeting Notes

Tuesday, April 24, 2012, 1:00 EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), John Foster (JFo),

Jay Feldman (JFe), Wendy Fulwider (WF)

Absent: Calvin Walker (CW)

National Organic Program (NOP) Staff: Michelle Arsenault and Lisa Brines

Work Plan 

Project Point Person Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW Discussion document (was 

presented at Fall 2011

meeting); Draft proposal In 

progress

Spring 2012

Aquaculture Materials 

Review Process

JFe & CW In progress Presentation Spring 2012

Material Evaluation

Checklist

ZS? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Discussion document Spring 2012

Agenda: 

• Review minutes from last call (4/10/12)

• Review public comments

• Preparation for Spring Meeting

• Aquaculture (chlorine) Issues/Lisa Brines, NOP

Item 1 – Definitions

- Proposed text for draft guidance: In implementing the NOSB’s recommendation, the 

NOP does not see the need to amend the existing regulations by adding new definitions. 

Instead, the NOP has provided explanatory definitions within the guidance document to 

be used when needed. Some definitions that were provided in the NOSB Formal 

Recommendation of April 10, 2011 have been updated or amended within the draft 

guidance for clarity.

- Specific Changes:

- Chemical change (definition not in regs)

- NOSB/AWG Definition:
- Chemical Change. An occurrence whereby the identity of a substance is modified, such 

that the resulting substances possesses a different distinct identity (see related 

definition of “substance”)

- NOP Proposed Clarification:

- Chemical change. A process (i.e., chemical reaction) whereby a substance is transformed 

into one or more other distinct substances.

- Extract (definition not in regs)

- NOSB/AWG Definition:

- Extract. To separate, withdraw, or obtain one or more essential constituents of an 

organism, substance or mixture by use of solvents, mechanical or physical methods.

- NOP Proposed Clarification:

- Extract. To separate, withdraw, or obtain one or more [lb – “essential” deleted] 

constituents of an organism, substance, or mixture by use of solvents (dissolution), acidbase extraction, or mechanical or physical methods.

- Substance (definition not in regs)

- NOSB/AWG Definition:

- Substance. An element, molecular species, or chemical compound that possesses a 

distinct identity (For example, a distinct identity may be demonstrated through the 

material having a separate Chemical Abstract Service (CAS) number (in some cases the 

same material may have multiple CAS numbers), Codex International Numbering system 

(INS) number, or FDA or other agency standard of identity).

- NOP Proposed Clarification:

- Substance. A generic type of material, such as an element, molecular species, or 

chemical compound that possesses a distinct identity (e.g. having a separate Chemical 

Abstracts Service (CAS) number, Codex International Numbering System (INS) number, 

or FDA or other agency standard of identity).

 Item 2 – Substances not previously classified / not on Permitted Substance List

- Proposed text in guidance:

Substances which have not been previously classified by the NOSB at a public meeting, 

and which do not appear on the Permitted Substances List, NOP 50XX, may be 

petitioned to the NOSB for review. 

 Item 3 – Eligibility for organic certification

- Proposed text in guidance:

- This draft guidance does not determine the eligibility of a substance for organic 

certification.

- If a substance contains or is made up of agricultural ingredients, and can meet the USDA 

NOP organic production, handling, processing and labeling standards, it may be eligible 

to be certified under the NOP regulations.

• Related Issues 

• Meeting adjourned.
Discussion:

• Approval of minutes from 04/10/12 delayed until next meeting

• Review public comments. Deferred to next meeting until more comments are received

• Preparation for Spring Meeting-Chair asked if anyone had any questions about presentations or 

other topics. 

• Aquaculture Issues – It is proposed by NOP to have the Aquaculture petitions handled by the

Livestock Committee (LC), but this is open to discussion. Chair proposed that the MC continue 

addressing the Aquaculture issues for background. NOP believes livestock would be a better fit 

because MC does not have in its purview in the PPM the ability to vote on petitions. A member 

felt that the MC is better suited to review these petitions. NOP added that most of the petitions 

that have come in so far have pertained to LS issues. Environmental concerns, which are unique 

to this issue and have broader environmental context need to be addressed. A member asked 

about a joint approach? Members agreed that this would be a good approach. Several 

possibilities about how to move forward were suggested, including forming a joint committee 

with all members, or just letting committee members who are interested in participating join 

the LS calls. One member thought that moving it to the LS committee was a good idea, and 

having members choose to sit in on calls if they want, instead of forming a joint committee was 

a better idea. JFe would like to look back at history and scope of the aquaculture before making 

decision about whether or not to send it to LS. ZS suggested that Jay call Katrina. In terms of 

workplans, NOP would like to finalize them on next call.

• ZS - item: asked that each of the committees look at relevant GMO items be discussed and 

added to their workplans. 

JFe: Two discussion docs that that the Committee is working on are not on workplan for fall. 

Would like to discuss this with NOP so things don’t get delayed. NOP requested that MC 

compose questions. The questions revolve around the definition of the word “significant”. 

However, it may not be necessary to define the word if the process they use to determine it is 

effective. 

• Related Issues -none 

• Meeting adjourned

Next Scheduled MC Calls 

• April 24 (1pm EDT) – Continue aquaculture discussion; review public comment received on MC 

documents for May meeting

• May 8 (1pm EDT) – Review public comment for NOSB meeting

Milestone Deadline

Public Comment Period April 9 - May 3, 2012

Informal prep meeting May 21, 6pm (in Albuquerque)

Spring 2012 NOSB Meeting

 

May 22 – 25, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes

Tuesday, May 8, 2012, 1:00 EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), John Foster (JFo),

Jay Feldman (JFe), Wendy Fulwider (WF)

Absent: Calvin Walker (CW)

Staff: Michelle Arsenault and Lisa Brines

Work Plan 

Project Reviewer Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW Discussion document (was 

presented at Fall 2011

meeting); Draft proposal In 

progress

Spring 2012

Aquaculture Materials 

Review Process

JFe & CW In progress Presentation Spring 2012

Material Evaluation

Checklist

ZS? TBD

Materials classification ? TBD

Petition tracking JT / LB In progress Ongoing

Technical Report tracking JT / LB In progress Ongoing

Material Review – Process 

Improvement

? TBD

Extractants/solvents JF Discussion document Spring 2012

Significant residues JF Discussion document Spring 2012

Agenda: 

• Review minutes from April 24 meeting. 

• Approval or addition to minutes.

• Discussion of public comments

− Aquaculture Overview and Presentation

− Proposal - Research Priorities Framework (RFP)

− Discussion Document – Extractants and Solvents 

− Discussion Document – Significant residues and Classification of Materials/Jay

• Workplan/Development of Draft

− Issues of critical overview/Fall 2012 and spring 2013

− Proceed with Recommendations on two discussion documents/Fall 2012

− Other Ingredients, processing aids, etc. /Jay

− GMOs/Zea 

- Examine and Update Petitions/Technical Review Process 

- Examine CBI/Confidential Business Information transparency, etc.

- Known utilization of substance and Ion exchange chromatography or similar analysis 

 to examine substance/ residue
- Other Issues

• Definition Issues/Lisa Brines, NOP

 

• Spring Meeting Preparation Continues/Michelle Arsenault

- Updates

- Response to journalist/public

- PowerPoint 

 Discussion

• Minutes from April 24 meeting not reviewed or approved 

• Discussion of public comments

o Aquaculture Overview and Presentation-no document, will have a short update 

 presentation. Received comments from aquaculture working group.

o Research Priorities Framework Proposal - not many comments and those that have 

 been received are supportive

o Extractants and Solvents Discussion Document - comments reflect positions on 

 both sides. Discussion breaks down on substance vs process. General sense from 

community is 

 to slow down and let NOP resolve some work before NOSB pushes forward with these 

 documents. 

o Significant residues and Classification of Materials Discussion Document- Piece of 

unfinished business that needs to be resolved. The committee agrees that it is valuable 

to have input and feedback. A member offered that perhaps the NOSB needs to slow 

down from time to time and let NOP respond. JFe asked that NOP weigh in on scope of 

guidance docs with regard to specific issues listed in doc and timeframe. Committee 

would like to add placeholder on workplan for these two issues once the NOSB meeting 

concludes.

• Workplan/Development of Draft

o Issues of critical overview/Fall 2012 and spring 2013

o Proceed with Recommendations on two discussion documents/Fall 2012

o Other Ingredients, processing aids, etc.

o GMOs and MCs role with regard to GMOs. Intention was for all the committees to 

interface with GMO committee. Appropriate topics for MC to consider include: 

Excluded methods, cell fusion, etc. Committee would like to clarify definition of terms 

within excluded methods clause. After RPF is passed, there is a lot of research that 

needs to be done about GMO contamination. LB asked if a TR would be required when it 

comes to reviewing definitions. ZS indicated that it probably would not, and is going to 

solicit comments from plant breeding group that is very knowledgeable about such 

things. 

o Examine and Update Petitions/Technical Review Process- Look at process in PPM in 

conjunction with PDC to streamline process for submitting petitions. 

o Examine CBI/Confidential Business Information transparency, etc. –unclear in guidelines 

in PPM. Who is receiving information and what happens to it? MC could look at 

usefulness of this. Committee member noted that they don’t feel comfortable voting on 

something when the CBI info is redacted. A member asked if the petitioner was aware 
that the NOSB will not, or are not required to, vote on something if the information is 

not complete. MC would work with PDC to get updates into manual. 

o Known utilization of substance and Ion exchange chromatography or similar analysis 

to examine substance/residue – Perennial issue. (Techniques used for separation of 

products). Would this technique be allowed and is this a topic that should be discussed 

at NOSB meeting? A member asked if this issue has been settled or not, citing a past 

material that was rejected because it was subjected to this process. Committee feels 

we would need a TR.

o Other Issues – ZS clarified that the research priorities should be included in the fall

workplan.

 

• Definition Issues/Lisa Brines. NOP will have a couple of slides at NOSB meeting about this issue. 

• MA updated group on Spring meeting preparation 

Response to journalist’s inquiries – Guidance was sent to NOSB from Soo Kim about conducting 

interviews. 

Meeting adjourned.

 

Next Scheduled MC Calls 

June 12 1pm EDT

June 26 1pm EDT

Milestone Deadline

Fall proposals due August 20, 2012

Fall 2012 NOSB Meeting

 

October 16-19, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, June 12, 2012, 1:00 EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), Jay Feldman (JFe), 

Absent: John Foster (JFo), Wendy Fulwider (WF), Calvin Walker (CW)

Staff: Michelle Arsenault (MA) and Lisa Brines (LB)

Work Plan 

Project Reviewer Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW Discussion document 

presented at Fall 2011 meeting; 

Draft proposal In progress

fall 2012

Examine Confidential 

Business Information (CBI) 

Transparency

JFe Discussion doc, jointly w/PDS

(JFe)

fall 2012

Update petition/TR 

process

Jointly with PDS TBD

Ion Exchange Resins Waiting for NOP background 

information. Discussion 

document. 

spring 2013

Petition and TR tracking JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Agenda: 

• Review minutes from April 10, 24, and May 08, 2012

• Discussion of 2012 NOSB Spring Meeting

• Public Comments

• Discussion of Draft Workplan 

o Workplan clarification requested on following:

• Materials Subcommittee (MS): Identifying what GE means to the public, Successful aquaculture

• New Issues/Biodiversity

• Report from Michelle Arsenault/ABS

• Additional report from NOP

• Meeting adjourned.

 

 Discussion

• Approval of minutes from April 10, 24, and May 08, 2012 deferred until June 26th, due to lack of 

quorum

• Discussion of 2012 NOSB Spring Meeting - no new discussion
• Public comments – There was a general sense that the public would like the subcommittee to 

work more quickly on various items. 

• Discussion of Draft Workplan

o Materials Working Group (WG) is ad hoc and is comprised of anyone who wants to join, 

including past members, members from Organic Materials Review Institute (OMRI) and 

National Organic Coalition (NOC). Currently there are about 20 people participating. It is 

intended as a vehicle for group to give input on materials classifications that have been 

delayed, i.e. “other ingredients” in food (which is on the Handling Subcommittees 

workplan). ZS indicated to NOP (MM) that the group had been reconvened in order to 

look at specific issues. NOP had questions about how working group would function, 

since it is organized outside the NOP and NOSB process. ZS asked for input from others 

so she could begin a discussion doc. Would like to invite JFo to participate. The WG 

already had one ‘framework’ call and has one scheduled for this afternoon. Group will 

meet every other week between now and August. ZS indicated that the WG would like 

to engage experts who have knowledge of these topics. JFe would like to stay in touch 

with this group and will try to participate. 

o JFe – There are two discussion docs (one on extractants and solvents, and one on 

residues) that are being addressed by NOP proposed guidance on materials 

classification. Would like to create similar doc to compare to the draft guidance to make 

sure the issues are being addressed. There seemed to be categories that were raised by 

the Subcommittee that were not included in the draft guidance and wanted to make 

sure there are no gaps. Feels that NOP is making determinations on material without 

applying the policy that the NOSB voted on. There is no precedent for this. Would like 

more clarity about “functional and technical affects”, if this is the terminology being 

substituted for “significant”. NOP indicated that this will not be policy but instead be 

draft guidance that will be available for public comment, and thinks that this issue can 

move forward without additional work on these proposals from the MC subcommittee. 

o Clarification requested on following workplan items: 

- Ion Exchange Resins- NOP will send background guidance before MS should start on 

this. Due to timing, this may be delayed until the spring 2013 meeting.

- Confidential Business Information. Several questions were raised including: to what 

degree should the NOSB be involved in creating a CBI/disc/COI policy? Can reviewers 

look at all ingredients that are considered proprietary? What can or can’t they disclose. 

Discussion on whether this overlaps with technical report (TR) disclosure/COI policy. 

This workplan item is separate – only addresses CBI that is submitted by the petitioner.

- ZS indicated that this would be a good opportunity for the NOSB to call for a TAP 

process that uses panels of technical experts.. Will determine at a later date who will 

take the lead (JFe?).

- GMO ad hoc will interface with Materials to look at definition of excluded methods. The 

main question is how far back in chain do you look when determining GMO. ZS will 

reference OMRI GMO decision tree as example. Not sure that this will result in anything

for the fall agenda, but would like to keep it as a place holder on agenda for now. 

- JFe (Crops) and CW (LS) need to determine research priorities for MS. ZS asked that they

assemble a list by the end of July which will be shortened to focus on most important 

research topics to be addressed. JT - GMO Vaccines issue? This will be addressed 

through the Livestock Subcommittee for now.
• Identifying what GE means to the public. These topics keep coming up in public comments, so 

would like to address this, but don’t intend on creating a discussion doc or proposal. Is there a 

need to examine organic integrity with regard to materials? At this time, the GMO ad hoc 

Subcommittee will be addressing GMO issues.

• Successful aquaculture. 

- Would like to appoint liaison to Livestock Subcommittee (CW) and Crops (JFe or ZS) to 

keep the Materials Subcommittee updated on the review of aquaculture petitions

• New Issues/Biodiversity

- Unclear as to whether or not this is something the MS would like or need to address. JT 

feels that the MS should look at broad overview of Biodiversity. It was noted that a 

previous joint subcommittee between CACC and Crops created a document and there 

are outstanding recommendations from NOSB. NOP (LB) feels that this item does not 

need to be added to the MS’s workplan at this time. ZS indicated that this sounds like an 

accreditation issue and not one for the NOSB. 

• ABS – update on status of minutes (posted on web) and recommendations from NOSB May 2012 

meeting (to be posted soon)

• Additional report from NOP (LB). There are lots of new petitions to be distributed to MC and 

some TRs should be returned soon. 

• Meeting adjourned.

Future Scheduled Subcommittee Calls:

June 26, 2012 1pm EDT

July 10, 2012 1pm EDT

July 24, 2012 1pm EDT

August 14, 2012 1pm EDT

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, July 10, 2012, 1:00 EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), Wendy Fulwider 

(WF), Calvin Walker (CW)

Absent: Lisa Brines (LB), John Foster (JFo), Jay Feldman (JFe)

Staff: Michelle Arsenault (MA) and Melissa Bailey (MB) 

Work Plan 

Project Reviewer Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW

& JFe

Discussion document 

presented at Fall 2011 meeting; 

Draft proposal in progress

fall 2012

Confidential Business 

Information (CBI) 

Transparency

JFe Discussion doc, jointly w/PDS

(JFe)

spring 2013

Update petition process Jointly with PDS. MS will lead. TBD

Ion Exchange Resins Waiting for NOP background 

information. Discussion 

document. 

spring 2013

Petition and TR tracking JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation policy –

NOP has proposed that 

this be renamed 

(Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/Materials? Could this be 

integrated within “Update 

Petition Process” item below? 

TBD

Agenda: 

• Review minutes from April 10, 24, May 08 and June 12, 2012

• Discussion documents - further processing

o Extractants and Solvents

o Significant Residues

• Develop and implement framework for NOSB Research Priorities.

o Identify research priorities procedure and issues. Calvin and Jay

• GMOs 

• Examine and update petitions/technical review process – joint PDS. 

• Examine Confidential Business Information Transparency – joint with PDS 

• Examine ion exchange resins and impact/ NOP wants to provide additional information before 

 we proceed with this item. 

• Additional items
• Discuss next call dates.

 

 

Discussion

• Minutes from April 10, 24, May 08, and June 12 approved. 

• Discussion documents - further processing

o Extractants and Solvents, Significant Residues

o NOP indicated that neither of these items is on the workplan so they are not on the 

agenda for fall meeting. During the last Materials call, JFe indicated that he wanted to

do a side by side comparison with the pending draft guidance, but the NOP feels that it

would be more productive for the subcommittee to comment after the draft guidance is 

released.

• Develop and implement framework for NOSB Research Priorities.

o ZS is working on this in conjunction with subcommittee representatives CW (LS) and JFe

(Crops)

• GMOs 

o GMO ad hoc subcommittee does not have any joint work in progress with the MS but 

may have in the future. JT would like to work on GM issues as they relate to materials. 

MB stated this is not on the workplan and is not sure what this topic would be. 

o MB indicated that GMO ad hoc Subcommittee is initiating projects and would involve 

other subcommittee as needed. ZS asked that the chair draft a document to clarify what 

she is proposing.

• Examine and update petitions/technical review process – joint PDS. 

o 2-stage TR policy-conversation deferred until next meeting to have JFe’s input. 

• Examine Confidential Business Information (CBI) Transparency – joint with PDS. 

o Currently the CBI that gets submitted with petition is filed and does not get sent to 

NOSB. The discussion included questions about the usefulness of collecting this 

information, and what is communicated to petitioners who are submitting CBI along 

with the petitions. A member noted that they would be unlikely to vote for a material if 

the CBI is not disclosed. The subcommittee would like additional information from NOP 

on how the NOSB would provide feedback. MB suggested this could be part of updating 

the petition guidelines and that LB could provide additional context. 

• Ion exchange resins and impact. NOP will provide additional information before 

 MS proceeds with this item. 

• No additional items

• Next call dates were not discussed due to lack of time. 

Future Scheduled Subcommittee Calls:

July 10, 2012 1pm EDT

July 24, 2012 1pm EDT

August 14, 2012 1pm EDT

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT
September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” tentative agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, July 24, 2012, 1:00 EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), Wendy Fulwider 

(WF), Calvin Walker (CW), John Foster (JFo), Jay Feldman (JFe)

Absent:

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW

& JFe

Discussion document 

presented at Fall 2011 meeting; 

Draft proposal in progress

Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe Discussion doc, jointly w/PDS

(JFe)

Spring 2013

Update petition process Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Spring 2013

Petition and TR tracking JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation policy –

NOP has proposed that 

this be renamed 

(Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. Could this be 

integrated within “Update 

Petition Process” item? 

Fall 2012?

Agenda: 

• Approve minutes from July 10 call

• Research Priorities Framework/Process

• Report current research topics and background information from public and NOSB 

subcommittees/Jay, Calvin, Zea

• Examine and update petitions/technical review process- joint with PDC/Jay (Fall 2012)

• Examine Confidential Business Information Transparency- joint with PDC. Requested additional 

information from NOP. (Spring 2013)

• Examine ion exchange resins and impact: NOP wants to provide additional information before 

we proceed with this item. No additional information provided as of yet. (Spring 2013)

• GMO Ad hoc Subcommittee update/Zea

• Program update and discussion/Lisa Brines 

• Extractants and Solvents
• Significant Residues

• Remarks and clarifications/Materials 

• New items

• Next call

Discussion

• Minutes from July 10 approved with no changes. 

• Research Priorities Proposal Document – Materials is soliciting topics from other 

Subcommittees. NOP encouraged the members to solidify lists/questions in order to move the 

process forward

• Update petitions/technical review (2-stage) process - joint with PDC/Jay (Fall 2012?). NOP has 

indicated that they would like the PDS to work on a proposal instead of a discussion doc. Now 

that PDS has worked on this, perhaps the MS would like to move forward. Chair asked for 

clarification about how the MS could continue this project, and NOP suggested looking at the 

bigger picture with regard to TRs. The 2-stage process will fall under that and may be revised 

along the way. The chair asked that the two subcommittees coordinate as this has not occurred 

yet. A member asked about the provenance of the checklist, and how the NOP uses it. NOP 

provided clarification about using the checklists for eligibility and petition sufficiency.

Confidential Business Information Transparency- joint with PDS. MS requested additional 

information from NOP, which will forward the CBI section of petition guidelines. It is unclear in 

petition guidelines about what happens to the CBI, so petitioners do not necessarily know that 

it’s not being sent to the NOSB, and that perhaps this is an obstacle to getting the substance 

approved. LB noted that there’s an issue with deliberation at the NOSB meetings since decisions 

need to be transparent and CBI cannot be disclosed to the public. 

• GMO ad hoc Subcommittee update - working on several items: Seed Purity, decision tree 

structures, policy and other standards with regard to how far back in chain we are looking. 

Envisions a 5-year plan for the GMO ad hoc Subcommittee and another member asked about 

potentially converting this to a standing Subcommittee. 

• Ion exchange resins- still waiting for NOP to provide more info. NOP doesn’t expect to get 

started on this until fall or after. 

• Significant residues/Extractants and Solvents - Draft guidance on classification is in progress (LB) 

with the intention to put into clearance this summer. Classification guidance will be available for 

public comment. NOP will provide group more info if plans change. 

• JFe would like to start discussion about production aids: what they are and how they are 

defined. 

Future Scheduled Subcommittee Calls:

August 14, 2012 1pm EDT

• Discuss/Vote: Research Priorities Proposal Document

• Discuss: Update petition process

• Discuss: CBI Process and Policies

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 
Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, August 7, 2012, 4:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Calvin Walker (CW), Jay Feldman (JFe), 

Absent: Zea Sonnabend (Vice-chairperson) (ZS), John Foster (JFo), Wendy Fulwider (WF)-call 

dropped/couldn’t gain access. 

Sitting in: Mac Stone (MS), Colehour Bondera (CBo)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW

& JFe

Discussion document 

presented at Fall 2011 meeting; 

Draft proposal in progress

Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe Discussion doc, jointly w/PDS

(JFe)

Spring 2013

Update petition process Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Spring 2013

Petition and TR tracking JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation policy –

NOP has proposed that 

this be renamed 

(Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. Could this be 

integrated within “Update 

Petition Process” item? 

TBD

Agenda: 

• Approve minutes from July 24, 2012 call.

• Discuss the research needs/issues, questions that have been discussed in-committee and those 

collected thus far.

Discussion:

• Minutes from July 24, 2012 call not approved due to lack of quorum

• Research ideas discussed by Subcommittee

• Livestock: methionine and herbal methionine

• Crops: Copper sulfate, antibiotics, quality of organic over conventional
• PDS: PDS has not discussed research topics since it is not directly relevant to this Subcommittee. 

The Materials group feels that the PDS could take on some issues about process, but it’s not 

certain that this is the best use of their time. 

• Chair asked if the Research Priority Framework should be included in the PPM so that it can be 

utilized by future Boards. CBo added that it should at least be mentioned in the PPM. A member 

asked if the NOSB would need a form letter in an effort to communicate to different agencies or 

communities. LB indicated that the NOP would communicate the information as stated in the 

Framework Document and felt that the Subcommittee does not need to create a form letter

document.

• Still need to get lists from the following subcommittees: GMO ad hoc, CACS, and Handling. Chair 

asked if the other members could relay this information and ask them to email their lists.

• LB reminded the group that this topic is scheduled to be voted on Tuesday, August 14, 2012.

Future Scheduled Subcommittee Calls:

August 9, 2012 1pm EDT extra call

August 14, 2012 1pm EDT

• Discuss/Vote: Research Priorities Proposal Document

• Discuss: Update petition process

• Discuss: CBI Process and Policies

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, August 9, 2012, 1:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Calvin Walker (CW), Zea Sonnabend (Vice-chairperson) 

(ZS), John Foster (JFo) 

Absent: Jay Feldman (JFe), Wendy Fulwider (WF)

Sitting in: Colehour Bondera (CBo)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Target Meeting 

Research Priorities

Proposal Document

ZS & CW

& JFe

Discussion document 

presented at Fall 2011 meeting; 

Draft proposal in progress

Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe Discussion doc, jointly w/PDS

(JFe)

Spring 2013

Update petition process Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Spring 2013

Petition and TR tracking JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation policy –

NOP has proposed that 

this be renamed 

(Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. Could this be 

integrated within “Update 

Petition Process” item? 

TBD

Agenda: 

• Approve minutes from July 24 call

• Discuss the research needs/issues, questions that have been discussed in-committee and those 

collected thus far.

Discussion:

• Minutes from July 24 call not approved. 

• Livestock: Seven research topics in preliminary discussion, including methionine, non-plant 

materials, parasitism, aquaculture (open v closed), mastitis. CBo added that the group spoke 

briefly about prioritizing the items but have not discussed them in depth yet. ZS asked that they 

include a few bullet points for each research topic to focus the research. 
• Handling: 

o Research areas of interest include: Tools to assess commercial availability; available tools to 

assess suitability of alternatives to sunsetting or petitioned materials; How to develop 

markets for organic alternatives to 605 and 606 substances; Health value and essentiality of 

accessory nutrients (e.g. ARA, DHA, inositol, choline, etc.); Silicon Dioxide (Subcommittee 

decided not to do this one); Sulfur Dioxide in wine (Subcommittee decided not to do this 

one); 

o Research areas of interest with respect to Carrageenan include: 

* Can Carrageenan be produced using methods that are non-synthetic and can those 

 methods be used for all the types of carrageenan?

* Does the gel formed by carrageenan when it is used in food provoke an inflammation 

 response? Injected or in vitro studies allegedly cannot be compared to feeding studies 

 because the carrageenan has formed a gel that is more resistant to degradation in food.

* Is there replicated proof that carrageenan breaks down into smaller molecular weight 

 forms in digestion and that these forms are small enough and populous enough to pose a 

 health concern?

* Allergic and toxicological responses to carrageenan are so far primarily anecdotal. Can 

 there be further research done to quantify how widespread and truthful these claims are?

* Are there viable alternatives to carrageenan and if so, for what uses?

* What are the ecological impacts of seaweed cultivation and harvest in species used for 

 Carrageenan?

ZS asked that Handling provide specific questions that will serve to focus the research. JFo 

will send this doc to the Handling Subcommittee members and solicit specific questions 

under each of the broad topics. 

• Crops: Group will discuss Research Topics on next call. Perhaps might need extra call to take 

vote on this. 

Future Scheduled Subcommittee Calls:

August 14, 2012 1pm EDT

• Discuss/Vote: Research Priorities Proposal Document

• Discuss: Update petition process

• Discuss: CBI Process and Policies

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline
NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, August 14, 2012, 1:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Calvin Walker (CW), Zea Sonnabend (Vice-chairperson) 

(ZS), Jay Feldman (JFe), Wendy Fulwider (WF)

Absent: John Foster (JFo)

Sitting in: Colehour Bondera (CBo), Barry Flamm (CBo)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan - Subject to change

Project Reviewer Status VOTE Target Meeting 

Research Priorities 

Proposal Document

ZS & CW

& JFe

Discussion document presented 

at Fall 2011 meeting; Draft 

proposal in progress 

Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe Discussion doc, jointly w/PDS 

(JFe)

Spring 2013

Update petition 

process

Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Spring 2013

Petition and TR 

tracking

JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. Could this be integrated 

within “Update Petition 

Process” item? 

TBD

Agenda: 

• Approve minutes from July 24 call

• Research Priorities Framework/Process.

o Research topics/questions - updated information from chairs

o Materials review and discussion

o Summary and list formation/top priorities

o Development of key questions about each topic

o Recommendation may include preliminary list of entities involved in

o Research and evaluation of funding opportunities, collaboration, endorsements. 

• Program update: Michelle or Lisa

• Additional Materials call scheduled for Friday August 17, 2012, 1:00pm.
• Discuss the research needs/issues, questions that have been discussed in-committee and those 

collected thus far.

Discussion:

• Minutes from July 24 call not ready for approval yet. Will approve on next call.

• Research topics/questions: Group discussed various aspects about research topics and 

narrowing scope of the research questions.

o LS: GMO vaccines research questions need to be more specific. Chair would like a 

completed document by tomorrow so the MS can finalize this on Friday. 

o CS: copper sulfate, antibiotics, whole farms system research. JFe and ZS would like to 

move forward with the Research Priorities for Crops Subcommittee. ZS will edit some 

language from a paragraph to question format and send it out before the next CS call. 

o HS: JFo sent Handling Research Priorities but it was unclear whether or not updates and 

edits were made. Chair asked that HS make edits (if they haven’t been done yet) and 

have them prepared for next call. 

o CACS has not discussed any research priorities. 

o ZS is working on preamble for the Research Priorities document. 

o A member asked that the MS chair send out an email reminder that the Research 

Priorities docs are due ASAP. 

• Research and evaluation of funding opportunities, collaboration, endorsements. Chair asked for 

feedback about implementing this portion of the process. NOP has committed to making this 

available to other agencies, as well as publishing this online. BF supports this endeavor. Chair 

asked that finalized docs be sent to her by tomorrow.

Future Scheduled Subcommittee Calls:

August 14, 2012 1pm EDT

• Discuss/Vote: Research Priorities Proposal Document

• Discuss: Update petition process

• Discuss: CBI Process and Policies

August 17, 2012 1pm EDT extra call

Vote on Research priorities proposal. 

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012
Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, August 17, 2012, 1:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) Calvin Walker (CW), 

(ZS), Wendy Fulwider (WF)

Absent: Jay Feldman (JFe), John Foster (JFo)

Sitting in: Colehour Bondera (CBo)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Vote Target Meeting 

Research Priorities 

Proposal Document

ZS & CW

& JFe

Discussion document presented 

at Fall 2011 meeting; Draft 

proposal in progress 

08 17 12 Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe Discussion doc, jointly w/PDS 

(JFe)

Spring 2013

Update petition 

process

Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Spring 2013

Petition and TR 

tracking

JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. Could this be integrated 

within “Update Petition 

Process” item? 

TBD

Agenda: 

• Approve minutes from July 24, 2012

• Vote on Research Priorities Framework/Process

Discussion:

• Minutes from July 24, 2012 not approved during the call. 

• The Materials Chair thanked the group for the extra effort they put forth to get the Research 

Priorities submitted. ZS asked that the Subcommittees narrow the list to approximately 3 per 

Subcommittee for this first submission. 

• Livestock priorities top 3: GMO vaccines, methionine alternatives, and organic aquaculture. 

Additional priorities: parasitism, mastitis, herd health, pneumonia and plant extracts. Group 

agreed to concentrate on short list for now, and add items as it progresses. 
o NOP asked for clarification about organic aquaculture. Suggestion to delete text which is 

not specific to a research priority, specifically statement on whether materials already 

approved by NOSB for organic plant, animal, and handling should be automatically 

approved for organic aquaculture systems. CW will edit and send to JT, who will work 

with ZS to finalize proposal

• Crops: “Whole farm systems research” includes 3 topics and research questions. Didn’t identify 

other issues beyond the 3, but expect more in the coming months. 

• Handling priorities: The group discussed the items that were sent for a prior meeting. 

Carrageenan is one priority, and so far this is the only item that the group has had a chance to 

discuss so they would like to put forth the one and add the others later. Other questions will be 

flushed out in the coming months.

• Research Priorities introduction: ZS wrote intro and left place holders for the Subcommittee’s 

topics. 

Vote on Research Priorities

Motion to adopt the proposal on NOSB Research Priorities.

Motion by: ZS 

Second: CW

No Additional Discussion

Yes: 4 No: 0 Absent: 2 Abstain: 0 Recuse: 0

Future Scheduled Subcommittee Calls:

August 17, 2012 1pm EDT extra call

Vote on Research priorities proposal. 

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, August 28, 2012, 1:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), Wendy Fulwider 

(WF), Jay Feldman (JFe) 

Absent: Calvin Walker (CW), John Foster (JFo)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Vote Target Meeting 

Research Priorities 

Proposal Document

ZS & CW

& JFe

Discussion document presented 

at Fall 2011 meeting; Draft 

proposal in progress 

08 17 12 Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and JT 

Discussion doc?, jointly w/PDS 

(JFe)

Spring 2013

Update petition 

process

JFe Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Spring 2013

Petition and TR 

tracking

JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. Could this be integrated 

within “Update Petition 

Process” item? 

TBD

Agenda: 

• Minutes from July 24, August 14, August 7, August 9, and August 17 need to be approved

• Discuss Research Priorities and update

• Review and identify additional list of primary organic research funders/funding opportunities, 

interest groups, etc. 

• Review work plan

• New items and priorities

• Program report/ Lisa Brines

• Materials discussion

Discussion:

• Minutes from July 24, August 14, August 7, August 9, and August 17 not approved as yet.
• Group discussed additions to the list of primary organic research funders/funding opportunities, 

interest groups, etc. CW volunteered to follow up with various agencies about proposal cycles 

and engaging in capacity building with them. LB commented on a possible mechanism by which 

NOP would disseminate the information about organically-focused research proposals. The 

group also discussed the previous NOP letter to ARS on a research priority issue (May 2011): 

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5091325

• Work plan and assimilation of research plan. The group discussed various workplan items (CBI, 

Update of petition process, and Ion Exchange Resins) and the target meeting dates for 

presentation of those items. It was noted that the PDS is working on updates to PPM, which are 

cross cutting to the Materials Subcommittee, making the process more transparent for the 

public. NOP and the MS clarified that the Subcommittee’s intention was to make individual 

determinations of which materials will need the abbreviated-TR, and not to request one for 

every material. 

• Possible new items for the MS workplan: definition of production aids (clarity and definitions), 

and vitamins and minerals. The group discussed a question on the checklist about adverse 

effects of production of materials, and the fact that the question about how NOSB uses scientific

data has a degree of uncertainty. JFe asked what the path forward is with regard to these new 

items. The Chair encouraged people to think about, and list, what items they would like to 

discuss further. 

• The GMO ad hoc will work jointly with materials to work on definitions relating to GMO topics: 

cell fusion, mutagenesis, microencapsulation etc. 

Future Scheduled Subcommittee Calls:

August 17, 2012 1pm EDT extra call

Vote on Research priorities proposal. 

August 28, 2012 1pm EDT

September 11, 2012 1pm EDT

September 25, 2012 1pm EDT

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, September 25, 2012, 1:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), Wendy Fulwider 

(WF), Jay Feldman (JFe), Calvin Walker (CW), John Foster (JFo)

Absent: 

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Vote Target Meeting 

Research Priorities 

Proposal Document

ZS & CW

& JFe

Discussion document presented 

at Fall 2011 meeting; Draft 

proposal in progress 

08 17 12 Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and JT 

Discussion doc, jointly w/PDS 

(JFe)

Spring 2013

Update petition 

process

JFe Jointly w/PDS. Mac Stone will 

lead.

Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Fall 2013

Petition and TR 

tracking

JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. 

TBD

Extractants JFe? Fall 2013?

2-stage TR process

Production aids Spring 2013

Agenda: 

• Approve notes from August 28th call

• Possible workplan Items: 

o Impact of extractants, spring 2013.

o Classification of materials (in absence of NOP decision), spring 2013.

o 2-stage TR (with PDS), spring 2013.
o Examine and update petition, technical review process, spring 2013.

o Definition of production aids, Spring 2013

o Checklist evaluation/adverse effects of production materials, on health, environment, 

etc. Fall 2013

o How to address scientific uncertainty, spring 2013.

o Confidential Business Information Transparency and Process, Spring 2013.

o GMO contamination impact, spring 2013.

o Examination of ion exchange chromatography and impact, fall 2013.

o Continued data collection of research concerns, topics from subcommittees and 

organic public, etc. Evaluate the dissemination of information and feedback from 

identified research agencies and grassroots organizations, etc. Fall 2013.

• New Items/issues for 2013/2014 workplan

• NOP report/LB

• Materials Discussion

Meeting adjourned.

Discussion:

• Notes from August 28th not approved yet.

• The Chair would like summaries of workplan items by COB today 

o Impact of extractants, spring 2013. Follow up to public comments received this past 

spring. The Subcommittee would like to create a consistent standard by which these 

items are evaluated which would help make the work of the NOSB more efficient. A 

member stated that it would be preferable to wait until the classification of materials 

doc by the NOP is released, although it is unclear when this document will be released. 

LB asked that the Subcommittee explain the focus of the proposed work and describe

the intent of this workplan item. The NOP suggested delaying this item until fall 2013, 

with the hope that the guidance will be out by then. 

o Classification of materials (in absence of NOP decision), spring 2013. The discussion was 

similar to the Extractants discussion. 

o 2-stage TR (with PDS), spring 2013. The intent is to streamline the process of technical 

review to save time and money. The group discussed the potential savings, the impact 

on the TR contractors and continuity of review. A member asked for clarification about 

which subcommittee is taking the lead...PDS or Materials, as this is a joint project. 

Criteria for compatibility and essentiality are vague and this “filter” should be part of the 

discussion. Natural/synthetic determination is also key and a member feels this should 

be primary. 

o Examine and update petition, technical review process, spring 2013.

o Definition of production aids, spring 2013. There are parameters built in the statute, but 

a member felt that there needs to be more clarity 

o Checklist evaluation/adverse effects of production materials, on health, environment, 

etc. fall 2013

o How to address scientific uncertainty, spring 2013. The group would like to see guidance 

in PPM about how to address this uncertainty. A member feels added that this might be 

too complex a topic for the group to address and NOP asked that something be written 

for distribution. 
o Confidential Business Information Transparency and Process, spring 2013. Work will be 

done in conjunction with PDS. ZS is taking lead. The NOP Deputy Administrator will 

clarify what is expected of petitioners and NOP. 

o GMO contamination impact, spring 2013. The intent is to look at methods of GMO 

prevention strategies. This is a project that would be joint with the GMO ad hoc

Subcommittee. 

o Examination of ion exchange chromatography and impact, changed from spring 2013 to 

fall 2013 in table above. 

o Continued data collection of research concerns, topics from subcommittees and 

organic public, etc. Evaluate the dissemination of information and feedback from 

identified research agencies and grassroots organizations, etc. Fall 2013. 

• ZS added that during the Expo East conference she spoke with Mark Lipson and Dr. Peet (NIFA) 

about the research priorities document and he will send guidance about a format which is more 

relevant for agencies. 

Future Scheduled Subcommittee Calls:

October 9, 2012 1pm EDT 

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, October 09, 2012, 1:00 pm EDT 

Attending: Jennifer Taylor (Chairperson) (JT), Zea Sonnabend (Vice-chairperson) (ZS), Calvin Walker 

(CW), John Foster (JFo), Wendy Fulwider (WF), Jay Feldman (JFe)

Absent: 

Staff: Michelle Arsenault (MA), Lisa Brines (LB), Mark Lipson (ML) (OSEC)

Work Plan 

Project Reviewer Status Vote Target Meeting 

Research Priorities 

Proposal Document

ZS & CW

& JFe

Discussion document presented 

at Fall 2011 meeting; Draft 

proposal in progress 

08 17 12 Fall 2012

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and JT 

Discussion doc, jointly w/PDS 

(JFe)

Spring 2013

Update petition 

process

JFe Jointly w/PDS. MS will lead. Spring 2013

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

Fall 2013

Petition and TR 

tracking

JT/LB Ongoing N/A

Material Evaluation 

Checklist

ZS? TBD

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Discussion Document - JOINT

w/PDS. 

TBD

Extractants JFe? Fall 2013?

2-stage TR process

production aids Spring 2013

Agenda: 

• Approve notes from August 28th call

• Review research Priorities Presentation, and correct format for dissemination of document to 

agencies 

• Comments

o Public comment from FMC (Chemical Company)
• Discuss proposed workplan items

• New Items for workplan?

• Program Report/L Brines

Discussion:

• Notes from the August 28 call were not approved. Will approve them on next call after fall 

meeting (November 13)

• The group discussed the research priorities format and the best way to disseminate it to the 

agencies. ML indicated that the criteria don’t seem to have a connection to the items listed in 

the research priorities doc. For example, there’s background for some items, and not for others. 

It seems it would be more useful if the format was systematic and structured. ZS added that the 

lack of ranking was intentional due to the varied nature of the Subcommittees’ work. NOP is 

asking for more structure, and without a ranking it might not get the support from the agencies. 

JT asked that ZS and CW give an overview of this document at the fall meeting. ZS will prepare 

some slides and CW will talk about the public comments and feedback. Also, each 

Subcommittee may be asked to add any feedback about research priorities. 

• The Carrageenan document will need to be updated at the meeting, with the addition of the 

following language: “What are the ecological impacts of seaweed harvest in seaweed for 

carrageenan”. (See August 9th notes)

• The Subcommittee would like the FMC comments posted prior to the meeting. 

• Workplans: Various items on the workplan were discussed, based on NOP feedback. 

• The Chair asked if there were any additional items for WP and asked about adding items at the 

fall meeting. MA will find out. 

• JFe asked about the Sept 12 aquaculture memo and whether or not a material for terrestrial 

plant use should be allowed for aquatic plant use. NOP is looking at the information in the 

memo to see if clarification is needed. 

Future Scheduled Subcommittee Calls:

October 23, 2012 1pm EDT - cancelled

November 13, 2012 1pm EST

November 27, 2012 1pm EST

December 11, 2012 1pm EST 

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, November 13, 2012, 1:00 pm EST 

Attending: Jennifer Taylor (2012 Chair, 2013 Vice Chair) (JT), Zea Sonnabend (2012 Vice Chair, 2013 

Chair) (ZS), Jay Feldman (JFe), Joe Dickson (JD), John Foster (JFo) (2012 member), Calvin Walker (CW), 

Mac Stone (MS)

Absent: Wendy Fulwider (WF), Tracy Favre (TF) 

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work Plan 

Project Reviewer Status Vote Target Meeting 

Examine and update 

petition and technical 

review process

JFe Jointly w/PDS (Materials will 

lead). JFe (Materials)/MS (PDS)

Spr 2013

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and CW 

Discussion doc, jointly w/PDS 

(JFe) in Spring? Prop in fall? 

Spr 2013/Fall 

2013?

Definition of 

production aids

Spr 2013

Research Priorities 

Proposal 

ZS & CW 

& JFe

Fall 2013

Petition and TR 

tracking

ZS/LB Ongoing N/A

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Joint w/PDS (PDS will lead) TBD

How to address 

scientific uncertainty

JFe Will begin this after “Update 

Petition Process and CBI 

projects” are complete

TBD

Ion Exchange Resins Waiting for NOP background 

information in late fall. 

Discussion document. 

TBD

Agenda: 

• Approve notes from the August 28 call, September 25, and October 10

• Future deadlines and call schedule (MA)

• Petition for polyalkylene glycol monobutyl ether (PGME); processing aid for livestock feed (LB)

• Workplan scrutiny to assign/confirm point people and determine which call each subject will be 

discussed on. 

Discussion: 

• Notes from the August 28 call will be approved via email by Friday November 16.
• Future deadlines and call schedule (MA)

• Petition for polyalkylene glycol monobutyl ether (PGME); processing aid for livestock feed (LB)

o Petitioned as a synthetic on 205.605, but discussion on whether 205.603 would be a 

better fit as a synthetic substances allowed for use in organic livestock production. The 

NOP will send the petition back to the petitioner for more information. Once it is 

returned, the NOP will forward it to Materials and the appropriate Subcommittee. 

• Workplan 

o Research priorities - Part 1: The group discussed revising the research priorities 

recommendation in the form of a letter for dissemination to potential funding agencies. 

Part 2: The group would like to begin compiling priorities for next year, and would like 

each Subcommittee rep to mention it on the next round of call. Research priorities 

delegates are as follows: JFe-Crops, JD-Handling, CW or WF? – Livestock. This will be an 

ongoing item and the group will bring a list of new priorities to the fall meeting.

o CBI - ZS will have draft ready for next call (Nov 27) 

o Examine and update petition and technical review process – the group asked if this

could this be incorporated into the PDS workplan item, “convening of technical advisory 

boards &/or working group policy”. The members also discussed renaming this to be 

more specific, since the examination process will be focused and not comprehensive. 

The members also discussed adding the process for reviewing re-petitioned items.

o Petition and TR tracking- LB will talk with ZS offline to determine ZS’s needs with regard 

to emails and correspondence. 

o Material initiation policy - NOP has proposed that this be renamed “Substance 

Annotation/Clean-up”. The members discussed the need for this workplan item, and

while some felt it was useful, others felt that perhaps there wasn’t a need. The 

supporters argued that sometimes substances are petitioned and there isn’t adequate 

notice and time for public comment, while others felt that this is resolved by issuing a 

discussion document rather than a proposal. 

o Definition of production aids - NOP would support work on this item if the MS decides 

pursue it. A member felt that this was a catchall category and the parameters are not 

well defined while other members didn’t feel that this is an issue. The group asked for 

examples of substances that were problematic before moving forward. 

o How to address scientific uncertainty -JFe has already written a document, which the 

chair asked is sent to new members. 

Future Scheduled Subcommittee Calls:

November 27, 2012 1:00 pm EST

• CBI

December 11, 2012 1:00 pm EST

• Examine and update petition and technical review process 

December 19, 2012 1:00 pm EST

• Definition of production aids 

January 8, 2013 1:00 pm EST

January 22, 2013 1:00 pm EST

February 12, 2013 1:00 pm EST - proposals due

February 26, 2013 1:00 pm EST

March 12, 2013 1:00 pm EST
March 26, 2013 1:00 pm EST

MILESTONE

 

TARGET DATE

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, November 27, 2012, 1:00 pm EST 

Attending: Zea Sonnabend (Chair) (ZS), Jennifer Taylor (Vice Chair) (JT), Jay Feldman (JFe), Joe Dickson 

(JD), Calvin Walker (CW), Wendy Fulwider (WF), Tracy Favre (TF), Mac Stone (MS) - sitting in

Absent: 

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

 

Work Plan 

Project Reviewer Status Vote Target Meeting 

Examine and update 

petition and technical 

review process

JFe Jointly w/PDS (Materials will 

lead). JFe (Materials)/MS (PDS)

Spr 2013

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and CW 

Discussion doc, jointly w/PDS 

(JFe) in Spring? Prop in fall?

Spr 2013/Fall 

2013?

Definition of 

production aids

Spr 2013

Research Priorities 

Proposals 

May 2012 Framework 

Proposal

ZS & CW 

& JFe

Fall 2013

Petition and TR 

tracking

ZS/LB Ongoing N/A

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Joint w/PDS (PDS will lead) TBD

How to address 

scientific uncertainty

JFe Will begin this after “Update 

Petition Process and CBI 

projects” are complete

TBD

Agenda: 

• Approve notes from November 13. The notes from August 28, Sept 25 and Oct. 9 were approved 

via email

• Designate someone for GMO ad hoc committee

• Discuss CBI proposal

• Workplan Clarifications (if needed) 

Discussion:
• Notes from November 13 approved with no changes. 

• The GMO ad hoc committee representative will be Jennifer Taylor (JT)

• The Subcommittee discussed the draft CBI document. LB discussed the process for the TR 

contractors, who can request the CBI, as the NOP does not provide this info unless it is 

requested. The contractor cannot put this information in the TR due to confidentiality 

agreements. The members discussed CBI issues surrounding the difference between reviewing

groups of items, as opposed to reviewing individual substances, and the fact that groups of 

items are generic, and generally CBI is not an issue. ZS will make edits to the document based 

on the conversation, and will clarify and strengthen the language about affidavits. 

• Workplan Clarifications: 

o Examine and update ‘petition and technical review process’. The ‘two stage TR process’, 

which was a separate item, has been incorporated into this workplan item. The group 

discussed folding in the ‘material initiation policy’ workplan item, but felt that it 

shouldn’t be. The Materials Subcommittee and the Policy Development Subcommittee 

are working jointly on the petition and technical review process, and since Materials is 

leading this effort, they will initiate a document for review. 

o Research priorities - CW will be working on a letter based on the recommendation from 

the last NOSB, which will then be circulated to funding entities. TF is the representative 

from the Livestock Subcommittee (LS) so she will take the lead for the LS research

priorities.

o Note from Advisory Board Specialist (Nov 30, 2012): Ion Exchange Resins was removed 

from the workplan table above, as the release of the NOP memo will be delayed, 

perhaps until fall 2013. It will be placed back on the workplan at a later date. 

Future Scheduled Subcommittee Calls:

November 27, 2012 1:00 pm EST

• Discussion of CBI Policy

December 11, 2012 1:00 pm EST

• Examine and update petition and technical review process 

December 19, 2012 1:00 pm EST

• Definition of production aids 

January 8, 2013 1:00 pm EST

January 22, 2013 1:00 pm EST

February 12, 2013 1:00 pm EST - proposals due

February 26, 2013 1:00 pm EST

March 12, 2013 1:00 pm EST

March 26, 2013 1:00 pm EST
MILESTONE

 

TARGET DATE

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, December 11, 2012, 1:00 pm EST 

Attending: Zea Sonnabend (Chair) (ZS), Jay Feldman (JFe), Calvin Walker (CW), Tracy Favre (TF), Jennifer 

Taylor (Vice Chair) (JT), Mac Stone (MS)-sitting in

Absent: Joe Dickson (JD), Wendy Fulwider (WF)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

 

Work Plan 

Project Reviewer Status Vote Target Meeting 

Examine and update 

petition and technical 

review process

JFe (for 

Materials), 

MS (for 

PDS) 

Jointly w/PDS (Materials will 

lead and pass along the 

document to PDS). 

Spr 2013

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and CW 

Discussion doc, jointly w/PDS 

(JFe) in Spring? Prop in fall?

Spr 2013/Fall 

2013?

Definition of 

production aids

? Spr 2013

Research Priorities 

Proposals 

May 2012 Framework 

Proposal

ZS & CW & 

JFe

Fall 2013

Petition and TR 

tracking

ZS/LB Ongoing N/A

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Joint w/PDS (PDS will lead) TBD

How to address 

scientific uncertainty

JFe Will begin this after “Update 

Petition Process and CBI 

projects” are complete

TBD

Agenda: 

• Approve notes from November 27

• Discuss “Examine and update petition and technical review process” workplan item 

Discussion:

• Notes from November 27 call approved with no changes

• Examine and update petition and technical review process. This was originally included in a PDS 

document proposing a two-stage TR but since the group feels that this is a substantive issue, not 
a mechanical/process issue, it’s logical to have Materials lead with PDS input. The members 

discussed separating these items, and decided that it would be better to combine them. JFe, the 

lead for Materials, will connect with MS, who is going to lead for PDS, and discuss the path 

forward. MS noted that he was interested in the topic and is willing to help disperse the 

workload even though he is not on the Subcommittee. LB described to the group how the NOP 

processes petitions when they are received, and how the decision is made to forward it to the 

appropriate Subcommittee. The group discussed the pros and cons of this process as it currently 

stands and considered how to mold a discussion document in light of this. JFe will clarify the 

statement of the problem and edit the proposal. MS asked if the NOP would be able to assist 

the Board with more direction when beginning a new review and LB answered that NOP can 

continue to provide background information, but that providing guidance about decisionmaking may not be appropriate since it’s the NOSB’s responsibility to provide guidance. 

• ZS asked of NOP could provide a list of all petitions received, including ones that were not 

referred to the NOSB for review. LB noted that the NOP maintains this information and can 

forward it.

 

Future Scheduled Subcommittee Calls:

November 27, 2012 1:00 pm EST

• Discussion of CBI Policy

December 11, 2012 1:00 pm EST

• Examine and update petition and technical review process 

December 19, 2012 1:00 pm EST

• Continue discussion of “Examine and update petition and technical review process” 

(JFe/MS)

• Definition of production aids 

January 8, 2013 1:00 pm EST

• Examine and update petition and technical review process (JFe/MS) 

• Continued discussion of CBI policy (ZS, JFe, and CW) 

January 22, 2013 1:00 pm EST

February 12, 2013 1:00 pm EST - proposals due

February 26, 2013 1:00 pm EST

March 12, 2013 1:00 pm EST

March 26, 2013 1:00 pm EST

MILESTONE

 

TARGET DATE

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Public comment closes March 19, 2013
NOP - Send compiled public comments to NOSB March 25, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Materials Subcommittee (MS) Meeting Notes 

Tuesday, December 19, 2012, 1:00 pm EST 

Attending: Zea Sonnabend (Chair) (ZS), Jay Feldman (JFe), Tracy Favre (TF), Jennifer Taylor (Vice Chair) 

(JT), Joe Dickson (JD), Wendy Fulwider (WF), Calvin Walker (CW), Mac Stone (MS) - sitting in

Absent: Wendy Fulwider (WF)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

 

Work Plan 

Project Reviewer Status Vote Target Meeting 

Examine and update 

petition and technical 

review process

JFe (for 

Materials), 

MS (for 

PDS) 

Proposal. Jointly w/PDS 

(Materials will lead and pass 

along the document to PDS). 

Spr 2013

Confidential Business 

Information (CBI) 

Transparency

ZS, JFe, 

and CW 

Discussion doc, jointly w/PDS 

(JFe) in Spring? Prop in fall?

Spr 2013/Fall 

2013?

Definition of 

production aids

JFe Spr 2013

Research Priorities 

Proposals 

May 2012 Framework 

Proposal

ZS & CW & 

JFe

Fall 2013

Petition and TR 

tracking

ZS/LB Ongoing N/A N/A

Material initiation 

policy – NOP has 

proposed that this be 

renamed (Substance 

Annotation/Clean-up)

JFe/JT Joint w/PDS (PDS will lead) TBD

How to address 

scientific uncertainty

JFe Will begin this after “Update 

Petition Process and CBI 

projects” are complete

TBD

Agenda: 

• Approve notes from December 11

• Discuss “Definition of production aids” 

• Discuss “Examine and update petition and technical review process” workplan item

Discussion:
• Notes from the December 11 call were approved with no changes. 

• Production aids: Production Aids is a generalized category in the statute but is not defined in the 

regulations, and it comes up frequently in discussions and petitions. The group discussed the 

construction of the discussion document and questions that could be posed to solicit input from 

the public. Production aids seems to have two definitions, one a strict interpretation (for 

example, mulch or row cover) and the second, a less strict one, as an aid or additive used to 

produce a product. The second interpretation has never been used, although the issue does get 

raised occasionally. The group discussed several examples, including lignin sulfonate and 

hydrogen peroxide. Members also discussed specific points in the document that was circulated 

noting that question #2 would work better as the first question, #4 should be moved to position 

# 2, and perhaps question #3 is redundant. The group pondered the need for a discussion 

document at all, and deferred the conversation until the next call. The group also considered the 

implementation of defining production aids, and how that would be incorporated into the 

various existing guidance documents and the Policy and Procedures Manual PPM). 

• The Subcommittee members will review the letter addressing research priorities on the next 

subcommittee call (January 8)

• The Chair will have new draft of the CBI document for the next call

 

Future Scheduled Subcommittee Calls:

November 27, 2012 1:00 pm EST

• Discussion of CBI Policy

December 11, 2012 1:00 pm EST

• Examine and update petition and technical review process 

December 19, 2012 1:00 pm EST

• Continue discussion of “Examine and update petition and technical review process” (JFe/MS)

• Discuss “Definition of production aids” 

January 8, 2013 1:00 pm EST

• Examine and update petition and technical review process (JFe/MS) 

• Continued discussion of CBI policy (ZS, JFe, and CW) 

• Continue discussion of “Definition of production aids” 

• Review letter addressing research priorities

January 22, 2013 1:00 pm EST

February 12, 2013 1:00 pm EST - proposals due

February 26, 2013 1:00 pm EST

March 12, 2013 1:00 pm EST

March 26, 2013 1:00 pm EST

Spring 2013 Milestones Target date
NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013