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May 1, 2017

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

FROM: Miles V. McEvoy 

Deputy Administrator

National Organic Program (NOP)

SUBJECT: Response to National Organic Standards Board Recommendations 

(November 2016 Meeting)

Background

This memorandum responds to the National Organic Standards Board (NOSB) recommendations

made at its November 16-18, 2016, meeting in St. Louis, Missouri. 

Summary of Recommendations 

1. Petitioned Substances. The NOSB recommended one amendment to the National List of 

Allowed and Prohibited Substances (National List). This section of the U.S. Department of 

Agriculture (USDA) organic regulations includes synthetic substances allowed in crop and 

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

non-organic substances allowed in the handling of organic products. 

Substance Section NOSB Recommendation

Ivermectin Livestock: 205.603(a)(18)(ii) The motion to remove 

ivermectin from the National 

List, section§205.603, passed.

The NOSB reviewed and 

supported the petition for 

removal of ivermectin from the 

National List. 

2. 2018 Sunset Review. The NOSB completed the 2018 sunset review for 15 substances. The 

NOSB considered motions to remove each of these substances from the National List.

Upon completing the 2018 Sunset review, the NOSB recommended one substance for 

removal: Carrageenan.
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Substance Section Action Considered by NOSB

NOSB Recommendation

Carrageenan §205.605(a) The motion to remove this substance from the 

National List, based on the OFPA criteria 

“availability of alternatives,” passed. The 

NOSB recommended removal from the 

National List as a result of its sunset review.

Copper sulfate 205.601(a); 

205.601(e)

The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Ozone gas 205.601(a) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Peracetic acid 205.601(a); 

205.601(i)

The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

EPA List 3 Inerts 205.601(m) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Calcium chloride 205.602(c) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Agar-agar 205.605(a) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Animal enzymes 205.605(a) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Calcium sulfatemined205.605(a) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Glucono deltalactone205.605(a) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Tartaric acid 205.605(a) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Cellulose 205.605(b) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Potassium 

hydroxide

205.605(b) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Silicon dioxide 205.605(b) The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

Colors: Betacarotene extract205.606 The motion to remove this substance from the 

National List failed.

The NOSB completed its sunset review.

3. Other Recommendations

Policy and Procedure Manual Revisions

The NOSB issued a recommendation to adopt the September 13, 2016, draft version of the 

NOSB Policy and Procedures Manual. The objective of the recommendation is to revise the 

manual to reflect the current procedures for the collaborative and productive functioning of the 

NOSB.

Sunset Review - Efficient Workload Reorganization

The NOSB recommended a reorganization of the sunset review schedule to distribute the 

workload more evenly over the course of the five-year review timeline. The new timeline was 

widely supported by organic stakeholders, as it also lessens the workload for stakeholders who 

provide public comment. 
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Research Priorities

The NOSB submitted a current list of research priorities that would support the organic sector, 

and urges researchers to consider whole farm systems when undertaking research topics. New 

priorities added to the 2016 list include: prevention of GMO contamination; biodegradable 

biobased mulch film; prevention and management of parasites for organic livestock; evaluation 

of methionine; a systems-based approach for organic poultry; chlorine materials for handling;

and alternatives to copper for plant disease and algae control. The NOSB recommended

adopting the proposal on the 2016 NOSB Research Priorities.

Excluded Methods Terminology

The NOSB passed a recommendation on excluded methods terminology that creates a structure 

for reviewing new technologies and disseminating the results of the review in a transparent 

manner. The Board voted to approve various definitions for excluded methods, and approve 

principles and criteria for evaluating new technologies and terminologies. 

Discussion and Response

1. Petitioned Substances: Ivermectin (Livestock) 

The NOSB concluded that ivermectin should be removed from the National List, pursuant to 

Section 6518(m) of the Organic Foods Production Act (OFPA), with particular reference to 

Criteria 2, 5, 6, and 7 at Section 6518(m). Specifically, the NOSB recommended to remove

ivermectin from the National List because: it is toxic in the environment by having a negative 

impact on dung beetles (a critical component of good pasture management); there are two 

alternative synthetic parasiticides on the National List, fenbendazole and moxidectin, that can be 

used as alternative medications during an emergency; high quality pasture and range 

management grazing techniques can reduce the need to use any parasiticide; and there are 

alternative herbal remedies. For the above reasons, the NOSB concluded that the use of 

ivermectin is incompatible with a system of sustainable agriculture.

The NOSB passed a recommendation to remove ivermectin from section 205.603(a)(18)(ii) of 

the National List. 

AMS Response: 

AMS is reviewing the recommendation to remove ivermectin from the National List. 

2. 2018 Sunset Review

The NOSB completed the sunset review for 15 substances as a part of the 2018 Sunset review 

and recommended the removal of one substance: carrageenan. 

The NOSB evaluated carrageenan according to OFPA criteria, and specifically with relation to

7 U.S.C 6518(m)(1) and (2). The NOSB determined that there are suitable alternatives to be 

used in place of carrageenan, such as gellan gum, guar gum, or xanthan gum. The majority of 
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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NOSB members also concluded that carrageenan is not compatible with OFPA criteria at 

7 U.S.C. 6518(m) due to controversial information regarding perceived human health risks 

associated with the material. The Board’s recommendation was also based on the NOSB’s

Guidance on Compatibility from the Appendix of the NOSB Policy and Procedures Manual, 

which addresses the question of whether the substance satisfies the expectations of organic 

consumers with regard to the authenticity and integrity of organic products. Some members 

stated that carrageenan does not meet the expectations of organic consumers. 

The NOSB passed a recommendation to remove carrageenan from section 205.605(a) of the 

National List. 

Response: 

AMS is reviewing the National List materials that were part of the 2018 sunset review process,

including the recommendation to remove carrageenan from the National List. 

3. Other Recommendations

As presented above, the NOSB made recommendations related to the Policy and procedure 

manual; sunset review - efficient workload reorganization; research priorities; and excluded 

methods terminology. 

Response: 

The NOSB Policy and Procedures Manual has been revised per NOSB’s recommendation and is 

available at https://www.ams.usda.gov/sites/default/files/media/NOSB-PolicyManual.pdf. AMS 

is working with NOSB to implement the reorganization of the sunset review process. AMS is 

providing the research priorities to USDA’s National Institute for Food and Agriculture and the 

Agricultural Research Service. AMS is reviewing the excluded methods recommendation to 

determine next steps to implement recommendations. 

Summary

AMS acknowledges and sincerely appreciates the hundreds of hours NOSB members provided in 

developing its November 2016 recommendations. In addition, AMS supports NOSB’s vital role 

in representing the diversity of the organic community to enhance organic regulatory

implementation and ensure organic product integrity.

AMS welcomes new committee members Joelle Mosso (Organic Handler), Sue Baird (Consumer 

Interest Representative), Asa Bradman (Environmental Protection and Resource Conservation 

Representative), Steve Ela (Organic Farmer), and David Mortensen (Scientist Representative). 

NOP thanks retiring board members Tracy Favre, Jean Richardson, Zea Sonnabend, 

Carmela Beck, and Harold Austin for their service and thoughtful guidance. During the past five 

years, they demonstrated a commitment to NOSB's role in advising AMS on the USDA organic 

regulations and the OFPA. Much of the success achieved by AMS is due to the considerable 

expertise and dedication of NOSB members.