Formal Recommendation

From: National Organic Standards Board (NOSB)

To: National Organic Program (NOP)

Date: November 18, 2016

Subject: 2016 Research Priorities

NOSB Chair: Tracy Favre

The NOSB hereby recommends to the NOP the following:

Rule Making Action:

Guidance Statement: 

Other: X

Statement of the Recommendation:

Although the NOSB often deliberates on the merits of a single material or process, we recognize 

that organic operations are a part of a larger whole. The entire farm as a system impacts the 

welfare of the environment and the animals that are part of that environment. Therefore, the 

NOSB urges that all research topics presented should be undertaken with consideration of the 

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

Livestock Subcommittee: 1) Evaluation of Methionine in the Context of a System Approach in 

Organic Poultry Production and 2) Prevention and Management of Parasites.

Crops Subcommittee: 1) Biodegradable Biobased Bioplastic Mulch, 2) Organic No-Till, 3) 

Alternatives to Antibiotics (Tetracycline and Streptomycin) for Fire Blight, 4) Alternatives to 

Copper for Disease and Algae Control, 5) Plant Disease Management, and 6) Mitigation 

Measures for Residues in Compost.

Handling Subcommittee: 1) Chlorine Materials & Alternative Materials, 2) Celery Powder, 3) 

Alternatives to Bisphenol A (BPA), and 4) Consumer Demand.

Materials/GMO Subcommittee: 1) Fate of Genetically Engineered Plant Material in Compost, 2) 

Integrity of Breeding Lines and Ways to Mitigate Small Amounts of Genetic Presence, 3) 

Prevention of GMO Contamination: Evaluation of effectiveness.
Rationale Supporting Recommendation (including consistency with OFPA and Organic

Regulations):

Since adopting its Research Priorities Framework in 2012, the National Organic Standards Board 

or NOSB, a Federal Advisory Committee, has presented a list of research priorities for organic 

food and agriculture. Research needs are prioritized along the following criteria: 1) persistent 

and chronic, 2) challenging, 3) controversial, 4) nebulous, 5) lacking in primary research, and 6) 

relevant to assessing the need for alternative cultural, biological, and mechanical methods to 

materials on the National List. The NOSB encourages collaboration with and between 

laboratories, federal agencies, universities, foundations and organizations, business interests, 

organic farmers, and the entire organic community to seek solutions to pressing issues in 

organic agriculture and processing/handling. This proposal’s topics reflect an effort by each 

Subcommittee to review and prioritize all previous years’ priorities from 2012-2015, and it also 

includes some priorities new in 2016. 

NOSB Vote: 

Motion to adopt the proposal on 2016 NOSB Research Priorities

Motion by: Emily Oakley

Seconded by: Tracy Favre

Yes: 14 No: 0 Abstain: 0 Recuse: 0 Absent: 1

Motion Passed
National Organic Standards Board

Materials Subcommittee Proposal

2016 Research Priorities

August 9, 2016

INTRODUCTION

Since adopting its Research Priorities Framework in 2012, the National Organic Standards Board 

or NOSB, a Federal Advisory Committee, has presented a list of research priorities for organic 

food and agriculture. The priorities are proposed by the NOSB’s Livestock, Crops, Handling, and 

Materials/GMO Subcommittees and are published each year, prior to the fall meeting. The final 

priorities include feedback from organic stakeholders, which is publicly available through the 

Federal Register. This document reflects an effort by each Subcommittee to review and 

prioritize all previous years’ priorities from 2012-2015. The topics listed below by 

subcommittee are the 2016 priorities, including some from previous years that the NOSB thinks 

are still relevant. The older priorities and their dates of adoption can be found in a list at the 

end of this proposal. 

BACKGROUND

Research needs are prioritized along the following criteria: 1) persistent and chronic, 2) 

challenging, 3) controversial, 4) nebulous, 5) lacking in primary research, and 6) relevant to 

assessing the need for alternative cultural, biological, and mechanical methods to materials on 

the National List1.

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

universities, foundations and organizations, business interests, organic farmers, and the entire 

organic community to seek solutions to pressing issues in organic agriculture and 

processing/handling.

PROPOSAL: 2016 RESEARCH PRIORITIES

Although the NOSB often deliberates on the merits of a single material or process, we recognize 

that organic operations are a part of a larger whole. The entire farm as a system impacts the 

welfare of the environment and the animals that are part of that environment. Therefore, the 

NOSB urges that all research topics presented should be undertaken with consideration of the 

whole farm system. 

 1 The National List of Allowed and Prohibited Substances identifies the synthetic substances 

that may be used and the nonsynthetic (natural) substances that may not be used in organic 

crop and livestock production. It also identifies a limited number of non-organic substances 

that may be used in or on processed organic products. The NOSB advises the National Organic 

Program (NOP) on which substances should be allowed or prohibited.
A whole-farm, systems-based research framework will ensure that the research questions 

posed demonstrate an understanding of the interplay of the agroecology and the necessary 

biodiversity of both native and farmed species of plants and animals. This whole-farm, 

agroecological framework will ensure that confounding variables are carefully recorded as part 

of a comprehensive and practical approach to the research. Such research could contribute to 

answering some of the broader questions in organic agriculture such as:

• How can crop species and varieties be specifically adapted to site-specific conditions

through plant breeding or cultural practices? 

• How does biodiversity contribute to pest and disease resistance? 

• What is the relationship between nutrient balancing fertilization practices and microbial 

life in the soil to susceptibility or resistance to pests? 

• How can the need for a diverse agroecological system be balanced with food safety 

concerns for sustainable organic farming systems? 

• How can the complex whole environmental system inform, support, and educate a 

farmer in developing a farming system plan?

The NOSB encourages integrated research into the following areas:

Livestock

Introduction

In previous years the Livestock subcommittee has suggested basic research priorities on 

prevention and treatment of pneumonia and mastitis. The consumer expects all organic 

livestock to be treated well and be healthy. Animal welfare is of critical importance to 

producers, and consumers expect to be able to observe that their meat, wool, and eggproducing organic livestock are in good health. 

In 2015, the NOSB suggested that the research priorities on herd and flock health be changed to 

reflect a systems review of successful models of livestock production nationwide. Which 

breeds are doing best under organic management? Are we selecting the most appropriate 

breeds for high levels of herd and flock health? Which grazing management systems and 

natural resource conservation practices are producing the highest quality organic product from 

the healthiest flocks and herds? What factors appear to be contributing to healthy livestock? 

What agroecosystem and management factors contribute to the healthiest herds and flocks? 

In the context as described above, the Livestock subcommittee proposes the following research 

topics as priorities for 2016:

1. Evaluation of Methionine in the Context of a Systems Approach in Organic Poultry 

Production 

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

fed a plant and meat-based diet without synthetic amino acids such as methionine. As the 

organic community moves toward reducing, removing, or providing additional restricting

synthetic methionine in the diets of poultry, a heightened need exists for the organic 

community to encourage omnivore producers to assist in marshaling our collective efforts 
to find viable alternatives to synthetic methionine, and to help find approaches for making 

them more commercially available. 

Continued research on the use of synthetic methionine in the context of a systems 

approach (nutrition, genetic selection, management practices, etc.) is consistent with the 

NOSB’s unanimous resolution to encourage the industry to move away from the use of 

synthetic methionine passed at the La Jolla, California, Spring 2015 full board meeting. A 

systems approach that includes industry and independent research by USDA/ARS, on-farms, 

and agricultural land grant universities is needed for:

a. evaluation of the merits of natural alternative sources of methionine such as 

herbal methionine, high methionine corn, and corn gluten meal in organic 

poultry production systems, 

b. evaluation of poultry breeds selection that could be adaptive to existing organic 

production systems – inclusive of breeds being able to adequately perform on 

less methionine, and 

c. assessment of management practices for improving existing organic poultry 

welfare under different conditions. 

Research findings and collaborations under various climates, housing types, geographical 

regions, and countries should be noted and researched, where applicable. These types of 

research topics are complex, and it could take years to achieve the expressed NOSB resolution. 

However, an aggressive and/or heightened research focus could lead to findings that can 

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

methionine with a systems approach is imperative and necessary. 

The key research areas should include the efficacy and viability of alternatives such as: herbal 

methionine, corn gluten meal, potato meal, fishmeal, animal by-products, and other non-plant 

materials. Additional research on the more promising alternatives related to bringing these 

alternative sources into commercial production is also encouraged. Furthermore, research 

should be conducted on management practices that impact a flock’s demand for methionine,

such as flock management practices, access to pastures, and pasture management.

2. Prevention and Management of Parasites 

Livestock production places large numbers of cattle, sheep, goats, poultry, etc. into 

relatively close contact with each other on fields and in barns. Organic production does not 

allow antibiotic use and requires that livestock are raised in a manner that accommodates

the animal’s natural behavior. The organic farmer can use a limited number of approved

synthetic parasiticides in an emergency but not prophylactically. Use of synthetic 

parasiticides is limited in organic systems. Even if prophylactic treatment with parasiticides 

were possible, it is clear that parasite immunity to chemical control will inevitably occur. 

Thus prevention of parasites is critical. 

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

What farm systems, animal breeds, and herd or flock management systems have shown the 

best results with parasite control over the last 20 years? What regional differences exist in 

the U.S. in parasite prevention? Are there specific herbal, biodynamic, or other alternative 
treatments that have been proven to work over time? What are the parasite-resistant

animal breeds? Are there plant species in pastures and scrublands that could be 

incorporated into the annual grazing system to reduce the spread of parasites or to provide 

prevention through the flora, fauna, and minerals ingested? Which pasture management 

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

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

breeds? 

Crops

1. Biodegradable Biobased Mulch Film (new priority in 2016)

This type of mulch film was recently recommended by the NOSB but did not include a 

specific percentage of biobased components it must contain. In 2015, NOP issued a Policy 

Memo2 that states that certifiers and material organizations should review biodegradable 

biobased mulch film products to verify that all of the polymer feedstocks are biobased. This 

requirement makes biobased mulches unavailable to organic producers, due to the

petroleum-based polymers in these mulch films. In order to provide a recommendation to 

the NOP addressing the presence of petroleum-based polymers in these mulches, the NOSB 

requests answers to the following questions:

• How rapidly do biodegradable biobased mulch films fully decompose, and does the 

percentage of the polymers in the mulch film affect the decomposition rate? Are 

there metabolites of these mulches that do not fully decompose?

• Are there different cropping systems, climate, soil types, or other factors that affect 

the decomposition rate?

• What type of effect does the breakdown of these polymers have on soil and plant 

life as well as livestock that would graze either crop residues or forages grown the 

subsequent year after this mulch film was used?

• Does the use of these synthetic polymers over time affect the balance of soil 

biology?

• Is there any cumulative effect if this mulch film is used 3-5 years or more in the same 

location?

• Are the available testing regimens adequate to meet the decomposition standards in 

our definition and to validate the non-GMO status of source materials?

2. Organic No-Till

Organic no-till practices are quite different from herbicide-based no-till systems. Organic notill, using a terminated, in-place mulching system, can increase soil health and provide for 

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

soil moisture, reduces soil erosion, and requires less fuel and labor than standard organic 

row crop farming. Even though this killed-in-place mulch practice has been used for more 

than a decade, widespread adoption has not occurred. This type of production is also

attractive to conservation minded nonorganic farmers, and more practical information could 

result in the growth of domestic organic production. There are some land grant universities

and federal agencies doing research on this type of production, but more work needs to be 

 2 Policy Memo 15-1
done. Increased research is needed to develop organic no-till systems that function for a 

wide variety of crops in diverse climates and soil types. Annual crops, such as commodity 

row crops and specialty crops, as well as perennial crops, such as tree fruits, berries, and 

grapes, would all benefit from these organic no-till practices. Research areas that could be 

covered include:

• Development of plant varieties that have specific characteristics, such as early 

ripening, to aid in the effectiveness and practicality of organic no-till.

• Identification of mulch crops, systems, and timing of practices that provide weed 

management benefits with minimum interference to the crop and yields?

• Research on various techniques that would provide a variety of options for diverse 

cropping systems including, but not limited to: strip tillage within a killed mulch, 

mowing or other organically approved techniques versus rolling to terminate the 

mulch, and living mulches in standing crops.

• Development of systems that allow for either continuous no-till organic crops or for 

multiple years of organic no-till in the crop rotation.

• Research on how reduced soil disturbance contributes to pest, weed, and disease 

management?

• Benefits or drawbacks of using this mulching system on weed, pest and disease 

management, as well as soil fertility, in perennial cropping systems, such as fruits. 

• Research about how the use of this system can be managed to improve water 

retention and permeation, both in annual crops and especially in perennial cropping 

systems.

• Biodiversity benefits to the living and/or killed mulches, and how they contribute to 

pest, weed, and disease management.

• Research into what effect the system would have on nutrient balance of the soil and 

subsequent fertilization practices, including use of outside inputs.

• Research into how this system affects soil microbial life and nutrient availability, 

given that less soil disturbance improves plant decomposition and therefore 

provides higher organic matter, and if it results in crops that are less susceptible to 

disease and pests.

3. Alternatives to Antibiotics (Tetracycline and Streptomycin) for Fire Blight

Prior to October 2014, oxytetracycline and streptomycin were allowed for the control of fire 

blight in apple and pear trees only. Since 2014, neither substance may be used in any 

organic practice. Organic apple and pear growers must now find suitable alternatives to 

control the deadly fire blight disease. Since apples and pears are grown in many regions 

throughout the United States, alternatives must work in a variety of climates and 

management systems. The following research issues are important to investigate: location;

planting density; choice of varieties of cultivar and rootstock; soil improvement practices;

pruning practices and general sanitation; groundcovers or intercrops; pollinator 

management; dormant copper sprays; bloom thinning/lime sulfur; early, full bloom, and late 

sprays with approved organic materials to prevent fire blight establishment; surveys for fire 

blight activity; and other cultural and preventative techniques. 
4. Alternatives to Copper for Disease and Algae Control

Organic producers have few alternatives to synthetic chemicals to control diseases. Copper 

has been used for more than a century to control serious diseases in crops such as late 

blight in tomatoes and fire blight in pears. Because the copper products degrade to 

elemental copper, continued use over time can cause copper to accumulate in soil. If used 

improperly or to excess, copper can be toxic to aquatic life and wildlife. 

Alternative materials are not yet available to address the many diseases which copper 

treats. Targeted research is needed to identify management practices and less toxic 

alternative materials for a wide range of crops. More research is needed on many of the 

crop/disease combinations. 

Some avenues for research: 

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

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

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

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

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

of elemental copper is reduced. 

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

used.

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

• Determining if alternatives, such as sodium carbonate peroxyhydrate or other materials,

are suitable alternatives to control scum and algae in rice in an aquatic environment. 

5. Plant Disease Management

There is a need for research into plant disease management practices and alternative 

materials, particularly for the humid areas of the country, that decrease reliance on copper 

or other substances that might have a negative impact on the soil and health of 

farmworkers. Pathogens include, but are not limited to: Alternaria, Erwinia, Pseudomonas, 

Xanthomonas, Cercospora, Colletotrichum, Cladosporium, powdery mildew, downy mildew, 

Phytophthora, Pythium, Mycosphaerella, Phomopsis, Taphrina, Elsinoe, Gnomonia, 

Fusicladium, Nectria, Phyllosticta, Diplocarpon, Albugo, Guignardia, Botrytis, Exobasidium, 

Entomosporium, Exobasidium, Pestalotia, Phoma, Cristulariella, and Monilinia fruticosa. 

Citrus greening, caused by the bacterium Candidatus Liberibacter, and spread by a diseaseinfected Asian citrus psyllid, is an emerging problem. Promising avenues of research include 

disease-resistant varieties, predators and parasites and how they interact with approved 

materials, nutrition (calcium, boron, and nitrogen have been identified), and botanical oils. 

In particular, both biological control of plant diseases and bio-pesticides should be a 

research priority to support organic growers. A large body of research has shown that plant 

diseases caused by bacteria and fungi can often be prevented by the application of a nonpathogenic microorganism before infection occurs. Although much basic research has been 

done to identify microbial biological control agents, there is still a need for commercial 

development, field testing, and adoption by growers. Biological controls have been 
researched for late blight of potato and tomato (Phytophthora infestans), several diseases 

caused by Botrytis cinerea, and powdery mildew (several species) controlled by mites, fungi,

and bacteria. 

Although many biological controls and bio-pesticides have demonstrated effectiveness in 

research plots, they have often not succeeded commercially because they can’t compete 

with inexpensive synthetic chemicals used by non-organic farmers. Biological materials are 

often more expensive than conventional pesticides, and they need be applied before 

disease is apparent. In the past, there was little market for biological controls because the 

organic acreage was limited. Now that organic acreage has increased, the market for 

alternative plant disease controls has also increased which can spur commercialization of 

natural methods of disease control. The availability of biological controls for plant diseases 

can also make it more feasible for conventional farmers to transition to organic, thus 

benefitting organic consumers. 

6. Mitigation Measures for Residues in Compost

Residues of pesticides in compost material are a problem that requires research, according 

to the Organic Materials Research Institute (OMRI). Because of the importance of compost 

to organic management systems, research is needed on: types of mitigation measures that 

are efficacious; identification of problematic feedstock (e.g. cotton-based materials and yard 

waste); types of corrective action; and if thresholds for allowable residues are established, 

testing guidelines. This is more important than ever with events of 2016 regarding 

contamination in compost.

Handling

1. Chlorine Materials and Alternatives 

The three chlorine materials currently allowed for use in organic agriculture are widely used 

in farming and handling to clean and disinfect equipment, surfaces, and produce. There 

have been some concerns raised about these materials and their impact on the environment 

and human health when/or if they form trihalomethanes and other toxic compounds. New 

FDA regulations on food safety (Food Safety Modernization Act) and best management 

practices for cleaning in handling operations both require a suitable level of cleanliness and 

disinfection to prevent pathogens from entering the food supply. Producers and handlers

are looking for alternatives to chlorine while continuing to provide a safe end product to 

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

fundamental organic principles involving human health and environmental impact is a 

concern.

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

appropriate chlorine materials are best suited for a specific use and control measure. This is 

especially important in determining if the industry can move away from the use of chlorine 

compounds in the future.

Points of consideration for future research activities:
• Comparison of alternatives to chlorine such as: citric acid, hydrogen peroxide, ethanol, 

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

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

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

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

mitigated and still allow the material to work as needed?

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

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

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

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

• Research about whether rotation of materials for cleaning and disinfecting could help lower 

the risks from chlorine materials and still be effective in providing the desired control of 

pathogens.

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

including information about amount of time of exposure. Would this be a persistent residual 

effect or temporary (if temporary – how long is it a viable residue), and would it be harmful if 

consumed at these levels?

2. Celery Powder

Celery Powder is used in a variety of processed meat product (hot dogs, bacon, ham, corned 

beef, pastrami, pepperoni, salami, etc.) to provide “cured” meat attributes without using 

prohibited nitrites (note: products must still be labeled “uncured”). Celery powder is 

naturally high in nitrates that are converted to nitrites during fermentation by a lactic acid 

culture. It has proven difficult to produce celery powder under organic production practices 

with sufficient levels of nitrates for cured meat applications. Are there growing practices or 

regions that could produce celery under organic conditions that would yield a crop with 

sufficient nitrate content for cured meat applications? Are there agriculturally derived 

substances (other than celery) that could be produced under organic production practices 

that provide nitrate levels sufficient for cured meat product applications of comparable 

quality?

3. Alternatives to Bisphenol A (BPA) 

The Handling subcommittee plans to take up the issue of whether to prohibit BPA in 

packaging material used for organic foods in light of mounting evidence that it may be 

harmful. There is a need for increased research about suitable alternatives for the linings of 

cans used for various organic products such as tomatoes, beans, and soups.

4. Consumer Demand 

The NOSB often receives comments from stakeholders that consumers have expectations 

about what organic means and what inputs and ingredients should be in organic food. 

Sometimes there is a wide difference between what consumer activist groups claim and 

sales of specific categories of organic products in the marketplace. How can the NOSB 

determine whether the consumers and groups who speak up are truly representing all 

consumers of organic, and is there a better measure of consumer preference and 

expectations for organic products than sales figures? Research showing the distribution 

curve of consumer preferences and expectations around organic products would be helpful. 
Materials/GMO

In previous years, the Materials subcommittee has prioritized the Reduction of genetically

modified content of breeding lines (2013) and seed purity from GMOs (2014). These issues are 

currently being addressed through an NOSB Seed Purity task force.

1. Fate of genetically engineered plant material in compost

What happens to transgenic DNA in the composting process? Materials such as cornstalks 

from GMO corn or manure from cows receiving rBGH are often composted, yet there is little 

information on whether the genetically engineered material and traits break down in 

composting process. Do these materials affect the microbial ecology of a compost pile? Is 

there trait expression of Bt (bacillus thuringienses) after composting that would result in 

persistence in the environment or plant uptake? 

2. Integrity of breeding lines and ways to mitigate small amounts of genetic presence

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

Breeding lines may have been created through genetic engineering methods such as doubled 

haploid technology, or they may have had inadvertent presence of GMOs from pollen drift. 

The extent of this problem needs to be understood.

3. Prevention of GMO contamination: Evaluation of effectiveness

How well are some of the prevention strategies proposed by the NOSB working to keep 

GMOs out of organic crops? For instance, how many rows of buffer are needed for corn? 

How fast does contamination percentage go up or down if there are more or fewer buffer 

rows? 

Other questions could include: whether cleanout of combines and hauling vehicles reduces

contamination using typical protocols for organic cleaning; whether situating at-risk crop 

fields upwind from GMO crops can reduce contamination; and what role pollinators may 

have in spreading GMO pollen. 

Lastly, research is needed on a mechanism to provide conventional growers incentives to 

take their own prevention measures, to prevent pollen drift and its impact on organic and 

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

important. 

Previous Years’ Research Priorities

For more detailed information about each topic, please see the relevant research priorities 

proposals. Each topic’s listing year is indicated.

Whole Farm Systems (2012, 2013)

Evaluation of Copper Sulfate for Rice (2012)

Evaluation of Genetically Modified Vaccines (GMO) (2012, 2013)

Organic Aquaculture (2012, 2013)
Carageenan (2012)

Aquatic Biodiversity (2013)

Pastured Poultry and Salmonella (2013)

Commercial Availability Assessments (2013)

Herd and Flock Health (2013, 2014, 2015)

Risk Reduction from Off-Target Exposure to Non-Permitted Materials (2014)

Seed Purity from GMO (2014)

Mastitis (2014)

Pneumonia (2014)

Plant Extracts (2014)

Soil Building Practices (2014)

Subcommittee Vote:

Motion to adopt the proposal on 2016 NOSB Research Priorities

Motion by: Emily Oakley

Seconded by: Trace Favre

Yes: 6 No: 0 Abstain: 0 Recuse: 0 Absent: 0