Updated June 17, 2010

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: April 29, 2011

Subject: Streptomycin Sunset

Chair: Tracy Miedema

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X

Guidance Statement 

Other 

Statement of the Recommendation (Including Recount of Vote): 

The board recommends amending §205.601 Synthetic substances allowed for 

use in organic crop production.(i) As plant disease control.(10) Streptomycin, 

for fire blight control in apples and pears only until October 21, 2014, by a vote 

of 13 yes, 1 no. A motion limiting it to post infection use failed by a vote of 5 

yes, 9 no.

The Board expects that members of the industry will collaborate and coordinate 

efforts in preparing for the eventual removal of this material from the National 

List, specifically optimizing the use of resistant rootstocks and cultivars, 

preventive management methods, and the use of alternative, allowed biological 

and chemical controls whenever warranted.

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

Based on the recommendation of the Crops Committee and testimony 

submitted to the Board, the Board recommends delisting streptomycin as soon 

as is reasonable. Testimony indicated that some time is needed for the 

transition. The Board also asks that the National Organic Program supports the 

transition to managing fire blight without antibiotics to the extent possible.

NOSB Vote:

§205.601 Synthetic substances allowed for use in organic crop production.

(i) As plant disease control.

(10) Streptomycin, for fire blight control in apples and pears only until 

October 21, 2014.
Updated June 17, 2010

Moved: Nick Maravell Second: Tina Ellor

Yes: 13 No: 1 Abstain: 0 Absent: 0 Recusal: 0

NOSB Backup Vote to Relist:

§205.601 Synthetic substances allowed for use in organic crop production.

(i) As plant disease control.

(10) Streptomycin, for fire blight control in apples and pears.

Moved: John Foster Second: Colehour Bondera

Yes: 10 No: 4 Abstain: 0 Absent: 0 Recusal: 0
National Organic Standards Board 

Crops Committee 

2012 Sunset Recommendation 

Streptomycin 

April 29, 2011 

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

(i) As plant disease control. 

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

Summary

The Crops Committee requested, but did not receive, prior to adopting its 

recommendation on streptomycin, an updated Technical Review (TR), noting 

deficiencies in the previous reviews. The committee had a 2006 TR and a1995 

Technical Advisory Panel (TAP) for streptomycin. The committee proceeded based on 

its own research, pending the receipt of the new TR, which was reviewed when it is 

received. 

The antibiotic streptomycin was first approved in November 1995. Streptomycin and 

another antibiotic, tetracycline, were each listed with a split vote. The issue of 

engendering antibiotic resistance in human pathogens and in workers was raised in the 

1995 TAP review. The annotation that permitted use for “fire blight control in apples and 

pears only” was adopted. Streptomycin antibiotics were to be reviewed again in two 

years, and there was to be a task force to further explore antibiotic use in fruit 

production. 

The 1998 proposed rule would have allowed “antibiotics as pesticides.” There was 

public opposition to the use of antibiotics as pesticides. When the USDA published the 

next draft rule in early 2000, it removed the NOSB recommendations allowing 

streptomycin and tetracycline in order to be consistent with the prohibition of antibiotics 

in livestock. The two antibiotics were reinstated in the December 2000 final rule in 

response to comments from growers. 

Thus, from the very beginning, there has been controversy over allowing these 

chemicals to be used in organic agriculture. The board discussion regarding the 2006 

sunset included concerns about: 

 Promotion of resistance in human pathogens 

 Natural substitutes 

 Inconsistency with the prohibition of antibiotics in livestock 

 Inconsistency with organic principles 

 Disagreement with the prophylactic use of antibiotics 
Sunset 2012 Recommendation 

Streptomycin 

April 29, 2011

Page 2 of 3

 The Centers for Disease Control and Prevention (CDC) opposition to the use of 

streptomycin and tetracycline in crop production 

 Failing to give an incentive for alternatives 

 Reaction against organic fruit by consumers 

 Possibility that antibiotics might be taken up by fruit trees 

 Need for more research 

 Restrictions on sales of fruit in Europe 

 Disruption of the organic system. 

And on the other hand, 

 Lack of data showing impact on resistance in human pathogens 

 Dependency of growers on the materials 

Ultimately, after expressing concern and the wish that someone might petition to 

remove them sooner than the next sunset, the two antibiotics were renewed with a vote 

of 7 yes, 4 no, 1 abstention, and 2 absent. 

Now the two antibiotics come to board again —streptomycin as a sunset and 

tetracycline as a petition to remove the annotation, the 2912 expiration date. Although 

the committee did not have an updated TR on streptomycin, it found that the case 

against streptomycin has grown stronger and that removal from 601 should be delayed 

no longer. 

The Crops Committee was presented with evidence that streptomycin can contribute to 

antibiotic resistance in human pathogens when used as pesticides on plants. At the 

same time, additional products are available for use against fire blight. Serenade Max, 

Bloomtime Biological FD, BlightBan C9-1 and Blightban A506 are relatively new 

biological controls. Surround is a kaolin clay product that has had some success in 

controlling fire blight. 

Furthermore, when the committee did receive the new TR, it contained the new 

information that streptomycin sprays can lead to detectable residues of streptomycin in 

apples, particularly the cores and skins. 

However, most importantly, the majority of the committee believes that the first line of 

defense is the choice of resistant varieties and rootstocks, a concept that the committee 

majority believes is a critical organic principle, essential to disease or pest prevention in 

organic systems. Despite this, the pattern of growth in organic apple and pear varieties 

in certain areas of the country has been skewed toward those varieties most susceptible 

to fire blight. In 2010, the leading organic apple varieties grown in Washington state 

were Fuji, Gala, and Granny Smith and accounted for approximately 54% of organic 

apple acreage —all highly susceptible to fire blight. (Some other widely-planted 

varieties are also highly susceptible.) The leading varieties in organic pear production 

were Bartlett, D’Anjou, and Bosc —80% of organic pear acreage— again among the 
Sunset 2012 Recommendation 

Streptomycin 

April 29, 2011

Page 3 of 3

most susceptible to fire blight. On the other hand, there are numerous apple and pear 

varieties that are not susceptible to fire blight. 

Given the public health threat associated with antibiotic resistant, the committee 

majority believes that organic production should not contribute in a small or large way to 

antibiotic resistance. The options for new antibiotics with efficacy are eluding us as 

resistance continues to increase. 

Similarly, the committee has been told that fire blight resistance to streptomycin in some 

apple production is found widely. Therefore, the committee found, streptomycin’s 

efficacy and, as a result, essentiality cannot be established. 

Prior to the board meeting, the Crops Committee voted to recommend against the 

continued listing of streptomycin, for fire blight control in apples and pears only. 

New public comment was also considered, which resulted in changing this 

recommendation. The comments included the regional differences in utility of 

streptomycin and tetracycline. Apple and pear growers commented that they need more 

time. Consumer representatives commented that consumers expect organic products 

to be produced without antibiotics. 

The Committee expects that members of the industry will collaborate and coordinate 

efforts in preparing for the eventual removal of this material from the National List, 

specifically optimizing the use of resistant rootstocks and cultivars, preventive 

management methods, and the use of alternative, allowed biological and chemical 

controls whenever warranted. 

The Committee also asks that the National Organic Program supports the transition to 

managing fire blight without antibiotics to the extent possible. 

Committee Recommendation 

The Crops Committee recommends the continued listing of streptomycin as follows: 

§205.601 Synthetic substances allowed for use in organic crop production. 

(i) As plant disease control.

(10) Streptomycin, for fire blight control in apples and pears for post-infection 

use, only until October 21, 2014.

Committee Vote 

Motion: Jay Feldman Second: Tina Ellor 

Yes: 0 No: 5 Absent: 2 Abstain: 0 Recuse: 0