Meeting Summary: NOSB in Providence, RI

The National Organic Standards Board (NOSB) held its public meeting October 15-18, 2012, in Providence, Rhode 

Island. At the beginning, the NOP provided an update on its activities, priorities, and NOSB’s substance review process. 

Introductory presentations also highlighted the NOP’s 10th anniversary and the Organic Literacy Initiative. Over the 

course of four days, the NOSB heard comments from approximately 80 members of the public on a wide range of 

issues. The NOSB discussed these and other suggested changes to their proposals from about 700 written public 

comments. A summary of the NOSB’s subsequent votes is provided below. The final recommendations from the 

Providence meeting will be posted in the near future at www.ams.usda.gov/NOSBMeetings. 

Note: NOSB is an advisory body to the Secretary of Agriculture. NOSB recommendations are not NOP policy unless the NOP 

issues final rules, final guidance, final instructions, or a policy memorandum that adopts the NOSB recommendations. They 

are not part of the USDA organic regulations unless such action is taken.

Petitioned Substances. The NOSB responded to several petitions to amend the National List of Allowed and 

Prohibited Substances (National List). This section of the USDA organic regulations identifies exemptions to the 

following general rule: synthetic substances are prohibited unless specifically allowed and natural substances are 

allowed unless specifically prohibited. In organic processed products, all non-organic ingredients must be specifically 

allowed. “Motion failed” indicates that less than two thirds of the NOSB members voted to make the change in 

question, meaning that USDA does not have the authority to amend the USDA organic regulations for that substance. 

Substance Section Action Considered by NOSB NOSB Recommendation

Biodegradable 

Mulch Film

§ 205.601 Allow in organic crop production. Allow in organic crop production with 

restrictions. 

Ferric Phosphate § 205.601 Prohibit as slug/snail bait in organic 

crop production.

Motion failed.

Oxidized Lignite § 205.601 Allow as soil amendment in organic 

crop production.

Motion failed.

Propylene Glycol 

Monolaurate 

§ 205.601 Allow as acaricide in organic crop 

production.

Motion failed.

Sulfuric Acid § 205.601 Allow as a stabilizer for digested 

poultry manure in organic crop 

production.

Motion failed.

Rotenone § 205.602 Prohibit in organic crop production. 

Note: the NOSB took action on this 

substance without a petition to amend 

the National List.

Prohibit in organic crop production 

effective January 1, 2016.

Nonanoic Acid § 205.603 Allow as insecticide in organic 

livestock production.

Motion failed.

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Substance Section Action Considered by NOSB NOSB Recommendation

Ascorbyl Palmitate § 205.605(b) Allow as preservative in organic infant 

formula.

Motion failed.

Beta-Carotene § 205.605(b) Allow the synthetic form in organic 

infant formula.

Motion failed.

L-Carnitine § 205.605(b) Allow in organic infant formula. Motion failed.

L-Methionine § 205.605(b) Allow in infant formula made with 

soy-based protein.

Allow in infant formula made with soybased protein.

Lutein § 205.606 Allow in organic infant formula, listed 

at § 205.605(b)

Motion failed.

Lycopene § 205.605(b) Allow in organic infant formula. Motion failed.

Nucleotides § 205.605(b) Allow in organic infant formula. Motion failed.

Taurine § 205.605(b) Allow in organic infant formula. Motion failed.

Inerts in Pesticides. The NOSB recommended a procedure for reviewing all EPA List 4 and 3 inerts used in organicapproved pesticide formulations. The procedure includes details on regulatory language changes for the listing of 

inerts on the National List, how NOSB review will proceed by group, what proposed groups have been identified so 

far, how technical reviews will be commissioned, and the anticipated timeline for this project. The procedure also 

states that, given the resources and time needed to complete these reviews, the NOSB will reassess the timeline after 

reviewing the first few groups of inerts. 

2012 Research Priorities. The NOSB identified the top research priorities in organic agriculture, requesting that NOP 

coordinate with USDA research agencies to encourage funding awards in these areas.

NOSB Policy and Procedures Manual (PPM). The NOSB voted to change the public comment procedures in the 

PPM. The recommendation addresses the comment sign-up process, time allocation for comments, and how public 

comment delivery at the meeting should proceed. A second motion to amend the process by which the NOSB would 

receive public communication failed. A third proposal, addressing NOSB members’ conflict of interest, was withdrawn 

at the meeting prior to a vote. 

Discussion Documents. NOSB subcommittees published discussion documents with request for public comments:

Omnivore Diets. The USDA organic regulations currently prohibit feeding mammalian or poultry slaughter byproducts to mammals or poultry. The discussion document outlines some of the pros (e.g., potential reduction in 

use of synthetic methionine in organic poultry) and cons (e.g., consumer perception) of amending the regulations 

to allow omnivore diets. 

Other Ingredients. In November 2011, NOP requested that the NOSB clarify which “other ingredients” contained 

within handling materials on the National List are allowed. The discussion document outlines several approaches to 

meeting the NOP’s request.

Percent Organic. Certifiers verify the percentage of organic content in multi-ingredient organic products, ensuring 

they meet all criteria for the specific labeling category. Certifiers were asked for information on how they make this 

determination, which challenges they face, and how this process could be clarified to increase consistency.

Biodiversity. In May 2009, the NOSB recommended addressing biodiversity in organic systems, which would affect 

materials review and organic system plans. The discussion document summarized progress to date and asked for 

feedback on other potential ways to conserve biodiversity.

GMOs + Seed Purity. The use of genetically modified organisms (GMOs) is prohibited in the production and 

handling of organic products, including seeds. The discussion document requests comments on seed purity 

standards, presence of GMOs in seed, and testing.

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