United States Agricultural 1400 Independence Avenue, S.W. 

Agricultural Department of Marketing Room 2642-S, Mail Stop 0268

Marketing Agriculture Service Washington, D.C. 20250-0268

Service

 

June 25, 2018

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

FROM: Jennifer Tucker, Ph.D.

Deputy Administrator

National Organic Program (NOP)

SUBJECT: Response to National Organic Standards Board Recommendations (Spring 2018

Meeting)

Background

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

made at its meeting in Tucson, Arizona, April 25-27, 2018.

Summary of Recommendations and AMS Responses

1. Petitioned Substances and Related Recommendations. The NOSB recommended three

amendments 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 of Organic 

Regulations

NOSB Recommendation

Sulfur (as a molluscicide) Crops

§205.601

Classified as synthetic; 

recommended for addition to 

the National List

Polyoxin D zinc salt Crops

§205.601

Classified as synthetic; 

recommended for addition to 

the National List

Magnesium chloride 

reclassification

Handling

§205.605(b) (current)

§205.605(a) (recommended)

Re-classified as non-synthetic; 

recommended moving from 

§205.605(b) to §205.605(a)

AMS Response: AMS is reviewing the NOSB’s three National List recommendations listed

above.
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

Page 2

2. Inspector qualifications. The NOSB recommended that the National Organic Program 

develop minimum qualifications, continuing education guidelines, and training to ensure a 

professional and competent inspector pool to meet the demands of ever-evolving and 

complex organic supply chains.

AMS Response: In May 2018, AMS announced its action plan to strengthen the oversight 

and enforcement of organic products. To strengthen organic control systems, the action plan 

includes additional training for inspectors, specification of inspector qualifications, and 

specification of inspector training requirements. AMS is reviewing the NOSB’s 

recommendation as we work to strengthen certification and enforcement processes. View 

AMS’s announcement at: 

https://www.ams.usda.gov/sites/default/files/media/ActionUpdatePlanEnforcement.pdf

3. Emergency use of synthetic parasiticides in organic livestock production. The NOSB

recommended that the organic regulations be revised to clarify when synthetic parasiticides 

on the National List may be administered by organic livestock producers. Current organic 

regulations permit the use of these medications for emergency treatment. The NOSB 

recommended a definition for the term “emergency” and additional language to describe the 

required practices to prevent parasitic infection. 

AMS Response: AMS is reviewing the NOSB’s recommendation.

4. Conversion of native ecosystems for crop production. To prevent alteration of native 

ecosystems (as a means to circumvent the three-year transition required by USDA organic 

regulations) the NOSB recommended a new requirement to prohibit the conversion of sites 

that support native ecosystems to organic production within 10 years of conversion. The 

NOSB also recommended a definition of the term “native ecosystem.” 

AMS Response: AMS is reviewing the NOSB’s recommendation.

Summary

AMS acknowledges and sincerely appreciates the many hours NOSB members provided in 

developing its recommendations. AMS supports NOSB’s vital role in representing the diversity

of the organic community and ensuring organic integrity.