Key Materials Differences Between
National Organic Standards Board Recommendations
and the
National Organic Program Proposed Rule
 
Definition
NOSB
Recommendation
NOP Proposal
Comment
Active and Inert Recommended the NOSB work with manufacturers to obtain full disclosure of inerts, and to review synthetic inerts after the National List is proposed in the Federal Register. Proposes that inerts policy apply to all materials, and that all inerts, other than those on EPA List 1 be allowed. OFPA 2119(l)(2) (7 USC 6518(l)(2) requires the NOSB to work with manufacturers to ‘obtain a complete list of ingredients and determine whether such substances contain inert materials that are synthetically produced.’ The NOSB did not define active ingredient, but did not indicate that the terms ‘active’ and ‘inert’ extend beyond EPA registered pesticides.
Compost [R]efers to the carefully managed process in which carbon based materials are digested aerobically or anaerobically by microbial action. Farm compost made from crop residues, crop waste from food processing operations, animal manures, and other vegetative by-products are allowed. Green or yard waste compost from municipalities or private sources are allowed. Municipal solid waste compost and sewage sludge compost are prohibited. No prohibited materials may be added in composting (including synthetically ‘fortified’ compost starters) and all ingredients must be documented. [Plant / soil input.] Certifiers may evaluate the risk of prohibited materials residues remaining after composting. A process that creates conditions that facilitate the controlled decomposition of organic matter into a more stable and easily handled soil amendment or fertilizer, usually by piling, aerating and moistening; or the product of such a process. NOP definition does not prohibit any feedstocks. This allows for composts fortified with synthetic fertilizers and containing contaminated industrial waste. 

The preamble requests comments on sludge, but does not mention sludge or municipal solid waste in the text of the proposed rule. If sludge is considered ‘non-synthetic’ and the synthetic constituents of municipal solid waste are considered ‘inert ingredients’ or ‘non-active residues’ then MSW compost would also be permitted under these proposed standards.  

The NOP requests comment on manure management, particularly with respect to human health and food safety. Neither definition accounts for pathogen reduction.

Genetically Engineered (Proposed rule defines ‘Genetic Engineering’) Made with techniques that alter the molecular or cell biology of an organism by means that are not possible under natural conditions or processes. Genetic engineering includes recombinant DNA, cell fusion, micro- and macro-encapsulation, gene deletion and doubling, introducing a foreign gene, and changing the positions of genes. It shall not include breeding, conjugation, fermentation, hybridization, in-vitro fertilization or tissue culture. Genetic modification of organisms by recombinant DNA techniques. 

 

The NOSB definition includes techniques other than rDNA, and is also explicit in what is not included in the definition. The NOSB determined these organisms to be synthetic, and recommended that they be prohibited. The NOP is requesting comment on both whether or not they are synthetic, as well as whether or not they should be allowed in organic production, processing, and handling. 
 
This table prepared by the Organic Materials Review Institute. Email: omri@efn.org

Last Updated on 4/19/98
By Karen Lutz
Email: karen@hillnet.com