Chapter 3

Approved Materials for Organic Farming

The National List

In order to comply with USDA organic regulations, producers, processors, and handlers must use input materials and substances that are in compliance with the regulation. Both the active ingredients in a substance, as well as any inert or minor ingredients, must fully comply with USDA organic regulations to be used in or on organic crops, products, or sites. The “National List,” Sections 205.601-205.606 of the USDA organic regulations, outlines the substances that are allowed and prohibited for use in organic production and handling. An “input” is any material applied to a crop, including compost, pheromones, and any pesticides. The term “pesticide” refers to any agent used to kill a pest. The National List uses the word “substance” to include not only inputs to crops but also any materials used for other purposes, such as rodent baits. All substances are listed by the generic terms only (e.g., sodium bicarbonate), not by the brand name (e.g., Arm and Hammer baking soda). This avoids suggesting that any one brand is better than any other. Substances proposed for use in production, handling and processing are subject to a rigorous technical review process by the National Organic Standards Board (NOSB) to determine if the substance satisfies the legal criteria in the Organic Foods Production Act (OFPA) and Final Rule of the NOP. Amendments to the list are updated through a federal register process. In general, synthetic substances are prohibited unless specifically allowed and non-synthetic substances are allowed unless specifically prohibited.

Allowed and Prohibited Substances

The NOP Standards were implemented on October 21st, 2002. The United States Department of Agriculture (USDA) has sole regulatory authority over the organic standard. There is now only one organic certification standard for agricultural products sold in the United States. The USDA accredits organic certification agencies to ensure that they certify operations for compliance with this standard. Certification agencies and other materials reviewers check whether a material is compliant with this Standard.

Allowed Synthetic Materials

In general, products containing synthetic ingredients cannot be used for organic production, processing, or handling unless they are specifically allowed and appear on the National List. The NOP definition of synthetic is “a substance that is formulated or manufactured by a chemical process that chemically changes a substance extracted from naturally occurring plant, animal or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes.” Substances that are created as the “result of naturally occurring biological processes” are referred to as non-synthetic or natural. The NOP says producers cannot use products with synthetic ingredients for organic crop production, unless they are specifically allowed and appear on the National List.

Inert Ingredients

The allowed pesticides on the National List are called active ingredients when they are formulated into a commercial product. Even if the active ingredient in a pesticide is allowed, if an inert ingredient is not allowed, the pesticide may not be used in organic crop production. The U.S. Environmental Protection Agency provides four classifications of inert ingredients: List One, List Two, List Three, and List Four. At this time, only a small fraction of the inert ingredients on these lists is allowed in organic production.

Restrictions in Using Approved Substances

The National List divides substances into categories of use that include crop, animal, and processed products. Therefore, substances may be allowed for use in processing of organic foods but prohibited from use in crop and animal production. Several substances are listed with annotations that limit or restrict products to specific uses within each category. For example, hydrated lime may be used as an ingredient in Bordeaux mixture for disease management on fruit trees—when other preventative practices are not enough and its use is consistent with Rule section 205.206(e), but hydrated lime cannot be used as a soil amendment. In another example, copper sulfate may be used in crop production only in a manner that minimizes accumulation of copper in the soil. The National List does not provide a comprehensive generic list of products that can or cannot be used within an organic farming system. For example, it does not include natural substances and biological controls.

Organic System Plan

The organic system plan or farm plan is part of the application form and includes a list of materials used in production and handling. This list includes fertilizers, soil amendments, potting soil, crop production aids, and pest control materials used in crop production; and ingredients, processing aids, post-harvest handling substances, sanitizers, and facility pest control materials used in processing and handling. This plan is the basis of the record keeping system that is reviewed during the certification process. All inputs must be included in the farm plan; this is required under the NOP but also allows inputs to be reviewed by the certification agency before use.

Removing or Amending Ingredients on the National List

Any individual or organization may submit a petition to the National Organic Standards Board to add, remove or amend the listing of an ingredient. Only single ingredients may be petitioned for evaluation. The petition must address why a synthetic substance is necessary for production of an organic crop and impacts on the environment, human health or farm ecosystem from its use instead of a natural substance or alternative cultural methods. The NOP’s first step is determining if the substance is eligible for petition, including verification that U.S. EPA allows the agricultural use being requested.

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Within This Chapter: Approved Materials for Organic Farming