NOC Intern, Kennedy Gullatte, Reflects on the Sunset Process in Organic
What exactly is ‘Sunset’ in the organic regulatory system? The National Organic Standards Board (NOSB) must review every substance on the National List of Allowed and Prohibited Substances every five years to make sure it meets the appropriate criteria. This list determines what substances can and cannot be used towards anything organic (fertilizers, pesticides). This process is called “sunset review” and the NOSB’s deliberative process on materials happens every five years. As part of this deliberative process, the NOSB holds a discussion for each individual substance, relying on expert knowledge, input from public stakeholders, scientific knowledge, and any other relevant information.
This spring, I had the pleasure of being on the majority of the NOC NOSB Committee calls where I heard about the sunset review process. It was a lot of discussion, debate, and careful consideration for each substance. This upcoming fall is when the actual NOSB votes on each substance will take place. The sunset review is important for the overall safety of organics which translates to the quality of organic products we consume. NOSB has very specific criteria they consider when keeping something on the list. After careful deliberation, the list is then reviewed by the NOSB and renewed by the USDA (United States Department of Agriculture). NOSB uses three main criteria to determine if a substance should be allowed in organic:
If it is not harmful to human health or the environment;
If it is necessary to the production of the agricultural products because of the unavailability of wholly non synthetic substitute products; and
If it is consistent with organic crop production.
If a substance can make it through this evaluation, then it can be approved.
One example of a substance that is undergoing sunset review in 2022 is copper sulfate. The NOSB is giving careful consideration to whether this material should still be allowed in organic agriculture. As part of that deliberative process, the NOSB heard this spring from public stakeholders. There is rigorous debate on whether copper meets the criteria for inclusion in organic production. During the NOSB public comment period, one wine maker testified about the importance of copper sulfate to his operation. A representative from the Northwest Horticultural Council also spoke on how copper is important for fire blight, a destructive bacterial disease that affects orchards. But there were also other perspectives represented. One public commenter mentioned how copper is not as effective as zinc products and how copper builds up in the soil.
As part of the deliberative process, the NOSB is hearing from organic certifiers, environmental groups, and farmers about copper sulfate and about many other substances. This public testimony will inform the NOSB’s vote on these materials in the fall.
Kennedy Gullatte completed an internship with the National Organic Coalition in the spring of 2022. Her internship was focused on learning about the National Organic Standards Board and the public comment process. Ms. Gullatte is a graduate of Florida A&M University, class of 2022 with a degree in environmental studies. She has a dream of having a farm and wants to explore her options in the organic field.