Organic 101: Permitted and prohibited substances

Posted by Miles McEvoy, National Organic Program Director in Food and Nutrition Research and Science

October 27, 2020

The basic rule for organic farming is to allow natural substances and prohibit synthetic ones. For farm animals like these healthy cows, however, vaccines play an important role in animal health – especially since antibiotic therapy is prohibited. (Courtesy photo of Pleasantview Farm, an Ohio-certified organic dairy farm)

This is the second installment in the Organic 101 series that explores various aspects of USDA organic regulations.

Organic standards should allow natural substances in organic farming and prohibit synthetic substances. Exceptions to this basic rule are listed in the national list of permitted and prohibited substances as part of the organic guidelines.

The National Organic Standards Board (NOSB) is legally mandated to advise the National Organic Program (NOP) on which substances should be allowed or prohibited. The board consists of dedicated public volunteers appointed by the Minister of Agriculture. Board members include organic farmers, traders, retailers, environmentalists, scientists, USDA-accredited certification bodies, and consumer advocates.

NOSB members must use certain criteria when voting, including the necessity of the substance and its effects on human health and the environment. In certain cases, the NOSB also votes in favor of allowing non-organic versions of a substance if it is not available in organic form on a scale that is large enough to support organic farming.

Some synthetic substances are listed as exceptions to the basic rule and may be used in organic farming. For example, pheromones have long been used as a powerful, non-toxic means to “confuse” insects that might otherwise attack organic plants, especially fruit. Vaccines for animals are also important instruments for disease prevention against many infectious diseases, especially since antibiotic therapy is prohibited in organic farm animals.

The National List also allows certain processing aids, such as baking powder. This substance brightens (or acidifies) the batter for organic pancakes, baked goods and other products.

Conversely, some substances such as strychnine and arsenic are examples of natural toxins that are prohibited in organic farming.

The process of adding or removing allowed substances is an open process that allows direct input from the eco-community. The process usually goes as follows:

  1. A person or organization files a formal petition to add, remove, or change the listing for a specific substance.
  2. The subcommittee of the NOSB is considering the petition. A third party technical report is often used to gather scientific information about the substance and identify negative effects on human health or the environment.
  3. The NOSB subcommittee publishes a proposed recommendation for the substance with a request for public comments prior to a public meeting, which usually takes place twice a year.
  4. During the meeting, the NOSB discusses the public comments on the petition and then votes in a public forum. All NOSB sessions are free and public.
  5. The NOP reviews the recommendation of the NOSB. The NOP can reject the NOSB’s recommendation to include a substance in the National List, but not a substance that has not been recommended by the NOSB.
  6. If the NOP agrees with the recommendation of the NOSB, it initiates a regulation to change the national list for this substance.

During this process, the NOSB spends countless hours discussing the range of perspectives on each substance it studies. The public comment process plays an important role in ensuring that all perspectives are thoroughly considered.

Since this citizens’ council represents all important sectors of the organic community, the recommendations of the NOSB give the NOP an invaluable insight into which substances should be allowed or prohibited in organic farming. The NOP invites the public to participate in this process as we shape the future of organic farming.

Category / Topic:
Food and nutrition research and science

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