Organic 101: Allowed and Prohibited Substances

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

Organic standards are designed to allow natural substances in organic farming while prohibiting synthetic substances. The National List of Allowed and Prohibited Substances—a component of the organic standards—lists the exceptions to this basic rule.

NOTE: Reshared from the archives, still true today.

The National Organic Standards Board (NOSB) is designed by law to advise the National Organic Program (NOP) on which substances should be allowed or prohibited.  Made up of dedicated public volunteers appointed by the Secretary of Agriculture, board members include organic growers, handlers, retailers, environmentalists, scientists, USDA-accredited certifying agents and consumer advocates.

NOSB members must use specific criteria when voting, including the need for the substance and its impacts on human health and the environment.  In specific cases, the NOSB also votes to allow non-organic versions of a substance if it isn’t available in organic form on a scale large enough to support organic agriculture.

Some synthetic substances are listed as exceptions to the basic rule and are allowed for use in organic agriculture.  For instance, pheromones have long been used as an effective, non-toxic way to “confuse” insects that may otherwise infest organic crops, especially fruit. Likewise, vaccines for animals are important disease prevention tools against many infectious diseases, especially since antibiotic therapy is prohibited in organic livestock.

The National List also allows certain processing aids, such as baking soda. This substance lightens (or leavens) the dough for organic pancakes, baked goods, and other products.

Conversely, some substances like strychnine and arsenic are examples of natural toxic substances that are prohibited in organic production.

The process for adding or removing allowed substances is an open process, allowing for direct input from the organic community.  The process typically follows these steps:

1. An individual or organization submits a formal petition to add, remove, or change the listing for a specific substance.
2. NOSB sub-committee reviews the petition. A third-party technical report is often used to gather scientific information about the substance and to identify any negative impacts to human health or the environment.
3. The NOSB sub-committee publishes a proposed recommendation for the substance with request for public comments before a public meeting, typically held twice per year.
4. During the meeting, the NOSB discusses the public comments related to the petition and then votes in a public forum. All NOSB meetings are free and open to the public.
5. The NOP reviews the NOSB’s recommendation. The NOP can reject the NOSB’s recommendation to add a substance to the National List, but can’t add a substance that hasn’t been recommended by the NOSB.
6. If the NOP agrees with the NOSB’s recommendation, it initiates rulemaking to amend the National List for that substance.

Through this process the NOSB devotes countless hours to discussing the range of perspectives on each substance under their review. The public comment process plays an important role in ensuring that all perspectives are considered thoroughly.

Since this citizen advisory board represents all key sectors of the organic community, the NOSB’s recommendations provides the NOP with invaluable insight into which substances should be allowed or prohibited in organic agriculture. The NOP invites the public to participate in this process as we shape the future of organic agriculture.