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Now That You’re Organic, What Products and Materials Can
You Use?
The Organic Materials Review Institute (OMRI)
Who am I? • Product Review Coordinator, 2 years in March
• Background in Organic Farming Systems and Organic Principles
• Responsibilities at OMRI: Product Review and Recommendations
Doug Currier
(541) 343-7600 ext. 113
OMRI is a 501(c)(3) nonprofit that reviews input materials such as fertilizers, feed additives and processing aids to determine compliance with the National Organic Standards.
Session Outline• 45 min: A). Setting the Stage- defining key terms
B). A look at Allowed, Restricted
and Prohibited materials for Organic crop, livestock and processing production.
• 15 min: Q and A
• 30 min: Label and Material Review on the farm and More about OMRI and how we can help!
Acronyms Used Today • NOP: National Organic
Program • NOSB: National Organic
Standards Board• ACA: Accredited
Certifying Agents• GML: Generic Materials
List• OPL: OMRI Products List
Determining Compliance
• Compliance starts with producer-learn which types of materials are compliant. Certifier have final say!
• ACAs conduct material review and determine compliance on an individual operation by operation basis.
• OMRI is an independent review organization, not an ACA
• Publish GML and OPL to communicate our recommendations and products list to certifiers, producers and other interested parties
• Certifier has final say!
• NOP Rule: The National Organic Standards define and outline which materials are allowed or prohibited.
• NOP issues Guidances that help to clarify the use of materials.
NOP
Material Review Organizations• No current NOP oversight of MROs
• The NOSB has recommended (May 2012) to the NOP a set of criteria to evaluate the competency and quality of MROs.
• The goal is to outline review criteria that all MROs must meet. Similar to ACAs.
Bird’s eye view first
Nonsynthetic and Synthetic Materials
• In general nonsynthetic materials are allowed and synthetic materials are prohibited.
• Exceptions are the Allowed synthetics listed in the NOP Rule
• Synthetic: A substance that is formulated or manufactured by a chemical process or by a 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 occurring biological processes.processes.
Synthetic Materials
Microbial products
•Examples being salts, materials relying on a reaction for production, most things made in a lab!
• Nonsynthetic (natural): A substance that is derived from mineral, plant, or animal matter and does not undergo a synthetic process
• Examples: mined minerals, botanical extracts, fish products (not stabilized), microbial products, citric acid.
Allowed Synthetics• §205.601 –Crops
• §205.603 –Livestock
• §205.605(b) --Processing
The listing of a synthetic material is often annotated restricting its use and how its manufactured
Many blanket restrictions apply to these materials (e.g. pesticide restriction)
All synthetic materials have a “Sunset” date
Synthetic/Nonsynthetic Classifications
Limestone (CaCO3)
Limestone (CaCO3)
• Synthetics not specifically on the National List - §205.601, 603 or 605(b)
• Prohibited nonsynthetics on the National List - §205.602 and 604
• Nonagricultural substances used in or on processed products, except those listed at §205.605
• Nonorganic agricultural substances used in or on processed products, except those listed at §205.606
• Products containing significant levels of heavy metals or pathogens.
• Products made from excluded methods such as sewage sludge (biosolids), genetic modification, irradiation.
Prohibited Substances
General Analysis
3. Does the manufacturing process make the product synthetic?
Is the ingredient syntheticon the National List or
Nonsynthetic?
2. Does the ingredient manufacturing
process make it synthetic?
Is the ingredient on the National List?
1. Are there ingredients within ingredients?
Go to #2
Is it present in final product?
Go to #3
Prohibit
Is it on the National List?
Prohibit
Allow Restriction?
Yes
No
Yes
No
No
NoNo
Yes
Yes
Yes
Yes
YesNo
Prohibit
Go to #2
Synthetic vs.
NonsyntheticDecision
Tree
Now a worm’s eye view
Crop Input Materials
• Crop Pesticides – OMRI Class CP
• Crop Fertilizers and Soil Amendments– OMRI Class CF
• Crop Tools- OMRI Class CT
205.601 Allowed Synthetics
Understanding Pesticides• Products sold in US with
pesticide claims on the label must be EPA registered or exempt from registration under “Section 25B.”
• Not all exempt products are compliant with the National Organic Program Rule (but most are).
All Pesticides
soldin the US
25Bexempt
products
EPARegisteredproducts
Crop Pesticides
Preventative measures
-Sound rotation -Mulching
-Variety choice -Habitat creation
-Use of beneficial -Lures, Traps, Repellents
Insects (e.g. botanical pesticides)
All pesticide products for use in Organic Production are restricted - §205.206* Must use practices to prevent crop pests, weeds and disease
NOP Compliant Pesticides
Registered Pesticides25(b) pesticides
What about home brew? (pesticides that is)
Crop Input Materials• Crop Pesticides – OMRI Class CP
• Crop Fertilizers and Soil Amendments– OMRI Class CF
• Crop Tools- OMRI Class CT
NOP Rule §205.203-Soil Fertility…Crop Nutrient
Days to Harvest Rule
Establishes Compost
Production Parameters
Allows for ash from plant and animal
materials…as long as not combined with prohibited
substances
Prohibits the use of plant and animal
materials that have been chemically
altered by manufacturing
process
Identifies management practices but also identifies allowed input materials
Top 5 Animal Ingredients
Bone MealBone Meal
Blood MealBlood Meal
Feather mealFeather meal
Bone and meat mealBone and meat meal Fish MealFish MealAllowed if not stabilized or fortified with prohibited materials
On-Farm Composting
• C:N ratio 25-40:1
• Turning requirements
• Temperature requirements
• Method requirements
Compost RecordsDate Temperature Turn
5/1/11 112 No
5/2/11 116 Yes
5/5/11 125 No
5/6/11 127 No
5/8/11 131 Yes
5/12/11 146 Yes
5/13/11 148 No
5/14/11 152 Yes
§205.602-Prohibited Nonsynthetics
Tobacco Dust Arsenic Lead Salts
Ash from Manure Burning
Crop Input Materials
• Crop Pesticides – OMRI Class CP
• Crop Fertilizers and Soil Amendments– OMRI Class CF
• Crop Tools- OMRI Class CT
◊ Many of these materials are nonsynthetic and allowed◊ Not used as plant or soil nutrient◊ Aid in crop production
Coconut Coir
Citric Acid
Adjuvants: increase effectiveness of fertilizers and pesticides
Compliant Inputs for Organic Livestock Production
Livestock Inputs
Livestock Feed Ingredients
Livestock Health Care
Livestock external parasiticides and
pesticides
Livestock management tools
and production aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide
Livestock Inputs
Livestock Feed Ingredients
Livestock Health Care
Livestock external parasiticides and
pesticides
Livestock management tools
and production aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide
§205.237 Livestock Feed
DefinitionsFeed additive.
A substance added to feed in micro quantities to fulfill a specific nutritional need; i.e., essential nutrients in the form of amino
acids, vitamins, and minerals.
Feed supplement. A combination of feed nutrients added to
livestock feed to improve the nutrient balance or performance of the total ration
and intended to be:(1) Diluted with other feeds when fed to
livestock;(2) Offered free choice with other parts of
the ration if separately available; or(3) Further diluted and mixed to produce a
complete feed.
FEED: any article that is intended to be
used as an animal feed ingredient, to become part of an
ingredient or feed, or added to an animal's
drinking water is considered a "food" and thus, is subject
to regulation.
205.237 Livestock FeedEstablishes
synthetics on §205.603 and
nonsynthetics may be used as additives
and supplements
205.237 Livestock FeedEstablishes
synthetics on 205.603 and
nonsynthetics may be used as additives
and supplements
Prohibits the use of animal drugs and
hormones to promote growth; feed
plastic pellets for roughage, feed
formulas containing urea or manure
205.237 Livestock FeedEstablishes
synthetics on 205.603 and
nonsynthetics may be used as additives
and supplements
Prohibits the use of animal drugs and
hormones to promote growth; feed
plastic pellets for roughage, feed
formulas containing urea or manure
Prohibits mammalian or poultry slaughter
by-products; antibiotics including
ionophores
205.237 Livestock FeedEstablishes
synthetics on 205.603 and
nonsynthetics may be used as additives
and supplements
Prohibits the use of animal drugs and
hormones to promote growth; feed
plastic pellets for roughage, feed
formulas containing urea or manure
Prohibits mammalian or poultry slaughter
by-products; antibiotics including
ionophores
Prohibits the use of feed, feed additives,
and feed supplements in
violation of the FD&C Act
205.237 Livestock FeedEstablishes
synthetics on 205.603 and
nonsynthetics may be used as additives
and supplements
Prohibits the use of animal drugs and
hormones to promote growth; feed
plastic pellets for roughage, feed
formulas containing urea or manure
Prohibits mammalian or poultry slaughter
by-products; antibiotics including
ionophores
Prohibits the use of feed, feed additives,
and feed supplements in
violation of the FD&C Act
205.237 Livestock FeedEstablishes
synthetics on 205.603 and
nonsynthetics may be used as additives
and supplements
Prohibits the use of animal drugs and
hormones to promote growth; feed
plastic pellets for roughage, feed
formulas containing urea or manure
Prohibits mammalian or poultry slaughter
by-products; antibiotics including
ionophores
Prohibits the use of feed, feed additives,
and feed supplements in
violation of the FD&C Act
Producer must provide organic livestock with a total feed ration composed of agricultural products that are organically produced.
• Agricultural Products used as ingredients in livestock feed must be certified Organic.
• Examples of agricultural products in livestock feed products:
Carriers: sugar, whey powder
Feed Supplement: Garlic, Oregano oil
Agricultural Ingredients in Livestock Feed
Yeast• A manufacturer can produce a yeast
product that is certified organic to the NOP Rule.
• However, a livestock operation may provide non-organic yeast to livestock as a nonsynthetic and still retain organic certification.
• Reference NOP Guidance 5014
Allowed synthetics • Currently no allowed synthetic feed
supplements-§205.603(c)• Allowed synthetic feed additives are listed at
§205.603(d) and include:-DL-Methionine, DL-Methionine-hydroxy analog, and DL-Methionine-hydroxy analog calcium for use in organic poultry production. -Trace minerals, used for enrichment and fortification when FDA Approved-Vitamins, used for enrichment or fortification when FDA approved
205.237 Livestock Feed
The producer of an organic operation must not: provide
feed supplements or additives in amounts above those needed for adequate
nutrition and health maintenance for the species at its specific stage of life .
Livestock Inputs
Livestock Feed Ingredients
Livestock Health Care
Livestock external parasiticides and
pesticides
Livestock management tools
and production aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide
Livestock healthcare products• Includes animal drugs, internal
parasiticides, general use healthcare substances, internal and topical medications, and biologics.
Examples:Herbal PreparationsProbiotics-not routinely fedBotanicals-Udder creamsMagnesium Sulfate (Epsom Salts)-Hoof Baths
205.238 Livestock Health Care Standard
Establishes that producers must
maintain preventative
livestock healthcare practices which
includes the use of vaccines and
biologics
205.238 Livestock Health Care Standard
Establishes that producers must
maintain preventative
livestock healthcare practices which
includes the use of vaccines and
biologics
Prohibits the sale of livestock products
from animals treated with drugs in
absence of illness, hormones, synthetic
parasticides on routine basis and to
slaughter stock
205.238 Livestock Health Care Standard
Establishes that producers must
maintain preventative
livestock healthcare practices which
includes the use of vaccines and
biologics
Prohibits the administration of
drugs in violation of the FD&C Act
Prohibits the sale of livestock products
from animals treated with drugs in
absence of illness, hormones, synthetic
parasticides on routine basis and to
slaughter stock
GMO Vaccines• GMO vaccines are not legally allowed in
organic production. However, producers are not currently required to declare if they are using non-GMO vaccine.
• Current NOSB recommendation to NOP that GMO vaccines be allowed only in times of declared emergency without losing organic status.
Livestock Inputs
Livestock Feed Ingredients
Livestock Health Care
Livestock external parasiticides and
pesticides
Livestock management tools
and production aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide
External parasiticides and pesticides defined
• Pesticides used to manage ticks, flies and other external parasites and pests.
• Include pesticides used in barns, poultry houses and other livestock facilities.
• Includes nonsynthetics and allowed synthetics at §205.603.
Pyrethrums
Livestock Inputs
Livestock Feed Ingredients
Livestock Health Care
Livestock external parasiticides and
pesticides
Livestock management tools
and production aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide
Livestock management tools and production aids
• Materials that do not have a nutritional or direct health care function.
• Examples include facility cleaners, grooming aids.
• Materials used on animals or in their living areas
Diatomaceous Earth
Absorbent and Deodorizer
Lactic acid bacteria
Silage Inoculant
Glycerin
Livestock teat dip, must be produced through the hydrolysis of fats or oils
Chlorine Materials
Disinfecting livestock facilities and equipment.
Processing Inputs
Agricultural ingredients and processing aids
Nonagricultural ingredients and processing aids
Processing Sanitizers and
Cleaners
Processing pest controls
Container and packaging materials
Shellac, orange Unbleached Sulfur Dioxide Vitamin D3
Ethylene AbsorberSachetsAcetic Acid
Processing Certified Organic products for Human Consumption
• Processing aids and additives allowed for use in certified organic products
• Remember: 100% Organic- made entirely of certified organic ingredientsOrganic- 95% organic ingredientsMade with organic ingredients- containing a minimum of 70% organic ingredients
Processing Inputs
Agricultural ingredients and processing aids
Nonagricultural ingredients and processing aids
Processing Sanitizers and
Cleaners
Processing pest controls
Container and packaging materials
Shellac, orange Unbleached Sulfur Dioxide Vitamin D3
Ethylene AbsorberSachetsAcetic Acid
Agricultural ingredients and processing aids
• If processing food and fiber for certified Organic or made with organic ingredients
• Nonorganically produced agricultural products
• Closed list at §205.606, all materials carry commercial availability restriction
Orange, Shellac-unbleached
Gums—water extracted only (Arabic; Guar; Locust bean; and Carob bean).
Lecithin—de-oiled
Processing Inputs
Agricultural ingredients and processing aids
Nonagricultural ingredients and processing aids
Processing Sanitizers and
Cleaners
Processing pest controls
Container and packaging materials
Shellac, orange Unbleached Sulfur Dioxide Vitamin D3
Ethylene AbsorberSachetsAcetic Acid
Nonagricultural ingredients and processing aids
• If processing food and fiber for certified Organic or made with organic ingredients
• Closed list at §205.605(a) and (b)
• Some listings are annotated, restrictions apply
Potassium hydroxide prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches during the Individually Quick Frozen (IQF) production process
Potassium phosphate- for use only in agricultural products labeled “made with organic (specific ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.
Acids –pH adjuster(Alginic; Citric- produced by microbial fermentation of carbohydrate substances; and Lactic)
Calcium sulfate—mined*
*Usually from mined gypsum evaporate
Processing Inputs
Agricultural ingredients and processing aids
Nonagricultural ingredients and processing aids
Processing Sanitizers and
Cleaners
Processing pest controls
Container and packaging materials
Shellac, orange Unbleached Sulfur Dioxide Vitamin D3
Ethylene AbsorberSachetsAcetic Acid
Sanitizers/Cleaning Materials on The National List
1) Allowed to contact food through direct application.– Sodium Hydroxide
2) Allowed to contact food in wash and/or rinse water.– Peracetic Acid/Peroxyacetic Acid
3) Allowed to contact food in wash and/or rinse water but must be followed by a clear water rinse.– Chlorine Materials or Chlorine Dioxide
4) Allowed to contact food indirectly through use on food contact surfaces (no rinse required).– Peracetic Acid/Peroxyacetic Acid – Chlorine Materials or Chlorine Dioxide
Intervening Events• Rinse with cold/hot water
• Purge
• Drip dry
• Evaporation
Use of Chlorine MaterialsMax label rates w/o
Intervening event
Not to exceed SDWA
At label rates approved by FDA Or EPA followed by SDWA rinse
5) Nonpersistent materials. May be used on food contact surfaces, however an intervening event (such as a rinse or a purge) must take place to prevent the contact of residue with organic products.– Various Detergents, Sanitizers, and Cleaners
6) Persistent antimicrobials. Not Listed by OMRI. Must have thorough intervening event.– Quaternary ammonia products.
Sanitizers/Cleaning Materials NOT on The National List
These materials may NOT contact organic products
Processing Inputs
Agricultural ingredients and processing aids
Nonagricultural ingredients and processing aids
Processing Sanitizers and
Cleaners
Processing pest controls
Container and packaging materials
Shellac, orange Unbleached Sulfur Dioxide Vitamin D3
Ethylene AbsorberSachetsAcetic Acid
Processing Pest Controls are used to
A) Disinfest or prevent infestation of stored commodities
B) Prevent post harvest decay
C) Provide pest control in handling facilities
Examples: Traps, lures and repellents
These are environmental, mechanical or physical controls
• All Processing Pest Control materials are restricted. Producer must ensure they are meeting the facility pest management standard (§205.271)
• Producer must ensure all health and food safety laws are met
NOP RULEFederal Food Safety Laws
State and Local Food Safety Laws
Requirements of superseding laws do not provide exemption for use of prohibited materials!
• Many of these materials are EPA Registered Pesticides
• Producer can begin to ensure their compliance by:
A). Documenting preventative measures to address post-harvest pest control.
B). Look at the label for agricultural use
C). Work with certifier to determine if there should be prevention of pest control material with organic produce.
Processing Inputs
Agricultural ingredients and processing aids
Nonagricultural ingredients and processing aids
Processing Sanitizers and
Cleaners
Processing pest controls
Container and packaging materials
Shellac, orange Unbleached Sulfur Dioxide Vitamin D3
Ethylene AbsorberSachetsAcetic Acid
Packaging Materials
• May not contain synthetic fungicides, preservatives or fumigants.
• Ethylene filters- Used in post-harvest handling to extend shelf life of produce.
• Potassium Permanganate often used as ethylene absorbent.
• Potassium Permanganate is a prohibited synthetic so must not contact organic produce.
Q&A
Session Outline• 45 min: A). Setting the Stage- defining key terms
B). A look at Allowed, Restricted
and Prohibited materials for Organic crop, livestock and processing production.
• 15 min: Q and A
• 30 min: Label and Material Review on the farm and More about OMRI and how we can help!
Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Service
Determining Compliance
• Compliance starts with producer-learn which types of materials are compliant. Certifier have final say!
• ACAs conduct material review and determine compliance on an individual operation by operation basis.
Input Product Labels• A product can tell you about the product
and keep you compliant• Look at ingredients listed on label.
- Livestock feed material, is it formulated using agricultural ingredients? Certified organic?- Crop fertilizer, is there a prohibited synthetic micronutrient listed on label?- If on-site processing, does the label require a rinse step after using product?
Label review
Kelp Products—Synthetic Extraction• Limited to potassium or
sodium hydroxide solvent. Common to use potassium
carbonate
• Used as natural potash source
•Comes in liquid, powder and meal form.
•OMRI has been unable to determine threshold at
which fortification occurs
Notice lack of ingredient list—
potassium or sodium hydroxide do not appear on
label
Does application method matter?
Complexed = Chelated
Does soil deficiency need to be documented to add
sulfur?
Agricultural ingredients?
Oregano oil, organic?
Agricultural Product do not need to be Certified Organic in a Livestock Healthcare Product
Liquid detergent Product –Sodium Hypochlorite active ingredient
Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Service
OMRI Publications
• Generic substances and compliance standards for each substance
• Brand name products that have undergone and passed OMRI review
**Stop by the OMRI Booth for a free copy of each!**
Sample GML Entry
The Generic Materials ListCategory
Material entry that corresponds to
main ingredient or product function.
Also called “listing”
Class: One of 12 product
use types: CF, CP, CT
Status: Attribute that
describes compliance
Citation:Gives regulatory reference from
which compliance and annotation
was derived
ClassificationDescribes synthetic/
nonsynthetic classification
Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Services
-Companies that have their products reviewed and listed by OMRI may use the OMRI Seal.
-Seal communicates allowance for use in Organics.
Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Service
OMRI Services, cont.
Subscriptions -Retail, Certifier, Organization, Individual
Technical Expertise -Trainings
-Newsletter
-Contracts
Search for a product
Search for a material
Search for products listed in a specific OMRI Class
Questions? Feedback?• We’re here to help!• Email [email protected]
Input Review Gold Standard
Certifiers
NOP
Farmers/Processors
Manufacturers
Consumers