Oregon Tilth published comments for the National Organic Standards Board’s fall 2020 meeting. 

Here’s a quick summary with links to our public comments:

Marine Macroalgae in Crop Fertility Inputs
The subcommittee’s proposal to revise the standards will protect marine habitats and ensure the sustainable harvest of marine materials for crop farming. Oregon Tilth requested the following considerations:

• Simplify the technical language for clarity and understanding by the public and manufacturers.
• Expand the definition of “fish waste” to prevent native species’ harvesting for fertilizer production.
• Clarify how certifiers verify that fertility products do not come from prohibited harvest areas or use banned methods.

Paper-based Crop Planting Aids (“Paper Pots”) and Wild, Native Fish for Fertilizer Production
The paper pots proposal does not clarify how to assess cellulose and biobased content when not using lab tests. Oregon Tilth requested the following considerations:

• Define cellulose and biobased content, using or similar to the identification from the July 2019 Technical Review of Paper Pots and Containers (i.e., wood, bamboo, reeds, jute, sugarcane bagasse, etc.).
• Clarify and align (if allowed) antimicrobials used to inhibit paper degradation with other areas of the standards.
• Establish the threshold for biobased content (80 percent) to prevent the use of planting aids from petroleum sources. 

The proposed revision for liquid fish fertilizers ensures organic agriculture protects marine ecosystems and the environment. Oregon Tilth believes this revision is one small step of many more, and even stronger, revisions to the organic standard that will protect our planet’s intricately linked biodiversity.

2020 Sunset Materials
Oregon Tilth provided data on usage of materials under consideration for removal from the National List in handling production. 

View Oregon Tilth’s Public Comments