Ssawg omri presentation

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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

dougc@omri.org

(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?

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

Application Kits

Application Specialist:Tara Sistrunk

taras@omri.org541-343-7600 (x105)

Questions? Feedback?• We’re here to help!• Email info@omri.org

Input Review Gold Standard

Certifiers

NOP

Farmers/Processors

Manufacturers

Consumers