ssawg omri presentation

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

[email protected]

(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



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



◊ 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

§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


synthetics on 205.603 and


and supplements

Prohibits the use of animal drugs and

hormones to promote growth; feed

plastic pellets for roughage, feed

formulas containing urea or manure




and supplements





Prohibits mammalian or poultry slaughter

by-products; antibiotics including

ionophores




and supplements







ionophores

Prohibits the use of feed, feed additives,

and feed supplements in

violation of the FD&C Act




and supplements







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




pesticides


and production aids


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






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






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




pesticides


and production aids


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




pesticides


and production aids


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