cows in field


Dr. Jean Richardson

By Dr. Jean Richardson, Chair National Organic Standards Board

In May, by the time you read this article, the April NOSB Meeting in California will be over and the Origin of Livestock rule will have been published - any day now I am told. At the NOSB meeting in late April we will be voting on two petitioned substances of interest to dairy producers: Acidified Sodium Chlorite for use as a pre- and post-teat dip treatment (205.603 (a)) to provide an alternative to iodine based teat dips, and Zinc Sulfate for use as a footbath only (205.603(b)).

Proposed rules to implement the NOSB Animal Welfare recommendations are under development, and this week Secretary Vilsack stated in public that these will be starting departmental clearance this summer. This seems to be a clear signal of the Secretary’s support for this rule. A proposed organic animal welfare rule could be published later this year, and this would be an ideal time for you to review the document and voice your opinion.
So, today I will talk a bit about what substances on the National List will be coming up for Sunset vote at the October meeting, and the kind of input that the NOSB would like to hear from NODPA members this summer.

If you have been following the Sunset Review changes at all you will know that now all substances stay on the National List unless the full NOSB (with a two thirds majority) recommends removing the substance from the National List. Previously, all substances went off the National List unless the NOSB voted to add them back during the Five Year Review process. Thus you will see that in order to be sure that all substances under Five Year Review are reviewed by the FULL Board for vote at public meeting, after public comment at two public meetings, every material is brought forward from the respective subcommittee on a Motion to Remove. This also ensures that the organic community is on public notice that every Sunset material could potentially be removed. So, please pay attention and let us know how essential a particular substance is to your production.

When you are researching a particular substance you will see Motions to Remove and subcommittee votes and comments or questions during the initial public comment period, and more detailed notes for the second public meeting period and the second posting. This may seem a bit cumbersome, but it seems to be working well, and certainly we are getting plenty of public comment on substances much earlier in the Review process, rather than a scramble at the end, or right before vote.

In terms of numbers to be voted on at the October meeting in Vermont: Livestock will be presenting 42 substances for Sunset 2017 Review; Crops 43; and Handling 79. There will be substances of interest to NODPA members in all of these subcommittees.

The NOSB has done an enormous amount of research on all these substances and each of us is presently going through more than a thousand written public comments and awaiting further oral comment at the April meeting. The NOSB asked NOP for many Technical Reports in the last twelve months, and the NOP ensured that the money was available for these Technical Reports and they have been really helpful to us in this complex analysis. Each subcommittee is trying to analyze all this information and data to determine how likely or not that the NOSB will actually vote to remove a specific substance. These decisions are based on the 7 criteria in the Organic Food Production Act (OFPA). So if a substance is necessary to your operation it is really important to let the NOSB know, by sending in public comment.

Based on public comment submitted so far, it does not appear that any of the livestock materials will be recommended for removal from the List in October, with the exception of one or two parasiticides.


There are 3 parasiticides up for Sunset Review to be voted on in October:

Fenbenzadole, Ivermectin and Moxidectin

There is research which indicates that Ivermectin, a broad spectrum parasiticide, is toxic to dung beetles which are an integral part of pastureland ecology. Moxidectin is less toxic in pastures than Ivermectin, but somewhat worse for fish if it gets into water. In addition, both Ivermectin and Moxidectin are macrocyclic lactones, a type of antibiotic, and antibiotics are not allowed in organic agriculture. Thus it seems possible that both Moxidectin and Ivermectin may be removed from the National List in October (remember that I am not clairvoyant!).

It is reasonable to assume that Fenbenzadole will remain on the National List. However, questions have been raised over the last few years about the Withholding period.

Fenbenzadole is listed as follows:

205.603 Parasiticides - prohibited in slaughter stock, allowed in emergency treatment for dairy and breeder stock when organic system plan-approved preventive management does not prevent infestation. Milk or milk products from a treated animal cannot be labeled as provided for in subpart D of this part for 90-days following treatment. In breeder stock, treatment cannot occur during the last third of gestation if the progeny will be sold as organic and must not be used during the lactation period for breeder stock.

Fenbenzadole - only for use by or on the lawful written order of a licensed veterinarian

Public comment suggests that the annotation of a 90 day withholding period was not established based on any scientific data, and should probably be reduced to 14 days.
We also have public comment suggesting that wool from sheep should be able to be sold as organic even though the meat is not able to be sold as such.

Annotations are not done at Sunset, and thus if these issues are of concern to NODPA members, a separate petition could be filed this summer. Such a petition for an annotation to Fenbenzadole could perhaps be on the October agenda as separate from the
Sunset item if it is received soon. However, petitions can take a year or more, so I can’t promise we can make a recommendation this fall.

Research Priorities:

Each subcommittee develops research priorities each summer for recommendation to the NOP in the fall. Parasite prevention and control has been suggested as a research priority. The livestock subcommittee would welcome your observations, and experience in management techniques, herbal remedies, plant species combinations in pastures or other mechanisms that you have found effective in parasite prevention and control.

I know that when I am on farm walks or doing inspections, parasite control issues are a relatively common conversation. Some suggest we should be approaching parasite control in a manner similar to the approach in the Canadian Organic Standards. What do you think?
Finally, we have received public comment regarding the use of Nonylphenyl Ethoxylates (NPE’s) used in formulations of teat dips containing iodine. NPE’s act as surfactants in complexing iodine. NPE’s, even at very low levels, have a toxic effect on aquatic systems. Iodine (205.603(a) and (b)) comes up for Sunset Review and vote in October. There has been some suggestion that a petition may be submitted to the NOSB asking to limit use of iodine to those forms made without NPE’s. However it looks as though the dairy industry has already recognized the issues related to NPE’s, and the industry is already moving fast to address this concern. One certifier has informed us that, of the 104 teat dips that they have reviewed, 94 contain NPE’s. So, we would appreciate your comments on iodine.

Well, that’s all from me for today. If you have comments or questions you can contact me at home: 802-425-3733; or by e-mail: