The following comments were presented before the National Organic Standards Board at their October 2010 meeting in Madison, WI. To learn more and take action, please go to our Safeguard Organic Standards campaign page.

I'm Alexis Baden-Mayer, here on behalf of the Organic Consumers Association and the 900,000 organic consumer activists who have worked with us over the last dozen years to keep organic standards strong.

On behalf of our 250,000 current e-activists and our 118,000 Facebook activists, I'm here to talk to you today about phasing out non-organic and synthetic ingredients, keeping nanotechnology out of organic, and the importance of animal welfare, especially stocking densities and outdoor access for organic poultry.

NANOTECHNOLOGY

Over 13,000 Organic Consumers Association activists submitted comments to you about the importance of keeping nanotechnology out of organic.

Nanotechnology is already being use in food, without being safety tested or labeled or regulated. Very little is known about the health and environmental effects of current commercial applications of food nanotechnology, but the dangers are beginning to be exposed.

Nano-silver is a powerful biocide that kills beneficial, as well as harmful, bacteria, and is toxic to fish.

Nano-gold decreases earthworms' reproductive capacity by 90%.

Titanium dioxide nano particles cause DNA damage in mice.

If you sincerely agree with consumers that nanotechnology should be excluded from organic, please do not pass the current committee recommendation.

The current committee recommendation simply states the status quo. It doesn't require any action of the NOSB or NOP to recognize that products of nanotechnology are synthetic, they're not allowed in organic, and if a company wants to use engineered nano materials in organic production, processing or packaging, they have to petition the NOSB for permission.

A year ago, there was a committee recommendation to ban nanotechnology from organic altogether. That's the only recommendation worth voting on.

But if it didn't pass, it wouldn't be the end of the world. Nanotechnology still isn't being used in organic and it isn't going to be, without specific engineered nano-materials being petitioned.

So, if you want to go ahead and do the right thing, ban nanotech from organic, but do not pass the current committee recommendation.

Before I close on the nanotechnology issue I want to refer you to the Center for Food Safety's comments on packaging. Nanotechnology is not allowed in organic packaging.

ANIMAL WELFARE

Over 11,000 Organic Consumers Association activists have submitted comments on the importance of animal welfare standards, in favor of phasing out synthetic methionine, and to enforce current regulations that require hens to be able to exhibit their natural behaviors and have meaningful year-round access to the outdoors. We will continue to submit comments in support of the Animal Welfare Discussion Document on Stocking Density. Please keep up the good work you've been doing on animal welfare. Now that the National Organic Program has put out a draft guidance on outdoor access for poultry, we're directing our comments to the NOP. We'd like to see a much stronger guidance. The NOP should implement the NOSB's recommendations as minimum standards that should guide the creation of organic system plans.

SULFITES IN ORGANIC WINE

So far, nearly 6,000 Organic Consumers Association activists have submitted comments opposing the petition to change the annotation on sulfites in organic wine. Please reject this petition. Currently, wine made with organic grapes and no added synthetic sulfites is "USDA Organic" while wine made with organic grapes with added sulfites is "Made With Organic." "USDA Organic" should continue to be reserved for sulfite-free wine. Wine makers are already getting a huge exemption to the general ban on sulfites. Sulfites are prohibited in organic along with genetic engineering, sewage sludge, and radiation. The wine exception for sulfites should not be expanded any further.

NON-ORGANIC INGREDIENTS

More than 4,000 Organic Consumers Association activists have sent letters in support of organic beer and bratwurst being made with organic hops and sausage casings. Please pass the recommendation on hops. The logic that was finally applied to hops should be applied to all agricultural products that are currently allowed in non-organic form. The commercial availability evaluation should require an investigation into whether the ingredient can be produced on a contract basis. It's time for companies to take responsibility for their supply chains. For example, imagine you're an organic sausage brand that is owned by the 3rd largest US beef and pork processor. Your certifier should be talking to you about contracting for the production of organic sausage casings. The National List sunsets every 5 years so that producers have 5 years to look for, contract for, or create ingredients in organic form.

Just a few more issues. The Organic Consumers Association would like to see the NOSB review each of the List 4 Inerts, we would like to see the Board pass the committee's corn steep liquor recommendation, we do not seek a change in the made with organic label, we oppose the use of non-organic or synthetic vitamins in organic food, and we continue to submit consumer comments to the NOP, urging it to implement last fall's NOSB recommendation for resolving the problem of mislabled organic personal care products. 12,331 Organic Consumers Association activists have sent letters to the USDA in support of that NOSB recommendation.