The National Organic Program Must Evaluate Undisclosed “Inert” Ingredients Used in Organic Production

It is time for the U.S. Department of Agriculture (USDA) to follow through on its duty to assess individual “inert” ingredients used in organic production. In creating the original regulations for the National Organic Program (NOP), USDA—based on the recommendation of the National Organic Standards Board (NOSB)—decided to postpone the evaluation of so-called “inert” ingredients until active materials had been reviewed for the National List of Allowed and Prohibited Substances. In this context, “inert” is a misleading legal term since the ingredient may be chemically or biologically active, but not included for purposes of attacking a target organism. The first regulation and all subsequent revisions have allowed the use of “inert” ingredients on EPA’s former Lists 4A (“minimal risk inert ingredients”) and 4B (“other ingredients for which EPA has sufficient information to reasonably conclude that the current use pattern in pesticide products will not adversely affect public health or the environment”).