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Inerts in Mating Disruption Potentially De-listed – Opportunity to Comment

Posted by | April 1, 2021

The National Organic Standards Board is reviewing inert ingredients which if lost could make pheremone mating disruption not available for organic. Please see the communication below from the Northwest Hort Council to make comments due April 5.

The NOSB is considering sunset review of List 3 Inert Ingredients used in mating disruption dispensers. Without List 3 inerts, pheromone disruption may be lost for use in organic. There is also a petition being considered to allow use of Kasugamycin to treat fire blight, and sunset review of several sanitizers/disinfectants used in both crops and handling. There is a concerted effort by some advocacy groups with influence on the board to use this review process to reduce the number of sanitizers available to the organic industry. Therefore, communicating the importance of maintaining each of these sanitizers is important to maintaining access to them in the future.

We would like to encourage folks across industry to use this NHC draft as a template for written comments they develop to describe their particular operation. Writers should individualize their comments to their own operations, referencing how your farm or packinghouse uses each material, and provide a summary of what material is used at each stage of the process in order to give the NOSB a full picture of how various materials are needed by each operation. We also suggest that you still list the other possible uses (i.e. still mention that PAA may be used to treat dump tank water, even if you don’t use it in that manner) to support the continued availability of these products for those purposes in the future.

NHC comments for consideration by the NOSB at their April 2021 meeting can be found at this url: – scroll down to 2021 meeting information to the Click here for draft comments for consideration by the NOSB at their April 2021 meeting.’

While NHC will be submitting written comments in support of maintaining these products (and adding Kacugamycin to the National List) and staff will be providing oral testimony, the number of comments from growers and packers matters to the NOSB as they are considering renewal of these materials and comments from producers carry a lot of weight. This is why the NHC is encouraging organic growers and packers to submit their own written comments and consider signing up to provide a (virtual) three-minute statement via oral testimony.

Writers do not need to comment on every material or petition that the NHC commented on, just those of importance to their own operation, such as the potential loss of mating disruption should the NOSB vote to delist List 3 inert ingredients, or they could write in support of allowing the use of Kasugamycin in organic production.

In addition to List 3 inerts and Kasugamycin, materials up for sunset review by the NOSB include:

205.601 Sunsets: Synthetic substances allowed for use in organic crop production and handling (all except ozone, which is only under review for use in crops):

  • Ozone gas
  • Peracetic acid (§205.601(a)(6) & §205.601(i)(8))
  • EPA List 3 – Inerts of unknown toxicity
  • Chlorine materials
  • Calcium hypochlorite

(ii) Chlorine dioxide

(iii) Hypochlorous acid – generated from electrolyzed water

(iv) Sodium hypochlorite

  • 205.602 Sunsets: Nonsynthetic substances prohibited for use in organic crop production:
  • Calcium chloride


Oral Comments – 3 minutes
Oral comment registration is full, but we are told they will make every effort to hear your comments if you would like to be added to a waitlist. Do so by emailing by no later than April 16, 2021. The Board will hear oral comments during the following times via Zoom: Tuesday, April 20, and Thursday, April 22, 2021, from 12:00 – 5:00 p.m. Eastern


David Epstein, VP for Scientific Affairs

Northwest Horticultural Council

105 South 18th St, Suite 105

Yakima, WA 98901

Office (509) 453-3193

Mobile: (509) 654-3713

Washington State University