Organic Concerns Everyone Should Be Talking About on Earth Day

7 Recommendations to the National Organic Standards Board to Improve Organic Farming and Food for April 2025

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What is the National Organic Standards Board?

The National Organic Standards Board (NOSB) is a Federal Advisory Board made up of 15 dedicated public volunteers from across the organic community. Established by the Organic Foods Production Act (OFPA) and governed by the Federal Advisory Committee Act (FACA), the NOSB considers and makes recommendations on a wide range of issues involving the production, handling, and processing of organic products. The NOSB also has special responsibilities related to the National List of Allowed and Prohibited Substances.

The NOSB generally meets twice per year at a public meeting to discuss the items on its work agenda, vote on proposals, and make recommendations to the U.S. Department of Agriculture (USDA) Secretary. The public is invited to participate.

A virtual meeting will be held April 29 – May 1, 2025, from 12:00PM to approximately 5:00PM Eastern Time (ET) each day. The deadline to submit written comments is 11:59PM ET, April 28, 2025.

GMO/Toxin Free USA’s Recommendations to the USDA and National Organic Standards Board (NOSB) April 2025

1. Place the entire class of PFAS chemicals on the National List of Prohibited Substances in Organic production, including Teflon and PTFE-coated equipment, lubricants, and cleaners in organic food prep and processing.
2. For Organic compost, strengthen the rules to prevent toxic chemicals, synthetic pesticides and GMO contamination.
3. Phase out the use of plastic mulch and tarps for growing.
4. Phase out the use of fluorinated (PFAS-coated) HDPE plastic containers and packaging.
5. Phase out the use of all petrochemical-based plastic containers and packaging for retail.
6. Require a separate certification label for hydroponics.
7. Prohibit polluting CAFOs (Concentrated Animal Feeding Operations, also known as factory farms) from being certified Organic.

Implementing these recommendations would protect the health of Organic consumers and the wider environment, and bring the organic label closer to meeting the expectations of Organic consumers.

1. Place the entire class of PFAS chemicals on the National List of Prohibited Substances in Organic production, including Teflon and PTFE-coated equipment, lubricants, and cleaners in Organic food prep and processing.

Per- and polyfluoroalkyl chemicals (PFAS), a class of over 15,000 toxic substances that don’t break down, are increasingly becoming a public health crisis due to historical and current uses. Studies have linked PFAS to cancer, autoimmune disease, thyroid disease, liver damage, high blood pressure, obesity, hormone disruption, decreased immunity, decreased fertility, birth defects, and harmful developmental effects in infants.

PFAS contamination of Organic food and products can occur during the production of crops and animals, the storage of raw materials (leaching from fluorinated containers, addressed later), during manufacturing (from machinery and/or the products used to clean and lubricate), and/or from the final consumer packaging (leaching from plastic and paper products coated with PFAS).

In a 2023 pilot study, researchers found higher levels of PFAS in Organic kale than conventional kale. This is not only embarrassing, but undermines the integrity of the USDA Organic label.

A thorough investigation into all the modes by which PFAS can contaminate or leach into Organic foods and products must be performed. But regardless of the reasons for contamination, the entire class of PFAS chemicals should be prohibited in all potential areas of exposure under the National Organic Program (NOP) and placed on the National List of Prohibited Substances.

2. For Organic compost, strengthen the rules to prevent toxic chemicals, synthetic pesticides and GMO contamination.

(As per Beyond Pesticides) Compost made in Organic production should use plant and animal waste, and not synthetic materials that could introduce hazardous contaminants like PFAS and microplastics. The current regulations require compost to be made from manure and plant wastes, allowing only synthetics on the National List — that is, those that have specifically been approved by the NOSB and USDA through a public comment process. The only synthetic inputs into compost that are currently allowed are newspaper and other paper. A petition seeks to allow “compost feedstocks” that might include, for example, “compostable” food containers.

Both Organic and non-organic farms have been taken out of production because of PFAS contamination, and microplastics can have a synergistic effect with PFAS. Even worse are potential contaminants we don’t know. Current PFAS contamination came from past use of biosolids now known to be a source of “forever chemicals.” Biosolids — fortunately never allowed in Organic production—should be a lesson to remember. The NOSB must protect Organic production by denying the petition to allow synthetic “compostable materials.”

(As per GMO/Toxin Free USA) Additionally, there are concerns that certain inputs used for certified Organic compost are not Organic and pose contamination risks. For example, animal manure can come from conventionally raised animals that eat pesticide-laced GMOs, risking contamination in the final Organic compost product. There should be required testing by Organic compost producers to assure that substances on the National List of Prohibited Substances, and dangerous substances not on the List, such as PFAS chemicals, are not present in the marketed product.

3. Phase out the use of plastic mulch and tarps for growing.

Plastic mulch and tarps are often used by growers for multiple reasons: To cover crop row walkways and crop beds, preventing the spread of weeds, to help control soil temperature and moisture, and to cover fallow land, preventing soil erosion, just to name a few. This has provided a convenience to growers.

But the research indicates that it’s time to move away from these products, as plastic mulches and tarps release toxic chemicals, potentially including PFAS chemicals, phthalates and other endocrine disruptors, and microplastics into the soil that are potentially take up by the plants grown there. Most of these plastic products are considered single-use and are not recyclable, further polluting the planet.

According to the FAO, “Soils are one of the main receptors of agricultural plastics and are known to contain larger quantities of microplastics than oceans.” The FAO also stated, “In 2019, agricultural value chains used 12.5 million tonnes of plastic products in plant and animal production and 37.3 million tonnes in food packaging. The crop production and livestock sectors are the largest users, accounting for 10 million tonnes per year collectively, followed by fisheries and aquaculture with 2.1 million tonnes, and forestry with 0.2 million tonnes.”

A December 2020 review study published in the journal Chemosphere shows that crops can uptake PFAS chemicals from the soil, with root uptake being the predominant pathway for the accumulation of PFAS in agricultural crops. The contaminated crops become a direct and potentially significant route of exposure to humans and animals eating the crops.

Like all plastic products, microplastic pollution is a problem with plastic mulches and tarps. A May 2020 study published in the journal Environmental Pollution stated that “The abundances of microplastic particles increased over time in the locations where plastic mulching was continuously employed… Fourier transform infrared analyses revealed that the composition of the microplastics matched that of the mulching films, suggesting the microplastic particles originated from the mulching films. These findings confirm that plastic mulching is an important source of macroplastic and microplastic contamination in terrestrial environments.”

And possibly most alarming is that, in addition to PFAS, plants can also uptake microplastics through their roots, according to a July 2020 study published in the journal Nature Sustainability, exposing humans and animals to the microplastics and the toxic chemicals they release. An August 2020 study published in the journal Environmental Research showed that microplastics are, in fact, in the vegetables and fruit we all eat. The study found microplastics in the foods tested (carrots, lettuce, broccoli, potatoes, apples and pears), with the highest contamination levels found in carrots and shockingly, apples.

We recommend that plastic mulches and tarps be prohibited in certified Organic operations.

4. Phase out the use of fluorinated (PFAS-coated) HDPE plastic containers and packaging.

A March 2023 study published in the journal Environmental Science & Technology Letters found that fluorinated high-density polyethylene (HDPE) plastic containers contain PFAS, including the highly toxic perfluorooctanoic acid (PFOA) as detected in ketchup, mustard and mayonnaise tested.

The study stated: “In all experiments, short-chain perfluoroalkyl carboxylic acids (PFCAs) were detected in the highest frequencies and concentrations with analyte concentration decreasing as chain length increased. An estimate for PFAS released into food ranged from 0.77 to 2.68 ng/kg body weight per week, showing ingestion of food stored in these containers could be a significant source of exposure.”

“Not only did we measure significant concentrations of PFAS in these containers, we can estimate the PFAS that were leaching off creating a direct path of exposure,” said Graham Peaslee, professor of physics in the Department of Physics and Astronomy at Notre Dame and an author of the study. “We measured concentrations of PFOA that significantly exceeded the limit set by the EPA’s 2022 Health Advisory Limits,” said Peaslee. “Now, consider that not only do we know that the chemicals are migrating into the substances stored in them, but that the containers themselves work their way back into the environment through landfills. PFAS doesn’t biodegrade. It doesn’t go away. Once these chemicals are used, they get into the groundwater, they get into our biological systems, and they cause significant health problems.”

Fluorinated plastic containers, whether used for storage and manufacturing or used for consumer packaging, must be prohibited to protect the health of Organic consumers and the environment.

5. Phase out the use of all petrochemical-based plastic containers and packaging for retail.

Research shows that plastic breaks down into microplastics and nanoplastics, contaminating food and drinks. When plastics are exposed to liquids, they can shed even more.

An April 2022 study published in the journal Environmental Science and Technology found that all plastics tested released nanoplastics. The authors chose to focus the study on two types of plastic: “food-grade” nylon bags and coffee cups lined with low-density polyethylene. They found that the materials released more nanoplastics as the water temperature rose, up to trillions of fragments.

Virgin plastics are bad. Recycled plastic is even worse.

A May 2022 study published in the Journal of Hazardous Materials found that widely-used PET recycled plastic bottles pass more toxic chemicals into their contents than virgin plastic bottles. They found that of the 150 toxic chemicals that leached into drinks from recycled plastic bottles, 18 were at levels exceeding regulations.

Concerning human and animal health…

An April 2021 study published in the Journal of Hazardous Materials found microplastics cause damage to human cells at the levels known to be consumed by people via contaminated food.

An April 2022 pilot study detected microplastics in the meat, milk and blood of farm animals.

A May 2022 study published in the journal Environment International found microplastics in human blood.

A June 2022 study published in the journal Polymers found microplastics in human breast milk.

A July 2022 study published in the journal Science of the Total Environment found microplastics in human lungs.

A March 2023 study published in the journal Nanomaterials found microplastics can breach the blood-brain barrier.

A July 2023 study published in the journal International Journal of Molecular Sciences found that microplastics infiltrated all systems of the body. The researchers found that plastic particles bioaccumulate in every organ. “The brain blood barrier is supposed to be very difficult to permeate. It is a protective mechanism against viruses and bacteria, yet these particles were able to get in there. It was actually deep in the brain tissue,” said Professor Jaime Ross, one of the study’s authors. The researchers found that the infiltration of microplastics was as widespread in the body as it is in the environment. They found that microplastic exposure induces both behavioral changes and alterations in immune markers in liver and brain tissues. The study mice began to move and behave peculiarly, exhibiting behaviors akin to dementia in humans. The results were even more profound in older animals. “To us, this was striking. These were not high doses of microplastics, but in only a short period of time, we saw these changes,” Ross said.

A February 2024 study published in the journal Toxicological Sciences found microplastics in all the placenta samples tested. Prof. Matthew Campen at the University of New Mexico who led the research, said: “If we are seeing effects on placentas, then all mammalian life on this planet could be impacted. That’s not good.”

And a May 2024 preprint study confirmed that microplastics bioaccumulated in human livers, kidneys and brains. Shockingly, the brain samples contained on average about 10 to 20 times more than the other organs. The researchers looked at 12 brain samples from people who had died with dementia, including Alzheimer’s disease. These brains contained up to 10 times more plastic by weight than healthy samples. The study also found the quantity of microplastics in brain samples from 2024 was about 50% higher from the total in samples that date to 2016, suggesting the concentration of microplastics found in human brains is rising at a similar rate to that found in the environment.

The groundbreaking report, Minderoo-Monaco Commission on Plastics and Human Health, published in March 2023 in the journal Annals of Global Health, makes it clear that a worldwide moratorium on single-use, fossil fuel-based plastics (produced from coal, oil and fracked gas) is necessary. The report concludes that plastic causes environmental damage and premature death at every stage of its life cycle, from production to use and disposal.

“These findings put us on an unequivocal path to demand the banning or severely restricting of unnecessary, avoidable, and problematic plastic items, many of which contain hazardous chemicals with links to horrific harm to people and the planet,” says report co-author, Dr. Sarah Dunlop.

Dr. Phillip Landrigan, epidemiologist and pediatrician, also a co-author, says: “Plastics are full of thousands upon thousands of really toxic chemicals. Some of them can cause cancer. Some of them can cause birth defects in babies. Some of them can cause brain damage. Some can disrupt the functioning of the endocrine system of the human body. And because plastic waste can contain all of these nasty materials, you can’t just recycle it and put it into food packaging.”

A September 2023 study, published in the journal JAMA Psychiatry, found pregnant women may experience a greater risk of postpartum depression when exposed to a specific class of chemicals known as phthalates — ubiquitous chemicals found in numerous personal care and plastic consumer products, including food packaging.

Microplastics and toxic chemicals go hand in hand. The two cannot be separated. And both are dangerous to human health.

Ongoing research by Adrift Lab has linked ingestion of plastics by seabirds to sublethal health effects. Their January 2023 study published in the Journal of Hazardous Materials found multi-organ damage in seabirds from ingesting microplastic fragments. A follow-up February 2023 study concluded that ingested plastic was causing scarring of the birds’ proventriculus, part of the digestive system, in a phenomenon they call “plasticosis.”

It is reasonable to expect that microplastics could be causing organ damage and scarring in humans. “In my view, plasticosis could be a sign that a new age of disease is upon us because of human overuse of plastics and other long-lasting contaminants, and their leakage into the environment,” writes Dr. Matt Savoca, a conservation biologist.

In light of the growing body of scientific evidence about plastics, the shedding of microplastics, and the toxic chemicals they leach under real-world use, we believe the organic sector should urgently research and identify alternatives.

There is no such thing as “food grade” plastic or “safe” plastic made from petrochemicals.

We recommend phasing out petrochemical-based plastics for the storage and packaging of food and consumer products such as cosmetics.

6. Require a separate certification label for hydroponics.

Hydroponic operations do not follow the National Organic Program requirement of stewarding the soil because hydroponic crops are not grown in healthy soil. Hydroponic operations use inputs such as sterile growing mediums in plastic containers and “proprietary” nutrient solutions. To make matters worse, some operations have been found to be using herbicides such as glyphosate-based Roundup in their operations.

Hydroponically-produced fruits and vegetables shouldn’t be allowed to be certified Organic at all. In fact, Canada and Europe prohibit hydroponic farms and products to be certified as Organic.

But if the USDA continues to allow this internationally rogue practice to continue, then Organic consumers have the right to know how their food is being produced.

And soil-based Organic farmers following the law deserve an even competitive playing field.

Hydroponic foods must be labeled in a way that clearly identifies the foods as being produced using hydroponic methods and not grown in soil. Packaging and labels should contain clearly visible text words such as “hydroponic product,” hydroponically produced,” or similar wording.

7. Prohibit polluting CAFOs (Concentrated Animal Feeding Operations, also known as factory farms) from being certified Organic.

Shoppers of Organic meats, eggs and dairy would not expect that those foods would come from factory farms.

Animals raised in CAFOs or in confinement situations are subjected to unnatural and cruel living conditions and practices. In most cases, animals such as cows, pigs and chickens are packed so tightly that they have no room to move. In dairy CAFOs, cows are not given enough space to lie down or are only allowed to roam within grassless lots. In pig CAFOs, pregnant sows are confined for their entire lives in gestation cages with no room to turn around. Chickens raised in CAFOs most often never see the light of day. These animals experience unnecessary pain and suffering from living in their own excrement, in horrid and filthy conditions.

CAFOs are also linked to the ill health of nearby residents and “are directly associated with the social and economic decline of rural communities,” according to the American Public Health Association. Additionally, CAFOs are responsible for massive air, water and environmental pollution that extends well beyond the areas where the CAFOs are sited. CAFOs are not sustainable.

Operations that fall under the USDA’s definition of a CAFO – an intensive animal feeding operation (AFO) in which over 1,000 animal units are confined for over 45 days a year – should be prohibited in Organic certification.