{"id":7286,"date":"2025-10-01T20:47:51","date_gmt":"2025-10-02T01:47:51","guid":{"rendered":"https:\/\/toxinfreeusa.org\/?p=7286"},"modified":"2025-10-02T13:34:24","modified_gmt":"2025-10-02T18:34:24","slug":"8-ways-to-vastly-improve-organic-food-and-consumer-products","status":"publish","type":"post","link":"https:\/\/toxinfreeusa.org\/8-ways-to-vastly-improve-organic-food-and-consumer-products\/","title":{"rendered":"Speak Up for Organic Standards That Truly Align With Consumer Values and Expectations"},"content":{"rendered":"\n

8 Recommendations to the National Organic Standards Board to Improve Organic Farming and Food \u2013 Fall 2025<\/p>\n\n\n\n

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IMPORTANT NOTE TO OUR SUPPORTERS: <\/strong>Something deeply troubling happened in September. The government blocked access to its public comment dockets by the third-party platform our nonprofit has long used to help you submit regulatory comments. For years, this tool allowed us to help thousands of people quickly and easily participate in the democratic process and ensure their voices were heard on critical issues. Now, that door has been slammed shut. The software vendor that provides our click-and-send tool is currently searching for a workaround. Until then, to submit your comment on a regulatory comment docket, you must copy and paste our suggested text and manually submit it using the link we\u2019ve provided. As always, you can send the suggested text as-is, but we encourage you to edit to make it your own. Your comment is more important than ever. We can\u2019t allow the government to silence our voices.<\/p>\n\n\n\n

8 Recommendations to the National Organic Standards Board to Improve Organic Farming and Food \u2013 Fall 2025 Meeting<\/strong>
<\/strong>
<\/strong>The public comment period closes at 11:59 PM Eastern Time on Wednesday, October 8, 2025. The pre-written comment text is <\/strong>below and in blue<\/strong>. Let the NOSB know why organic integrity is important for you.<\/strong>
<\/strong>
<\/strong>TAKE ACTION TODAY AND TELL THE NOSB TO ADDRESS THESE PRESSING ISSUES. <\/strong>Copy the suggested comment below and then paste and edit on the public comment docket <\/strong>CLICK HERE<\/strong><\/a> (or use this link <\/strong>https:\/\/www.regulations.gov\/commenton\/AMS-NOP-25-0034-0001<\/strong><\/a> )<\/strong>
<\/strong>
<\/strong>SUGGESTED PRE-WRITTEN COMMENT TEXT<\/strong><\/p>\n\n\n\n

\n

I purchase certified organic products because I want to reduce my exposure to toxic pesticides and other synthetic chemicals. I also expect those foods and products to be produced in ways that benefit the soil, do not harm wildlife, and do not pollute the environment.<\/p>\n\n\n\n

The body of scientific evidence of the harm caused by PFAS chemicals grows month after month. It\u2019s mind-boggling that this class of toxic chemicals is still allowed in organics. I should be able to expect that the organic foods and consumer products I buy do not contain these dangerous chemicals. PFAS chemicals must be banned in organic production.<\/p>\n\n\n\n

The overuse of petrochemical-based plastics in organic farming, and in retail, is very problematic and alternatives need to be developed quickly.<\/p>\n\n\n\n

A recent study proves that toxic microplastic particles are taken up by plants through the roots, and move into the edible vegetable tissues. Plastic tarps and mulches used extensively in organic farming are contaminating the soil with microplastics and synthetic chemicals, poisoning the crops which we then consume.<\/p>\n\n\n\n

Research also shows chemicals in plastic containers and packaging, including PFAS, BPA, phthalates and other endocrine-disrupting chemicals, leach into food and drink. Additionally, plastics break down into toxic microplastics and nanoplastics, further contaminating our food.<\/p>\n\n\n\n

I am urging the NOSB to implement the following:<\/p>\n\n\n\n

    \n
  1. Place the entire class of dangerous 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.<\/li>\n\n\n\n
  2. Strengthen the rules for organic compost production to prohibit the use of inputs from conventional agriculture such as manure and compost inputs which are contaminated with toxic chemicals, synthetic pesticides and GMOs to keep synthetics out of organic compost.<\/li>\n\n\n\n
  3. Research and develop non-toxic alternatives to phase out the use of plastic mulch and tarps for growing.<\/li>\n\n\n\n
  4. Prohibit the use of fluorinated (PFAS-coated) HDPE #2 plastic containers and packaging.<\/li>\n\n\n\n
  5. Prohibit the use of recycled plastic containers and packaging; research and develop non-toxic alternatives to phase out the use of all petrochemical-based plastic containers and packaging for retail.<\/li>\n\n\n\n
  6. Require a separate certification label for hydroponics.<\/li>\n\n\n\n
  7. Prohibit CAFOs (Concentrated Animal Feeding Operations, also known as factory farms, that raise animals in deplorable conditions and generate massive amounts of pollution) from being certified organic.<\/li>\n\n\n\n
  8. Prohibit synthetic hormones in organic milk production.<\/li>\n<\/ol>\n\n\n\n

    The organic sector has a duty to exclude harmful substances, materials and practices whenever sufficient evidence arises to prove harm. There is more than enough peer-reviewed science to show that PFAS chemicals and microplastics do not belong in organic food and products. Integrity is critically important.<\/p>\n\n\n\n

    Implementing the above actions would help organic shoppers like me to reduce my exposure to those dangerous toxins. Implementing these actions would bring the National Organic Program closer to what shoppers expect and pay a premium for.<\/p>\n\n\n\n

    The relevant research in support of the 8 recommendations in my comment can be found here: https:\/\/tinyurl.com\/8WaysToImproveOrganic<\/p>\n<\/div><\/div>\n\n\n\n\n\n

    BACKGROUND<\/strong><\/p>\n\n\n\n

    What is the National Organic Standards Board?<\/strong><\/p>\n\n\n\n

    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.<\/p>\n\n\n\n

    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.<\/p>\n\n\n\n

    The NOSB fall meeting will be held November 4\u20136, 2025. The deadline to submit written comments is 11:59PM ET, October 8, 2025.<\/p>\n\n\n\n

    What are the most pressing issues?<\/strong><\/p>\n\n\n\n

    For two years, we have focused on PFAS Forever Chemicals and toxic plastic contamination in organics as central issues, but the NOSB has failed to address either of them in a meaningful way. As organic stakeholders, we must make sure both of these very important issues are front row center and keep the pressure on.<\/p>\n\n\n\n

    Recommendations to the USDA and NOSB \u2013 Fall 2025<\/strong><\/p>\n\n\n\n

      \n
    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.<\/strong><\/li>\n\n\n\n
    2. Strengthen the rules for organic compost production to prohibit the use of inputs from conventional agriculture such as manure and compost inputs which are contaminated with toxic chemicals, synthetic pesticides and GMOs, to keep synthetics out of organic compost.<\/strong><\/li>\n\n\n\n
    3. Research and develop non-toxic alternatives to plastic mulch and tarps for growing with the goal of phasing out the use of plastic mulch.<\/strong><\/li>\n\n\n\n
    4. Prohibit the use of fluorinated (PFAS-coated) HDPE #2 plastic containers and packaging.<\/strong><\/li>\n\n\n\n
    5. Prohibit the use of recycled plastic containers and packaging. Research and develop non-toxic alternatives to petrochemical-based plastic containers and packaging with the goal of phasing out the use of plastic containers and packaging.<\/strong><\/li>\n\n\n\n
    6. Require a separate certification label for hydroponics.<\/strong><\/li>\n\n\n\n
    7. Prohibit CAFOs (Concentrated Animal Feeding Operations, also known as factory farms) from being certified organic.<\/strong><\/li>\n\n\n\n
    8. Prohibit synthetic hormones in organic milk production.<\/strong><\/li>\n<\/ol>\n\n\n\n

      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.<\/p>\n\n\n\n

      Support for these recommendations is as follows:<\/p>\n\n\n\n

        \n
      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.<\/strong><\/li>\n<\/ol>\n\n\n\n

        Per- and polyfluoroalkyl chemicals (PFAS)<\/a> are a class of over 15,000 toxic substances that don\u2019t break down naturally, earning the nickname \u201cForever Chemicals.\u201d These chemicals are increasingly causing a public health crisis due to cumulative historical and continuing use. 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.<\/p>\n\n\n\n

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

        In a 2023 pilot study<\/a>, researchers found higher levels of PFAS in organic kale than conventional kale. This is a black mark on organics and undermines the integrity of the USDA Organic label.<\/p>\n\n\n\n

        Research should be conducted to investigate all the modes by which PFAS can contaminate or leach into organic foods and products. But regardless of the sources of contamination, the entire class of PFAS chemicals should be prohibited in all potential areas of exposure under the National Organic Program (NOP). PFAS chemicals, as  a class, should be placed on the National List of Prohibited Substances.<\/p>\n\n\n\n

          \n
        1. Strengthen the rules for organic compost production to prohibit the use of inputs from conventional agriculture such as manure and compost inputs which are contaminated with toxic chemicals, synthetic pesticides and GMOs, to keep synthetics out of organic compost.<\/strong><\/li>\n<\/ol>\n\n\n\n

          (Per our friends at<\/em> Beyond Pesticides<\/em><\/a>) Support the proposal of the Crops Subcommittee (CS) to keep synthetic compostable materials out of organic compost. Compost from plant and animal materials is of fundamental importance to organic practices. Composting is one way that organic growers meet the requirement in law to \u201cfoster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.\u201d The integrity of organic production must be maintained by preserving the integrity of compost. Contaminants in broadly defined \u201ccompost feedstocks\u201d cannot be predicted, but history suggests that more persistent toxic pollutants will be found. The NOSB must maintain control over synthetic materials allowed in organic production, as required by the Organic Foods Production Act<\/em> (OFPA). Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. Only synthetic materials that are specifically added to the National List through the prescribed process should be allowed in compost destined to be an input into organic production. The NOSB should reopen the workplan item on contaminated inputs that is currently on hold.<\/p>\n\n\n\n

          (Per GMO\/Toxin Free USA<\/em>) Additionally, there are concerns that certain inputs used for certified organic compost do not come from certified organic sources and pose contamination risks. For example, animal manure can come from conventionally raised animals that eat GMOs laced with synthetic pesticides and are potentially contaminated by PFAS, 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.<\/p>\n\n\n\n

            \n
          1. Research and develop non-toxic alternatives to plastic mulch and tarps for growing with the goal of phasing out the use of these plastic products.<\/strong><\/li>\n<\/ol>\n\n\n\n

            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, for moisture retention, and to cover fallow land, preventing soil erosion, just to name a few. This has provided a convenience to growers.<\/p>\n\n\n\n

            But research indicates that it\u2019s time to stop using these products. Plastic mulches and tarps release toxic chemicals, potentially including PFAS, phthalates and other endocrine disruptors. These products also break down into microplastics and nanoplastics<\/a> (particles smaller than one micrometer in size) which are taken up by food crops through the roots. These plastic products are not recyclable, further polluting the planet.<\/p>\n\n\n\n

            According to the FAO<\/a>, \u201cSoils are one of the main receptors of agricultural plastics and are known to contain larger quantities of microplastics than oceans.\u201d The FAO also stated, \u201cIn 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.\u201d<\/p>\n\n\n\n

            A December 2020 review study<\/a> published in the journal Chemosphere<\/em> 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.<\/p>\n\n\n\n

            Like all plastic products, microplastic pollution is a problem with plastic mulches and tarps. A May 2020 study<\/a> published in the journal Environmental Pollution<\/em> stated that \u201cThe abundances of microplastic particles increased over time in the locations where plastic mulching was continuously employed\u2026 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.\u201d<\/p>\n\n\n\n

            Possibly most alarming is that plants can uptake plastic particles through their roots, according to a July 2020 study<\/a> published in the journal Nature Sustainability<\/em>, exposing humans and animals to the microplastics and the toxic chemicals they release. An August 2020 study<\/a> published in the journal Environmental Research<\/em> 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. And a new August 2025 study<\/a> published in the journal Environmental Research<\/em> confirms that nanoplastics can move from roots into edible vegetable tissues.<\/p>\n\n\n\n

            Research and development of non-toxic alternatives is urgently needed to phase out the use of plastic mulches and tarps in certified organic operations.<\/p>\n\n\n\n

              \n
            1. Prohibit the use of fluorinated (PFAS-coated) HDPE #2 plastic containers and packaging.<\/strong><\/li>\n<\/ol>\n\n\n\n

              A March 2023 study<\/a> published in the journal Environmental Science & Technology Letters<\/em> found that fluorinated high-density polyethylene (HDPE) #2 plastic containers contain PFAS, including the highly toxic perfluorooctanoic acid (PFOA) as detected in ketchup, mustard and mayonnaise tested.<\/p>\n\n\n\n

              The study stated: \u201cIn 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.\u201d<\/p>\n\n\n\n

              \u201cNot 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,\u201d said<\/a> Graham Peaslee, professor of physics in the Department of Physics and Astronomy at Notre Dame and an author of the study. \u201cWe measured concentrations of PFOA that significantly exceeded the limit set by the EPA\u2019s 2022 Health Advisory Limits,\u201d said Peaslee. \u201cNow, 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\u2019t biodegrade. It doesn\u2019t go away. Once these chemicals are used, they get into the groundwater, they get into our biological systems, and they cause significant health problems.\u201d<\/p>\n\n\n\n

              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.<\/p>\n\n\n\n

                \n
              1. Prohibit the use of recycled plastic containers and packaging. Research and develop non-toxic alternatives to petrochemical-based plastic containers and packaging with the goal of phasing out the use of these products.<\/strong><\/li>\n<\/ol>\n\n\n\n

                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.<\/p>\n\n\n\n

                An April 2022 study<\/a> published in the journal Environmental Science and Technology<\/em> found that all plastics tested released nanoplastics. The authors chose to focus the study on two types of plastic: \u201cfood-grade\u201d 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.<\/p>\n\n\n\n

                Virgin plastics are toxic. Recycled plastic is even more toxic.<\/p>\n\n\n\n

                A May 2022 study<\/a> published in the Journal of Hazardous Materials<\/em> 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.<\/p>\n\n\n\n

                Concerning human and animal health\u2026<\/p>\n\n\n\n

                An April 2021 study<\/a> published in the Journal of Hazardous Materials<\/em> found microplastics cause damage to human cells at the levels known to be consumed by people via contaminated food.<\/p>\n\n\n\n

                An April 2022 pilot study<\/a> detected microplastics in the meat, milk and blood of farm animals.<\/p>\n\n\n\n

                A May 2022 study<\/a> published in the journal Environment International<\/em> found microplastics in human blood.<\/p>\n\n\n\n

                A June 2022 study<\/a> published in the journal Polymers<\/em> found microplastics in human breast milk.<\/p>\n\n\n\n

                A July 2022 study<\/a> published in the journal Science of the Total Environment<\/em> found microplastics in human lungs.<\/p>\n\n\n\n

                A July 2023 study<\/a> published in the journal International Journal of Molecular Sciences<\/em> found that microplastics infiltrated all systems of the body. The researchers found that plastic particles bioaccumulate in every organ. \u201cThe 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,\u201d said Professor Jaime Ross, one of the study\u2019s 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. \u201cTo us, this was striking. These were not high doses of microplastics, but in only a short period of time, we saw these changes,\u201d Ross said.<\/p>\n\n\n\n

                A February 2024 study<\/a> published in the journal Toxicological Sciences<\/em> found microplastics in all the placenta samples tested. Prof. Matthew Campen at the University of New Mexico who led the research, said<\/a>: \u201cIf we are seeing effects on placentas, then all mammalian life on this planet could be impacted. That\u2019s not good.\u201d<\/p>\n\n\n\n

                And a May 2024 preprint study<\/a> 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\u2019s 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.<\/p>\n\n\n\n

                The groundbreaking report<\/a>, Minderoo-Monaco Commission on Plastics and Human Health, published in March 2023 in the journal Annals of Global Health<\/em>, 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.<\/p>\n\n\n\n

                \u201cThese 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,\u201d says report co-author, Dr. Sarah Dunlop.<\/p>\n\n\n\n

                Dr. Phillip Landrigan, epidemiologist and pediatrician, also a co-author, says<\/a>: \u201cPlastics 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\u2019t just recycle it and put it into food packaging.\u201d<\/p>\n\n\n\n

                A September 2023 study<\/a>, published in the journal JAMA Psychiatry<\/em>, found pregnant women may experience a greater risk of postpartum depression when exposed to a specific class of chemicals known as phthalates \u2014 ubiquitous chemicals found in numerous personal care and plastic consumer products, including food packaging.<\/p>\n\n\n\n

                Microplastics and toxic chemicals go hand in hand. The two cannot be separated. And both are dangerous to human health.<\/p>\n\n\n\n

                Ongoing research by Adrift Lab has linked ingestion of plastics by seabirds to sublethal health effects. Their January 2023 study<\/a> published in the Journal of Hazardous Materials<\/em> found multi-organ damage in seabirds from ingesting microplastic fragments. A follow-up February 2023 study<\/a> concluded that ingested plastic was causing scarring of the birds\u2019 proventriculus, part of the digestive system, in a phenomenon they call \u201cplasticosis.\u201d<\/p>\n\n\n\n

                It is reasonable to expect that microplastics could be causing organ damage and scarring in humans. \u201cIn 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,\u201d writes<\/a> Dr. Matt Savoca, a conservation biologist.<\/p>\n\n\n\n

                There is no such thing as \u201cfood grade\u201d plastic or \u201csafe\u201d plastic made from petrochemicals.<\/p>\n\n\n\n

                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.<\/p>\n\n\n\n

                Recycled plastics have been found to be many times more toxic than virgin plastics and should be banned immediately. Virgin petrochemical-based plastics for the storage and packaging of food and consumer products such as cosmetics should be phased out.<\/p>\n\n\n\n

                  \n
                1. Require a separate certification label for hydroponics.<\/strong><\/li>\n<\/ol>\n\n\n\n

                  Hydroponic operations do not follow the National Organic Program requirement of stewarding the soil because hydroponic crops are not grown in soil. Hydroponic operations use inputs such as sterile growing mediums in plastic containers that likely leach toxic chemicals, and \u201cproprietary\u201d nutrient solutions.<\/p>\n\n\n\n

                  To make matters worse, some operations have been found to be using herbicides such as glyphosate-based Roundup to manage weeds on facility property. Glyphosate is banned in organics, no matter how it is used. Why is the USDA turning a blind eye to the egregious and unacceptable practices used by hydroponic facilities?<\/p>\n\n\n\n

                  Hydroponically-produced fruits and vegetables shouldn\u2019t be allowed to be certified organic at all. In fact, Canada and Europe prohibit hydroponic farms and products from being certified as organic.<\/p>\n\n\n\n

                  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.<\/p>\n\n\n\n

                  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 \u201chydroponic product,\u201d \u201chydroponically produced,\u201d or similar wording.<\/p>\n\n\n\n

                    \n
                  1. Prohibit CAFOs (Concentrated Animal Feeding Operations, also known as factory farms) from being certified organic.<\/strong><\/li>\n<\/ol>\n\n\n\n

                    Shoppers of organic meats, eggs and dairy would not expect that those foods would come from factory farms.<\/p>\n\n\n\n

                    Animals raised in CAFOs or in extreme 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 barely have room to move. In dairy CAFOs, cows are not given enough space to lie down or are only allowed to roam within grassless lots. 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.<\/p>\n\n\n\n

                    CAFOs are also linked to the ill health of nearby communities and \u201care directly associated with the social and economic decline of rural communities,\u201d 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.<\/p>\n\n\n\n

                    Operations that fall under the USDA\u2019s definition of a CAFO \u2013 an intensive animal feeding operation in which over 1,000 animal units are confined for over 45 days a year \u2013 must be prohibited in organic certification.<\/p>\n\n\n\n

                    8. Prohibit synthetic hormones in organic milk production.<\/strong><\/p>\n\n\n\n

                    (Per Beyond Pesticides<\/em>) Oxytocin is available as a synthetic hormone and currently allowed in organic dairy production. A vague annotation has resulted in some producers using it inappropriately for milk letdown. Oxytocin is a hormone and, even if rarely used, it leaves organic dairy farmers open to valid criticism that they can still use hormones. For this reason, the two largest organic milk buyers in the U.S. did not support it remaining on the National List of Allowed and Prohibited Substances. Alternative treatments are available. The NOSB should allow oxytocin to sunset or be removed from the National List. If it remains on the National List, the NOSB should adopt the recommended annotation, \u201cuse in post parturition therapeutic applications within 3 days after birth. It may not be administered to increase an animal\u2019s milk production or for milk letdown.\u201d

                    The public comment period closes at 11:59 PM Eastern Time on Wednesday, October 8, 2025. The pre-written comment text is below and in blue. Let the NOSB know why organic integrity is important for you.

                    TAKE ACTION TODAY AND TELL THE NOSB TO ADDRESS THESE PRESSING ISSUES. Copy the suggested comment below and then paste and edit on the public comment docket <\/strong>                    CLICK HERE<\/strong><\/a> (or use this link <\/strong>https:\/\/www.regulations.gov\/commenton\/AMS-NOP-25-0034-0001<\/strong><\/a> )

                    SUGGESTED PRE-WRITTEN COMMENT TEXT<\/strong>
                    <\/p>\n\n\n\n

                    \n

                    I purchase certified organic products because I want to reduce my exposure to toxic pesticides and other synthetic chemicals. I also expect those foods and products to be produced in ways that benefit the soil, do not harm wildlife, and do not pollute the environment.<\/p>\n\n\n\n

                    The body of scientific evidence of the harm caused by PFAS chemicals grows month after month. It\u2019s mind-boggling that this class of toxic chemicals is still allowed in organics. I should be able to expect that the organic foods and consumer products I buy do not contain these dangerous chemicals. PFAS chemicals must be banned in organic production.<\/p>\n\n\n\n

                    The overuse of petrochemical-based plastics in organic farming, and in retail, is very problematic and alternatives need to be developed quickly.<\/p>\n\n\n\n

                    A recent study proves that toxic microplastic particles are taken up by plants through the roots, and move into the edible vegetable tissues. Plastic tarps and mulches used extensively in organic farming are contaminating the soil with microplastics and synthetic chemicals, poisoning the crops which we then consume.<\/p>\n\n\n\n

                    Research also shows chemicals in plastic containers and packaging, including PFAS, BPA, phthalates and other endocrine-disrupting chemicals, leach into food and drink. Additionally, plastics break down into toxic microplastics and nanoplastics, further contaminating our food.<\/p>\n\n\n\n

                    I am urging the NOSB to implement the following:<\/p>\n\n\n\n

                      \n
                    1. Place the entire class of dangerous 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.<\/li>\n\n\n\n
                    2. Strengthen the rules for organic compost production to prohibit the use of inputs from conventional agriculture such as manure and compost inputs which are contaminated with toxic chemicals, synthetic pesticides and GMOs to keep synthetics out of organic compost.<\/li>\n\n\n\n
                    3. Research and develop non-toxic alternatives to phase out the use of plastic mulch and tarps for growing.<\/li>\n\n\n\n
                    4. Prohibit the use of fluorinated (PFAS-coated) HDPE #2 plastic containers and packaging.<\/li>\n\n\n\n
                    5. Prohibit the use of recycled plastic containers and packaging; research and develop non-toxic alternatives to phase out the use of all petrochemical-based plastic containers and packaging for retail.<\/li>\n\n\n\n
                    6. Require a separate certification label for hydroponics.<\/li>\n\n\n\n
                    7. Prohibit CAFOs (Concentrated Animal Feeding Operations, also known as factory farms, that raise animals in deplorable conditions and generate massive amounts of pollution) from being certified organic.<\/li>\n\n\n\n
                    8. Prohibit synthetic hormones in organic milk production.<\/li>\n<\/ol>\n\n\n\n

                      The organic sector has a duty to exclude harmful substances, materials and practices whenever sufficient evidence arises to prove harm. There is more than enough peer-reviewed science to show that PFAS chemicals and microplastics do not belong in organic food and products. Integrity is critically important.<\/p>\n\n\n\n

                      Implementing the above actions would help organic shoppers like me to reduce my exposure to those dangerous toxins. Implementing these actions would bring the National Organic Program closer to what shoppers expect and pay a premium for.<\/p>\n\n\n\n

                      The relevant research in support of the 8 recommendations in my comment can be found here: https:\/\/tinyurl.com\/8WaysToImproveOrganic<\/p>\n<\/div><\/div>\n","protected":false},"excerpt":{"rendered":"

                      8 Recommendations to the National Organic Standards Board to Improve Organic Farming and Food \u2013 Fall 2025 IMPORTANT NOTE TO OUR SUPPORTERS: Something deeply troubling happened in September. The government blocked access to its public comment dockets by the third-party platform our nonprofit has long used to help you submit regulatory comments. For years, this …<\/p>\n","protected":false},"author":13,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_genesis_hide_title":false,"_genesis_hide_breadcrumbs":false,"_genesis_hide_singular_image":false,"_genesis_hide_footer_widgets":false,"_genesis_custom_body_class":"","_genesis_custom_post_class":"","_genesis_layout":"","footnotes":""},"categories":[58],"tags":[],"class_list":{"2":"type-post","6":"category-the-non-toxic-sleuth","7":"entry"},"acf":[],"_links":{"self":[{"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/posts\/7286","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/users\/13"}],"replies":[{"embeddable":true,"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/comments?post=7286"}],"version-history":[{"count":3,"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/posts\/7286\/revisions"}],"predecessor-version":[{"id":7291,"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/posts\/7286\/revisions\/7291"}],"wp:attachment":[{"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/media?parent=7286"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/categories?post=7286"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/toxinfreeusa.org\/wp-json\/wp\/v2\/tags?post=7286"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}