On March 7, the U.S. Dept of Agriculure (USDA) proposed a revised National Organic Standards (NOS) rule in response to an outpouring of condemnation of the NOS they proposed in 1997. The "Revised Proposed Rule" has addressed many of the major concerns from 1997 by specifically prohibiting the use of genetic engineering, sewage sludge, and irradiation in the production of food products labeled "organic." The proposal also prohibits antibiotics in organic livestock production and requires 100 percent organic feed for organic livestock. In 1997 the USDA received more than 275,000 comments from the public-- the most comments on any proposal in U.S. history.
USDA National Organics Program web: http://www.ams.usda.gov/nop/
The NOS proposed rule allows for the use of certain INERTS -- specifically, those contained in the US EPA "List 4" of inerts. SODIUM FLUORIDE is included in List 4. ("Inerts" are also called "Other Ingredients"). Full list of "List 4" inerts are at: http://www.epa.gov/opprd001/inerts/list4inerts.html
>From the full text of the March 7, 2000, proposed National Organics Standards Rule:
(Available as pdf at: < http://www.ams.usda.gov/nop/>) Page 308: "... In February 1999, the NOSB [National Organic Standards Board] voted to prohibit EPA List 1 and 2 inerts, prohibit EPA List 3 inerts unless specifically allowed by the NOSB, and allow EPA List 4 inerts unless specifically prohibited. The NOSB also recommended full disclosure of all ingredients in formulated products... In this proposal, only EPA List 4 inerts are allowed as ingredients in formulated products used in organic production..."
The Comment Period for the NOS Revised Proposed Rule is March 13-June 12.
Some background information from EPA on List 4: >From Website: www.epa.gov/pesticides/ppdc/inert.htm
List 4--Inerts of minimal concern. "This list includes 430 chemicals of minimal concern. In 1989, this list was further divided into List 4A, minimal risk inerts, and List 4B, inerts for which the Agency had sufficient information to conclude that their current use patterns in pesticide products would not adversely affect public health and the environment."
List 1--Inerts of toxicological concern. List 2--Potentially toxic inerts, with high priority for testing. List 3--Inerts of unknown toxicity.
Note: I am concerned by a number of other chemicals on "List 4" - as you may be when you see the full list.
MORE BACKGROUND INFO ON "INERTS" AVAILABLE FROM EPA'S WEBSITES:
from: www.epa.gov/opprd001/inerts/fr59.htm "Inert Ingredients in Pesticide Products; List of Minimal Risk Inerts" [Federal Register: September 28, 1994]
"In reviewing List 4 inert ingredients for the proposed section 25(b) rule, many inerts on the original List 4 were moved from List 4A to List 4B. In particular, acutely toxic inerts were moved to 4B because, although the testing of products for acute toxicity ensures low concern for these inerts in registered products, without such regulatory oversight there may be unacceptable acute risks. In addition, many of the inerts on the original List 4 received little review for environmental fate and ecological effects. Those inerts have been moved to List 4B while EPA further assess their environmental risks. EPA also plans soon to move inert ingredients now on List 3 to Lists 4A and 4B. The Food and Drug Administration has considered these inerts for use as direct food additives and in pharmaceuticals, and they are undergoing additional review by the FDA and the Office of Water before final disposition."
1997 EPA Definition of "Inerts" or "Other Ingredients": From Website: http://www.epa.gov/opppmsd1/PR_Notices/pr97-6.html
"The terms "active ingredient" and "inert ingredient" have been defined in FIFRA since 1947 and pesticide labeling regulations require that the ingredients statement use the terms "Active ingredients" and "Inert ingredients" as the headings for the ingredients statement information. An active ingredient is one that prevents, destroys, repels or mitigates a pest, and each active ingredient must be identified by name on the label together with its percentage by weight. An inert ingredient is simply any ingredient in the product that is not pesticidally active. Unless an inert ingredient is determined to be highly toxic, it is not required to be identified by name or percentage on the label, but the total percentage of such ingredients must be declared. Neither FIFRA nor the regulations define the term "inert ingredient" on the basis of toxicity, hazard or risk to humans, non-target species, or the environment.
Most "inert" ingredients are not known to pose health or environmental concerns; however, EPA has long known and acknowledged that some inert ingredients are not benign to human health or the environment. The "inert" ingredients in some products may be more toxic or pose greater risks than the active ingredient. Since 1987, EPA has been actively evaluating new and existing inert ingredients for their toxicity before allowing their use in pesticide products. EPA will also be reassessing food tolerances for existing inert ingredients in pesticide products. EPA has not taken the additional step, however, of departing from its traditional use of the term "inert ingredient" on pesticide labeling.
In 1996, EPA began a Consumer Labeling Initiative (CLI), which has as its goal the improvement of consumer labeling (focussing on pesticide products). In the first phase of the CLI, one-on-one interviews were conducted with users of household pesticides (indoor insecticides, outdoor pesticides, and household hard surface cleaners) and non-pesticide cleaning agents. Among other things, the interviews demonstrated that many consumers have a misleading impression of the term "inert ingredient," believing it to indicate water or other harmless ingredients. A number of comments from the public and the consumer interviews recommended that EPA discontinue the use of the term. By this notice, EPA is implementing that recommendation with respect to pesticide labeling."
Ellen Connett, Editor, W A S T E N O T, 82 Judson Street, Canton, New York 13617, Tel: 315-379-9200, Fax: 315-379-0448, Email: wastenot@northnet.org,