1. Now That You’re Organic,
What Products and Materials Can
You Use?
The Organic Materials Review Institute
(OMRI)

2. Who am I? • Product Review
Coordinator, 2 years in
March
Doug Currier • Background in Organic
dougc@omri.org Farming Systems and
Organic Principles
(541) 343-7600
ext. 113 • Responsibilities at OMRI:
Product Review and
Recommendations

3. OMRI is a 501(c)(3)
nonprofit that reviews input
materials such as fertilizers,
feed additives and
processing aids to
determine compliance with
the National Organic
Standards.

4. Session Outline
• 45 min: A). Setting the Stage- defining key terms
B). A look at Allowed, Restricted
and Prohibited materials for Organic
crop, livestock and processing
production.
• 15 min: Q and A
• 30 min: Label and Material Review on the farm
and More about OMRI and how we can help!

5. Acronyms Used Today
• NOP: National Organic
Program
• NOSB: National Organic
Standards Board
• ACA: Accredited
Certifying Agents
• GML: Generic Materials
List
• OPL: OMRI Products List

6. Determining Compliance
• Compliance starts with producer-learn
which types of materials are compliant.
Certifier have final say!
• ACAs conduct material review and
determine compliance on an individual
operation by operation basis.

7. • OMRI is an independent review
organization, not an ACA
• Publish GML and OPL to communicate
our recommendations and products list to
certifiers, producers and other interested
parties
• Certifier has final say!

8. • NOP Rule: The National Organic
Standards define and outline which
materials are allowed or prohibited.
• NOP issues Guidances that help to clarify
the use of materials.
NOP

9. Material Review Organizations
• No current NOP oversight of MROs
• The NOSB has recommended (May 2012)
to the NOP a set of criteria to evaluate the
competency and quality of MROs.
• The goal is to outline review criteria that all
MROs must meet. Similar to ACAs.

10. Bird’s eye view first

11. Nonsynthetic and Synthetic
Materials
• In general nonsynthetic materials
are allowed and synthetic
materials are prohibited.
• Exceptions are the Allowed
synthetics listed in the NOP Rule

12. Synthetic Materials
• Synthetic: A substance that
is formulated or Microbial products
manufactured by a chemical
process or by a process that •Examples being
chemically changes a salts, materials
substance extracted from relying on a
naturally occurring plant, reaction for
animal, or mineral sources, production, most
except that such term shall things made in a
not apply to substances lab!
created by naturally
occurring biological
processes.

13. • Nonsynthetic (natural): A
substance that is derived from
mineral, plant, or animal matter
and does not undergo a synthetic
process
• Examples: mined minerals,
botanical extracts, fish products
(not stabilized), microbial
products, citric acid.

14. Allowed Synthetics
The listing of a synthetic material is
• §205.601 –Crops often annotated restricting its use and
how its manufactured
• §205.603 –Livestock
Many blanket restrictions apply to these
• §205.605(b) materials (e.g. pesticide restriction)
--Processing All synthetic materials have a “Sunset”
date

15. Synthetic/Nonsynthetic
Classifications
Limestone (CaCO3)
Limestone (CaCO3)

16. Prohibited Substances
• Synthetics not specifically on the National List - §205.601, 603 or 605(b)
• Prohibited nonsynthetics on the National List - §205.602 and 604
• Nonagricultural substances used in or on processed products, except
those listed at §205.605
• Nonorganic agricultural substances used in or on processed products,
except those listed at §205.606
• Products containing significant levels of heavy metals or pathogens.
• Products made from excluded methods such as sewage sludge
(biosolids), genetic modification, irradiation.

17. General Analysis s
Ye
Yes Is the ingredient synthetic Go to #2
1. Are there ingredients on the National List or Prohibit
within ingredients? Nonsynthetic? No s
Is it present in Ye
final product? No
Go to #2
No
2. Does the ingredient Ye
s Go to #3
manufacturing
Yes Is the ingredient on the
process make it synthetic? National List?
Prohibit
N
o
No
Ye
s Allow
3. Does the manufacturing Restriction?
process make the
Yes Is it on the
product synthetic? National List?
Prohibit
N
o

18. Synthetic
vs.
Nonsynthetic
Decision
Tree

19. Now a worm’s eye view

20. Crop Input Materials
• Crop Pesticides – OMRI Class CP
• Crop Fertilizers and Soil
Amendments– OMRI Class CF
• Crop Tools- OMRI Class CT

21. 205.601 Allowed Synthetics

22. Understanding Pesticides
• Products sold in US with All
pesticide claims on the Pesticides
label must be EPA sold
registered or exempt from in the US
registration under “Section
25B.”
• Not all exempt products
are compliant with the
National Organic Program 25B EPA
Rule (but most are). exempt Registered
products products

23. Crop Pesticides
All pesticide products for use in Organic
Production are restricted - §205.206
* Must use practices to prevent crop pests,
weeds and disease
Preventative measures
-Sound rotation -Mulching
-Variety choice -Habitat creation
-Use of beneficial -Lures, Traps, Repellents
Insects (e.g. botanical pesticides)

24. NOP Compliant Pesticides
25(b) pesticides Registered Pesticides
What about home brew?
(pesticides that is)

25. Crop Input Materials
• Crop Pesticides – OMRI Class CP
• Crop Fertilizers and Soil
Amendments– OMRI Class CF
• Crop Tools- OMRI Class CT

26. NOP Rule §205.203-Soil Fertility…
Crop Nutrient
Identifies management practices but
also identifies allowed input materials
Prohibits the use of
plant and animal Allows for ash from
materials that have plant and animal
been chemically materials…as long
altered by as not combined
manufacturing with prohibited
process substances
Establishes
Compost Days to Harvest
Production Rule
Parameters

27. Top 5 Animal Ingredients
Blood Meal
Bone Meal Feather meal
Bone and meat meal Allowed if Fish Meal
not stabilized
or fortified
with
prohibited
materials

28. On-Farm Composting
• C:N ratio 25-40:1
• Turning
requirements
• Temperature
requirements
• Method
requirements

29. Compost Records
Date Temperature Turn
5/1/11 112 No
5/2/11 116 Yes
5/5/11 125 No
5/6/11 127 No
5/8/11 131 Yes
5/12/11 146 Yes
5/13/11 148 No
5/14/11 152 Yes

30. §205.602-Prohibited Nonsynthetics
Ash from Manure Burning
Tobacco Dust Arsenic Lead Salts

31. Crop Input Materials
• Crop Pesticides – OMRI Class CP
• Crop Fertilizers and Soil
Amendments– OMRI Class CF
• Crop Tools- OMRI Class CT

32. ◊ Many of these materials are nonsynthetic and allowed
◊ Not used as plant or soil nutrient
◊ Aid in crop production
Coconut Coir
Adjuvants: increase
effectiveness of fertilizers
and pesticides
Citric Acid

33. Compliant Inputs for Organic
Livestock Production

34. Livestock
Inputs
Livestock external Livestock
Livestock Feed Livestock Health
parasiticides and management tools
Ingredients Care
pesticides and production
aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide

35. Livestock
Inputs
Livestock external Livestock
Livestock Feed Livestock Health
parasiticides and management tools
Ingredients Care
pesticides and production
aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide

36. §205.237 Livestock Feed

37. Definitions
Feed additive.
A substance added to feed in micro
quantities to fulfill a specific nutritional need;
FEED: any article
i.e., essential nutrients in the form of amino
acids, vitamins, and minerals. that is intended to be
used as an animal
Feed supplement. feed ingredient, to
A combination of feed nutrients added to
become part of an
livestock feed to improve the nutrient
balance or performance of the total ration ingredient or feed, or
and intended to be: added to an animal's
(1) Diluted with other feeds when fed to
drinking water is
livestock;
(2) Offered free choice with other parts of considered a "food"
the ration if separately available; or and thus, is subject
(3) Further diluted and mixed to produce a
to regulation.
complete feed.

38. 205.237 Livestock Feed
Establishes
synthetics on
§205.603 and
nonsynthetics may
be used as additives
and supplements

39. 205.237 Livestock Feed
Establishes
synthetics on
205.603 and
nonsynthetics may
be used as additives
and supplements
Prohibits the use of
animal drugs and
hormones to
promote growth; feed
plastic pellets for
roughage, feed
formulas containing
urea or manure

40. 205.237 Livestock Feed
Establishes
synthetics on
205.603 and
nonsynthetics may
be used as additives
and supplements
Prohibits the use of
animal drugs and
hormones to
Prohibits mammalian promote growth; feed
or poultry slaughter plastic pellets for
by-products; roughage, feed
antibiotics including formulas containing
ionophores urea or manure

41. 205.237 Livestock Feed
Prohibits the use of
Establishes
feed, feed additives,
synthetics on
and feed
205.603 and
supplements in
nonsynthetics may
violation of the FD&C
be used as additives
Act
and supplements
Prohibits the use of
animal drugs and
hormones to
Prohibits mammalian
promote growth; feed
or poultry slaughter
plastic pellets for
by-products;
roughage, feed
antibiotics including
formulas containing
ionophores
urea or manure

42. 205.237 Livestock Feed
Prohibits the use of
Establishes
feed, feed additives,
synthetics on
and feed
205.603 and
supplements in
nonsynthetics may
violation of the FD&C
be used as additives
Act
and supplements
Prohibits the use of
animal drugs and
hormones to
Prohibits mammalian
promote growth; feed
or poultry slaughter
plastic pellets for
by-products;
roughage, feed
antibiotics including
formulas containing
ionophores
urea or manure

43. 205.237 Livestock Feed
Prohibits the use of
Establishes
feed, feed additives,
synthetics on
and feed
205.603 and Producer must provide supplements in
nonsynthetics may organic livestock with a violation of the FD&C
be used as additives total feed ration
Act
and supplements composed of agricultural
products that are
organically produced. Prohibits the use of
animal drugs and
hormones to
Prohibits mammalian
promote growth; feed
or poultry slaughter
plastic pellets for
by-products;
roughage, feed
antibiotics including
formulas containing
ionophores
urea or manure

44. Agricultural Ingredients in Livestock Feed
• Agricultural Products used as ingredients in
livestock feed must be certified Organic.
• Examples of agricultural products in livestock
feed products:
Carriers: sugar, whey powder
Feed Supplement: Garlic, Oregano oil

45. Yeast
• A manufacturer can produce a yeast
product that is certified organic to the NOP
Rule.
• However, a livestock operation may
provide non-organic yeast to livestock as a
nonsynthetic and still retain organic
certification.
• Reference NOP Guidance 5014

46. Allowed synthetics
• Currently no allowed synthetic feed
supplements-§205.603(c)
• Allowed synthetic feed additives are listed at
§205.603(d) and include:
-DL-Methionine, DL-Methionine-hydroxy analog,
and DL-Methionine-hydroxy analog calcium for
use in organic poultry production.
-Trace minerals, used for enrichment and
fortification when FDA Approved
-Vitamins, used for enrichment or fortification
when FDA approved

47. 205.237 Livestock Feed
The producer of an organic
operation must not: provide
feed supplements or
additives in amounts above
those needed for adequate
nutrition and health
maintenance for the species
at its specific stage of life .

48. Livestock
Inputs
Livestock external Livestock
Livestock Feed Livestock Health
parasiticides and management tools
Ingredients Care
pesticides and production
aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide

49. Livestock healthcare products
• Includes animal drugs, internal
parasiticides, general use healthcare
substances, internal and topical
medications, and biologics.
Examples:
Herbal Preparations
Probiotics-not routinely fed
Botanicals-Udder creams
Magnesium Sulfate (Epsom Salts)-Hoof Baths

50. 205.238 Livestock Health Care
Standard
Establishes that
producers must
maintain
preventative
livestock healthcare
practices which
includes the use of
vaccines and
biologics

51. 205.238 Livestock Health Care
Standard
Establishes that
producers must
maintain
preventative
livestock healthcare Prohibits the sale of
practices which livestock products
includes the use of from animals treated
vaccines and with drugs in
biologics absence of illness,
hormones, synthetic
parasticides on
routine basis and to
slaughter stock

52. 205.238 Livestock Health Care
Standard
Establishes that Prohibits the
producers must administration of
maintain drugs in violation of
preventative the FD&C Act
livestock healthcare
practices which
Prohibits the sale of
includes the use of
livestock products
vaccines and
from animals treated
biologics
with drugs in
absence of illness,
hormones, synthetic
parasticides on
routine basis and to
slaughter stock

53. GMO Vaccines
• GMO vaccines are not legally allowed in
organic production. However, producers
are not currently required to declare if they
are using non-GMO vaccine.
• Current NOSB recommendation to NOP
that GMO vaccines be allowed only in
times of declared emergency without
losing organic status.

54. Livestock
Inputs
Livestock external Livestock
Livestock Feed Livestock Health
parasiticides and management tools
Ingredients Care
pesticides and production
aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide

55. External parasiticides and
pesticides defined
• Pesticides used to manage ticks, flies and
other external parasites and pests.
• Include pesticides used in barns, poultry
houses and other livestock facilities.
• Includes nonsynthetics and allowed
synthetics at §205.603.

56. Pyrethrums

57. Livestock
Inputs
Livestock external Livestock
Livestock Feed Livestock Health
parasiticides and management tools
Ingredients Care
pesticides and production
aids
Molasses Zinc sulfate Hydrated lime Chlorine Dioxide

58. Livestock management tools and
production aids
• Materials that do not have a nutritional or
direct health care function.
• Examples include facility cleaners,
grooming aids.
• Materials used on animals or in their living
areas

59. Livestock teat dip,
Absorbent and
must be produced
Deodorizer
through the
hydrolysis of fats or
Diatomaceous Earth oils
Glycerin
Silage Inoculant Disinfecting
livestock facilities
and equipment.
Lactic acid bacteria
Chlorine Materials

60. Processing
Inputs
Agricultural Nonagricultural Processing Processing Container and
ingredients and ingredients and Sanitizers and pest controls packaging
processing aids processing aids Cleaners materials
Shellac, orange Ethylene Absorber
Unbleached Sulfur Dioxide Acetic Acid Vitamin D3 Sachets

61. Processing Certified Organic
products for Human Consumption
• Processing aids and additives allowed
for use in certified organic products
• Remember:
100% Organic- made entirely of certified
organic ingredients
Organic- 95% organic ingredients
Made with organic ingredients-
containing a minimum of 70% organic
ingredients

62. Processing
Inputs
Agricultural Nonagricultural Processing Processing Container and
ingredients and ingredients and Sanitizers and pest controls packaging
processing aids processing aids Cleaners materials
Shellac, orange Ethylene Absorber
Unbleached Sulfur Dioxide Acetic Acid Vitamin D3 Sachets

63. Agricultural ingredients and
processing aids
• If processing food and fiber for certified
Organic or made with organic ingredients
• Nonorganically produced agricultural
products
• Closed list at §205.606, all materials carry
commercial availability restriction

64. Orange, Shellac-
unbleached
Gums—water extracted
only (Arabic; Guar; Locust
bean; and Carob bean).
Lecithin—de-oiled

65. Processing
Inputs
Agricultural Nonagricultural Processing Processing Container and
ingredients and ingredients and Sanitizers and pest controls packaging
processing aids processing aids Cleaners materials
Shellac, orange Ethylene Absorber
Unbleached Sulfur Dioxide Acetic Acid Vitamin D3 Sachets

66. Nonagricultural ingredients and
processing aids
• If processing food and fiber for certified
Organic or made with organic ingredients
• Closed list at §205.605(a) and (b)
• Some listings are annotated, restrictions
apply

67. Potassium hydroxide prohibited
for use in lye peeling of fruits
and vegetables except when
used for peeling peaches during
the Individually Quick Frozen
(IQF) production process
Potassium phosphate- for use
only in agricultural products
labeled “made with organic
(specific ingredients or food
group(s)),” prohibited in agricultural
products labeled “organic”.

68. Acids –pH adjuster
(Alginic; Citric- produced by
microbial fermentation of
carbohydrate substances; and
Lactic)
Calcium sulfate—mined*
*Usually from mined gypsum
evaporate

69. Processing
Inputs
Agricultural Nonagricultural Processing Processing Container and
ingredients and ingredients and Sanitizers and pest controls packaging
processing aids processing aids Cleaners materials
Shellac, orange Ethylene Absorber
Unbleached Sulfur Dioxide Acetic Acid Vitamin D3 Sachets

70. Sanitizers/Cleaning Materials on The National List
1) Allowed to contact food through direct application.
– Sodium Hydroxide
2) Allowed to contact food in wash and/or rinse water.
– Peracetic Acid/Peroxyacetic Acid
3) Allowed to contact food in wash and/or rinse water but must be followed by
a clear water rinse.
– Chlorine Materials or Chlorine Dioxide
4) Allowed to contact food indirectly through use on food contact surfaces (no
rinse required).
– Peracetic Acid/Peroxyacetic Acid
– Chlorine Materials or Chlorine Dioxide

71. Intervening Events
• Rinse with cold/hot water
• Purge
• Drip dry
• Evaporation

72. Use of Chlorine Materials
Max label rates w/o
Intervening event
Not to exceed SDWA
At label rates approved by FDA
Or EPA followed by SDWA rinse

73. Sanitizers/Cleaning Materials
NOT on The National List
These materials may NOT contact organic products
5) Nonpersistent materials. May be used on food contact
surfaces, however an intervening event (such as a rinse
or a purge) must take place to prevent the contact of
residue with organic products.
– Various Detergents, Sanitizers, and Cleaners
6) Persistent antimicrobials. Not Listed by OMRI. Must
have thorough intervening event.
– Quaternary ammonia products.

74. Processing
Inputs
Agricultural Nonagricultural Processing Processing Container and
ingredients and ingredients and Sanitizers and pest controls packaging
processing aids processing aids Cleaners materials
Shellac, orange Ethylene Absorber
Unbleached Sulfur Dioxide Acetic Acid Vitamin D3 Sachets

75. Processing Pest Controls are used to
A) Disinfest or prevent infestation of stored
commodities
B) Prevent post harvest decay
C) Provide pest control in handling facilities
Examples: Traps, lures and repellents
These are environmental, mechanical
or physical controls

76. • All Processing Pest Control materials are
restricted. Producer must ensure they are
meeting the facility pest management
standard (§205.271)
• Producer must ensure all health and food
safety laws are met
Federal Food Safety Laws
NOP RULE
State and Local Food Safety Laws
Requirements of superseding laws do not provide
exemption for use of prohibited materials!

77. • Many of these materials are EPA Registered
Pesticides
• Producer can begin to ensure their
compliance by:
A). Documenting preventative measures to
address post-harvest pest control.
B). Look at the label for agricultural use
C). Work with certifier to determine if there
should be prevention of pest control material
with organic produce.

78. Processing
Inputs
Agricultural Nonagricultural Processing Processing Container and
ingredients and ingredients and Sanitizers and pest controls packaging
processing aids processing aids Cleaners materials
Shellac, orange Ethylene Absorber
Unbleached Sulfur Dioxide Acetic Acid Vitamin D3 Sachets

79. Packaging Materials
• May not contain synthetic fungicides,
preservatives or fumigants.

80. • Ethylene filters- Used in post-
harvest handling to extend shelf
life of produce.
• Potassium Permanganate often
used as ethylene absorbent.
• Potassium Permanganate is a
prohibited synthetic so must not
contact organic produce.

81. Q&A

82. Session Outline
• 45 min: A). Setting the Stage- defining key terms
B). A look at Allowed, Restricted
and Prohibited materials for Organic
crop, livestock and processing
production.
• 15 min: Q and A
• 30 min: Label and Material Review on the farm
and More about OMRI and how we can help!

83. Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Service

84. Determining Compliance
• Compliance starts with producer-learn
which types of materials are compliant.
Certifier have final say!
• ACAs conduct material review and
determine compliance on an individual
operation by operation basis.

85. Input Product Labels
• A product can tell you about the product
and keep you compliant
• Look at ingredients listed on label.
- Livestock feed material, is it formulated
using agricultural ingredients? Certified
organic?
- Crop fertilizer, is there a prohibited
synthetic micronutrient listed on label?
- If on-site processing, does the label
require a rinse step after using product?

86. Label review

87. Kelp Products—Synthetic Extraction
• Limited to potassium or
sodium hydroxide solvent.
Common to use potassium
carbonate
• Used as natural potash
source
•Comes in liquid, powder
and meal form.
•OMRI has been unable to
determine threshold at
which fortification occurs

88. Notice lack of
ingredient list—
potassium or
sodium hydroxide
do not appear on
label
Does application
method matter?

89. Does soil deficiency need
to be documented to add
sulfur?
Complexed = Chelated

90. Agricultural ingredients?
Oregano oil, organic?
Agricultural
Product do
not need to be
Certified
Organic in a
Livestock
Healthcare
Product

91. Liquid detergent Product –Sodium
Hypochlorite active ingredient

92. Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Service

93. OMRI Publications
• Generic substances and
compliance standards for
each substance
• Brand name products that
have undergone and
passed OMRI review
**Stop by the OMRI Booth for a free copy of each!**

94. Sample GML Entry

96. The Generic Materials List
Category Status:
Material entry that Attribute that
corresponds to describes
main ingredient or compliance
product function.
Also called “listing”
Classification
Describes
Class: synthetic/
One of 12 product nonsynthetic
use types: classification
CF, CP, CT
Citation:
Gives regulatory
reference from
which compliance
and annotation
was derived

97. Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Services

98. -Companies that have their products reviewed
and listed by OMRI may use the OMRI Seal.
-Seal communicates allowance for use in
Organics.

99. Material Review on the Farm
• Label Review
• Using the OMRI Lists
• The OMRI Seal
• OMRI Website and Subscription Service

100. OMRI Services, cont.
Subscriptions
-Retail, Certifier, Organization,
Individual
Technical Expertise
-Trainings
-Newsletter
-Contracts

102. Search for a product
Search for a material
Search for products
listed in a specific
OMRI Class

103. Application Kits
Application Specialist:
Tara Sistrunk
taras@omri.org
541-343-7600 (x105)

104. Questions? Feedback?
• We’re here to help!
• Email info@omri.org

105. Input Review Gold Standard
Certifiers
Farmers/ Consumers
Processors
NOP Manufacturers