Permitted Substances List - Questions and Answers Regarding National Standard on Organic Production Systems

The Canadian Food Inspection Agency, in partnership with the Organic Federation of Canada, has developed the Organic Standards Interpretation Committee (SIC). The objective of the Committee is to provide, to the Canada Organic Office, interpretive guidance on issues related to the National Standards for Organic Agriculture (CAN/CGSB 32.310 and CAN/CGSB 32.311).

These are the final answers to questions raised by organic stakeholders, regarding the National Standards for Organic Agriculture. Any further clarifications related to these questions and answers can be sent to the Canada Organic Office. The numbers found in brackets at the end of each question are reference numbers used by CFIA staff for tracking purposes. Please quote the reference number when sending in your query.

What is the pathway for approving cleaners, or substances used? (3)

Operators should approach their Certification Bodies to verify the cleaner complies with the Standards. Approval of individual substances is the mandate of CGSB Technical Committee, through Permitted Substances List working groups (Reference, PSL).

Can chlorine be used to wash organic produce? (5)

Chlorinated water, up to the concentration used in the closest municipal water system, is acceptable for washing organic vegetables and does not require rinsing.

Can uncertified garlic be used as a de-wormer in organic livestock operations? (7)

This standard does not prohibit the use of uncertified garlic as a de-wormer in the event that certified garlic is not commercially available (Reference: 6.7.9 b).

Is copper sulphate allowed as a treatment for fence-posts on pasture? (9)

The use of copper sulphate is permitted for use as a fungicide (wood preservative) for wood (e.g. fence posts) on organic production units (Table 4.3 copper products).

Are approved cleaners applicable only to food contact surfaces or to the whole processing facility? (10)

The restrictions on cleaners, disinfectants and sanitizers provided in the PSL do not apply to parts of the facility where there is no direct or indirect contact with the food products or food contact surfaces (Reference, PSL Tables 7.3 and 7.4).

Which forms of lecithin are acceptable, according to the organic standard? (14)

The current standard should be interpreted to allow organic lecithin both bleached and unbleached, and non organic where organic is not commercially available. Non organic lecithin must still comply with 1.4.1 (Reference: PSL 6.3).

Do clauses 7.3 and 7.4 apply to the cleaning of: dedicated and non dedicated spraying equipment; of irrigation systems; and non-food contact surfaces such as floors, windows, staff toilets etc.? (21.1)

The restrictions on cleaners, disinfectants and sanitizers provided in the PSL do not apply to parts of the facility where there is no direct or indirect contact with the food products or food contact surfaces (Reference, PSL Tables 7.3 and 7.4). Tables 7.3 and 7.4 of the Permitted Substances List generally apply to food contact surfaces, food, and equipment in contact with food, unless otherwise annotated. While the cleaners listed in these tables may be used in other applications, cleaning of non-food contact surfaces is not restricted to these cleaners. In the case of use of substances not listed in 7.3 & 7.4, the operator is responsible to ensure that no residual contamination occurs on land and crops.

Does the prohibition of sulphates produced with sulphuric acid apply to cobalt sulphate used as a mineral supplement and for medical use? (22.1)

No. Table 5.2 of the PSL allows for Trace elements from any source for feed. Table 5.3 allows them from any source for medical use.

Is the use of fish products as feed supplements prohibited? (22.2)

Table 5.2 of the PSL allows for protein feeds from organic sources. Fish products would thus not be permitted as feed supplements unless organic.

Under the Canadian Standards for Organic products it is listed that water is permissible. Can you please tell me if seawater would be included in this definition? (23)

Table 4.3 of the PSL allows for water (and wetting agents) to be used as crop production aids. Sea water, in all its various forms of concentration, is acceptable.

Is clove oil allowed as an organic sprout inhibitor for potatoes? (27)

Table 4.3 of the PSL lists plant extracts, oils and preparations as acceptable crop production aids. Clove oil would be acceptable for use on seed potatoes.

Is the end product from an anaerobic digester or biogas digester acceptable for use as a soil amendment? (30)

The products of anaerobic digestion cannot be considered compost under the standard since the definition specifies aerobic decomposition. The product may be used as compost feedstock (see table 4.2, 32.311 composting feedstocks). If only manure is used in the digester, the end product could be applied to fields under the conditions applying to raw manure. If other materials such as abattoir waste were used as raw material, the final product of the digester would still not be acceptable for use on organic soil unless composted.

Is tractor exhaust, injected into the soil, acceptable under the standard? (32)

Tractor exhaust may be injected into the soil only if all the components of the tractor exhaust comply with the standard and PSL.

Is the use of ethylene as a sprout inhibitor for onions and potatoes admissible? (43)

No. The use of ethylene in this context is clearly as a growth regulator prohibited in 4.3.

When pesticides allowed under section 8.4.3 (not listed in PSL) are used in a facility, is the fact that the bait stations are clamped to the wall sufficient to ensure that no contact occurs? (38)

Where a pesticide not listed in PSL (32.311) is dispensed using a fixed bait station the operator must ensure that neither the pesticide nor the contaminated pest could come in contact with the organic product. For indoor use, no organic products or packaging materials may be present during the use of the pesticide.

Can you clarify the requirement for removal of plastic mulch from fields? (44)

The annotation for plastic mulches, in table 4.3 PSL, is clearly intended to prohibit the incorporation into the soil for any material other than fully biodegradable films compliant with section 1.4.1 (32.310). Where there is any risk of contamination, plastic mulch must be removed from the soil. The distinction between annual and perennial crops is made on the premise that following an annual crop, tillage will occur in preparation for the next year, but this distinction is not essential to fulfilling the intent of the standard, which is to avoid contamination of the soil. In situations where the mulch will not be incorporated into the soil then it may be left on.

Since lactic acid is mentioned twice in table 6.3, once under "Acids" with no designation of specific use and again under "Lactic acid", with a clear single use, are operators bound to the second specific use or allowed to use this substance more widely? (47)

The wider use is acceptable as it is listed under acids with no annotation. Neither of the listing in 6.3 fix the use of the substance lactic acid; the annotation accompanying lactic acid is intended to five examples, not exclude other food uses.

Please confirm whether sulphates of magnesium, copper, manganese and cobalt produced using sulphuric acid may be used to correct deficiencies determined by soil or plant tissue testing? (51)

Sulphates of zinc, iron and potash magnesia are listed in the PSL table 4.2. Forms produced using sulphuric acid are specifically excluded in the annotation.

Can plant oils / plant extracts based herbicides contain PMRA list 4 A and 4 B formulants? (53.1)

Yes, the formulants listed in PMRA 4A and 4B can be used. These two categories meet the basic organic principles and thus would be acceptable as there is no specific list in the PSL for formulants See table 4.3.

Are non-synthetic formulants allowed in fertiliser formulations? (55)

Non synthetic formulants may be used in fertiliser formulations providing section 1.4.1 is respected.

Is Lanolin allowed for use on dairy cows teats? (60.2)

Yes. Lanolin is listed on the elaboration of Health Care Products and Production Aids published on the CFIA-COO website.

Does the listing of "fully biodegradable films" in table 4.3 PSL under mulches include films made from petroleum products? (60.2)

No. Mulches made using petroleum are not considered to be "fully biodegradable" and must be removed from the field and may not be incorporated into the soil.

Is the use of DL-methionine from processes involving Genetic Modification allowed? (54)

No. Table 5.2 of the PSL allows for the use of DL-synthetic Methionine, as a special exception subject to a review by the CGSB technical committee. Section 1.4.1 prohibits products from genetic engineering.

Can ink be used to label organic eggs? (46)

Yes. Ink that does not contain prohibited substances may be used to label egg shells.

Does the annotation applying to Amino Acids (non-synthetic) in table 4.2 of the PSL also apply to Amino Acids in table 5.2? (59)

Yes. The annotation for amino acids in table 4.2 PSL (soil amendments) should be considered to be applicable also to table 5.2 (animal feed additives and food supplements) as it explains more fully the definition of "non-synthetic" for the purpose of the Standards.

Does the process described in Table 4.2 of the PSL (annotation for amino acids-non synthetic) apply to other microbial products, for example yeast; for use as a soil amendment? (57.2)

No. There is insufficient justification for applying the annotation specific to the production of amino acids to the production of all microbial products.

Is sugar allowed as a soil amendment? (60.1)

Organic sugar only can be used as a soil amendment. An organic substance does not have to be listed on table 4.2 to be allowed as a soil amendment.

If citric acid is permitted, is sodium citrate also permitted? (66)

No. Citric acid and sodium citrate are different substances.

Is citrus extract allowed as a cleaner or disinfectant in buildings for animal production? (68.1)

Yes. Citrus extract, included under botanical compounds in 5.3 (32.311) would be useable as a cleaner in livestock houses.

If vitamin and mineral premixes that do not contain preservatives are unavailable, how can organic farmers meet the nutritional needs of their animals? (65.2)

The listing of premixes in table 5.2 (PSL) and vitamins and trace minerals in table 5.3 (PSL) with the accompanying annotations makes it permissible to use pre-mixes that are not fully compliant with the standard, if no fully compliant product is available. See section 3 "Definitions": "Commercially Available."

What is the status of tables 7.3 and 7.4 regarding livestock production? (68.2)

Substances on Tables 7.3 and 7.4 can be used in livestock facilities but cleaning or disinfection of livestock facilities is not confined to these lists. See also 5.3 PSL and 6.8.4 - 32.310.