PCO Prohibited Substances & Allowed Inputs 1 — Questions and Answers
Question 1: Under the USDA National Organic Program (NOP), which list in the Organic Foods Production Act (OFPA) specifies substances that are prohibited for use in organic crop production?
- The National List of Allowed and Prohibited Substances (Correct answer)
- The EPA Restricted Use Pesticide List
- The FIFRA Approved Substances Registry
- The USDA Green Book of Organic Inputs
Correct answer: The National List of Allowed and Prohibited Substances
The National List of Allowed and Prohibited Substances (7 CFR 205.600–205.607) is the regulatory foundation that defines which synthetic and nonsynthetic materials may or may not be used in organic production.
Question 2: An inspector finds that an operator applied a synthetic pesticide not on the National List to a certified organic field. What is the MOST immediate concern regarding the crop?
- The crop may no longer qualify for organic certification and may require decertification (Correct answer)
- The operator must simply re-apply an approved organic material to counteract the prohibited substance
- The crop remains certifiable as long as the application was accidental
- The inspector must obtain a lab sample before any compliance action can be taken
Correct answer: The crop may no longer qualify for organic certification and may require decertification
Applying a prohibited synthetic pesticide to an organic field is a major non-conformance that can disqualify the crop and trigger a Notice of Non-Compliance or suspension.
Question 3: Which of the following synthetic substances is ALLOWED in organic crop production under the NOP National List?
- Copper-based fungicides (with restrictions) (Correct answer)
- Atrazine herbicide
- Synthetic nitrogen fertilizers
- Organophosphate insecticides
Correct answer: Copper-based fungicides (with restrictions)
Copper-based materials such as copper hydroxide are listed under 7 CFR 205.601 as allowed synthetic substances for organic crop production when used with restrictions.
Question 4: A certified organic livestock producer wants to use a synthetic medication to treat a sick animal. Under the NOP, what is the correct course of action?
- Administer the medication if necessary to relieve suffering, then sell the animal as non-organic (Correct answer)
- Use only approved nonsynthetic treatments and never sell a treated animal as organic
- Document the treatment and maintain organic status if the withdrawal period has passed
- Obtain prior written approval from the certifier before any treatment
Correct answer: Administer the medication if necessary to relieve suffering, then sell the animal as non-organic
NOP regulations require that prohibited synthetic medications be used when necessary for animal welfare, but the animal (and its products) must then be removed from organic sale.
Question 5: When evaluating whether a material is allowed in organic production, inspectors should verify that the material is reviewed by which independent body before it can be added to or removed from the National List?
- National Organic Standards Board (NOSB) (Correct answer)
- Environmental Protection Agency (EPA)
- Food and Drug Administration (FDA)
- Organic Trade Association (OTA)
Correct answer: National Organic Standards Board (NOSB)
The NOSB is the federal advisory board that evaluates petitions for substances and makes recommendations to the USDA Secretary before changes to the National List are finalized.
Question 6: Under 7 CFR 205.602, which of the following nonsynthetic substances is PROHIBITED in organic crop production?
- Arsenic (Correct answer)
- Fish emulsion
- Compost tea
- Kelp meal
Correct answer: Arsenic
Arsenic is specifically listed under 7 CFR 205.602 as a nonsynthetic substance prohibited for use in organic crop production despite being naturally occurring.
Question 7: An organic inspector reviews an operator's purchased input materials. The operator shows a product labeled 'OMRI Listed.' What does this designation mean during an inspection review?
- The product has been reviewed by the Organic Materials Review Institute as compliant with NOP standards (Correct answer)
- The product is automatically approved by the USDA for organic use without further review
- The certifier has pre-approved this specific product for all operations it certifies
- The EPA has confirmed the material is safe for organic crops
Correct answer: The product has been reviewed by the Organic Materials Review Institute as compliant with NOP standards
OMRI (Organic Materials Review Institute) listing indicates the product has been independently evaluated as compliant with USDA organic regulations, though certifiers must still approve its use.
PCO Prohibited Substances & Allowed Inputs 1
Under the USDA National Organic Program (NOP), which list in the Organic Foods Production Act (OFPA) specifies substances that are prohibited for use in organic crop production?