PCO Prohibited Substances & Allowed Inputs 2 — Questions and Answers
Question 1: An operator claims that a soil amendment they used is 'natural' and therefore allowed. As an inspector, what is the CORRECT basis for evaluating this claim?
- Determine if the material is listed or classified correctly under the NOP National List and the operator's Organic System Plan (Correct answer)
- Accept the claim since natural substances are always permitted under organic regulations
- Require an independent lab analysis to confirm the material is nonsynthetic
- Consult only the product label to determine organic compliance
Correct answer: Determine if the material is listed or classified correctly under the NOP National List and the operator's Organic System Plan
Whether a substance is 'natural' is insufficient — the inspector must evaluate it against the National List classifications and ensure it is documented in the OSP.
Question 2: Which regulation section specifically lists synthetic substances allowed for use in organic crop production?
- 7 CFR 205.601 (Correct answer)
- 7 CFR 205.602
- 7 CFR 205.603
- 7 CFR 205.238
Correct answer: 7 CFR 205.601
7 CFR 205.601 enumerates the synthetic substances that are permitted in organic crop production, often with specific annotations and conditions.
Question 3: During an inspection, an inspector discovers that sewage sludge was applied to a field three years before the operator sought organic certification. What is the primary concern?
- Sewage sludge is a prohibited substance and its prior use must be evaluated for the 3-year transition period compliance (Correct answer)
- There is no concern because the application occurred before certification began
- The field only needs a soil test to confirm it is now free of prohibited residues
- The operator must immediately reapply for a new transition period starting from the inspection date
Correct answer: Sewage sludge is a prohibited substance and its prior use must be evaluated for the 3-year transition period compliance
Sewage sludge is explicitly prohibited under NOP (7 CFR 205.203), and any application must be evaluated against the required 3-year transition period from last prohibited substance use.
Question 4: Which of the following substances is allowed as a livestock feed supplement under the NOP National List?
- Trace minerals (including copper sulfate) at nutritionally recommended levels (Correct answer)
- Synthetic growth hormones such as rBST
- Urea as a nitrogen source in ruminant feed
- Subtherapeutic antibiotics for disease prevention
Correct answer: Trace minerals (including copper sulfate) at nutritionally recommended levels
Trace minerals at nutritionally recommended levels are permitted under 7 CFR 205.603 for organic livestock, while hormones, urea, and subtherapeutic antibiotics are all prohibited.
Question 5: An organic operator wants to use a chlorine-based sanitizer on food-contact surfaces in a handling operation. Under NOP regulations, this is permissible only if:
- The residual chlorine in rinse water does not exceed maximum EPA safe water standards (Correct answer)
- The certifier provides written authorization for each use
- The sanitizer is listed on the EPA's approved organic sanitizer list
- An OMRI-listed alternative is unavailable in the operator's region
Correct answer: The residual chlorine in rinse water does not exceed maximum EPA safe water standards
Under 7 CFR 205.605, chlorine-based sanitizers are allowed in organic handling provided that residual chlorine levels in rinse water meet EPA maximum residue standards.
Question 6: A crop inspector notes that a neighboring conventional farm sprays pesticides near a certified organic field. What is the inspector's primary duty in this situation?
- Document the proximity risk and assess whether the operator's buffer zones and contamination prevention practices are adequate (Correct answer)
- Immediately revoke organic certification pending laboratory testing
- Require the operator to erect physical barriers before the next inspection
- Report the neighboring farm to the EPA for pesticide drift violations
Correct answer: Document the proximity risk and assess whether the operator's buffer zones and contamination prevention practices are adequate
The inspector must document the risk and evaluate whether buffer zones and contamination prevention measures in the OSP adequately address prohibited substance contact from adjacent land.
Question 7: Under the NOP, which of the following is the correct classification for Chilean nitrate (sodium nitrate) used as a crop fertilizer?
- A nonsynthetic substance restricted on the National List, allowed only when the total nitrogen from nonsynthetic sources comprises at least 20% of the total nitrogen applied (Correct answer)
- A fully prohibited synthetic substance that cannot be used in any organic production system
- An unrestricted allowed nonsynthetic substance that can be applied without limitation
- A synthetic substance allowed with a specific annotation permitting unlimited use in vegetable production
Correct answer: A nonsynthetic substance restricted on the National List, allowed only when the total nitrogen from nonsynthetic sources comprises at least 20% of the total nitrogen applied
Chilean nitrate is a nonsynthetic (mined) material but is restricted under 7 CFR 205.602, allowed only when the nitrogen from synthetic sources like Chilean nitrate is ≤20% of the total nitrogen applied.
PCO Prohibited Substances & Allowed Inputs 2
An operator claims that a soil amendment they used is 'natural' and therefore allowed.
As an inspector, what is the CORRECT basis for evaluating this claim?