"Nutrient additives" in organics

November 11, 2011

Dear National Organic Standards Board,

As the largest consumer-owned and consumer-operated grocer in the nation, PCC Natural Markets urges the NOSB to reject the petition for DHA Algal Oil and ARA single cell oil by Martek Biosciences Corporation. We are thankful for the research done by the Cornucopia Institute, documenting many concerns and questions about this proposed additive, and ask NOSB to accept Cornucopia’s comments as the concerns of organic consumers, verified by data from our own consumer survey (attached).

We sympathize with the volume and range of topics demanding attention that makes such research virtually impossible by NOSB members, and we understand Handling Committee members did not have PCC’s survey data (or Cornucopia’s information) in hand before casting their votes. It’s difficult to imagine the vote would be the same if you had.

PCC’s survey of organic consumers on vitamins and mineral supplements, and additives to food deemed “nutrients,” was prompted after NOSB members asked us questions at the April meeting that we did not have adequate information to answer well. Realizing our 47,000 member households are an ideal target population to poll, we designed a survey to collect the information requested.

The findings show that while 88.5% of shoppers take at least one dietary supplement on a regular basis, 52.9% believe most vitamins and minerals are made from natural ingredients. Almost 8 out of 10 (77.8%) shoppers do not believe FDA ensures that added nutrients, such as omega 3s, are effective and safe before allowing them on the market.

Only about 16% of shoppers deliberately choose foods because they’re labeled as containing added vitamins, minerals or other nutrients. Six of 10 shoppers would not buy products to which omega-3s made from synthetic sources have been added. Nearly 90% would not purchase foods with omega-3s made with synthetic additives or agents, including hexane, glucose syrup solids, and modified starch. A significant portion (11%) would not purchase foods with any added omega-3s, even if derived from natural sources. We interpret these findings to indicate that organic shoppers consider the organic foods they buy to be healthy inherently, without additives of any kind.

We remind NOSB that PCC already has pulled “organic” infant and baby products containing Martek’s unapproved DHA and ARA additives that reportedly are linked to unhealthy reactions in some infants. We ardently urge NOSB to uphold its mandated responsibility to honor the formal petition and review process and not surrender this unique authority by deferring to FDA standards for expediency in managing petitions. NOSB’s authority was hard-fought and hard-won and is central to consumer trust in the organic label.

At the time the Harvey lawsuit ended in 2005, there were 38 synthetics on the National List of Allowed and Prohibited Substances. Today, the number of synthetics has more than tripled, a dirty detail that raises questions about the very purpose and meaning of the organic label. No other topic in organics (except animal welfare) so jeopardizes the value of the label as the exploding number of synthetics allowed.

The National List was instituted to allow ONLY for synthetics lacking an organic version or substitute. In the case of the DHA Algal Oil and ARA Fungal Oil on petition, there already are several organic or NOSB-approved alternatives, including fish oil and egg yolk. Approving such multi-ingredient products as additions to the National List should not even be considered since they are not necessary and almost certainly will expose organic standards to warranted criticism.

We submit the results of the PCC Shopper Survey of Nutrient Additives — conducted in August and September of this year and aggregating the responses of 1,430 organic consumers — as support and documentation for our remarks.

Thank you,

Trudy Bialic, Director of Public Affairs
PCC Natural Markets

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