Carcinogenic preservative in processed meat, synthetic amino acids in chicken feed, and a warning against compost contaminated with toxic food packaging

I’m speaking to you today from La Farge, Wisconsin.

I wish, like members of Congress, NOSB members were required to take an oath to protect and defend the spirit and letter of the law governing organics.

But I’m going to give each and every one of you the benefit of the doubt that that is your goal, placing it over and above corporate profit.

Celery Powder

The use of celery powder is a “synthetic nitrogen delivery system.”

Based on how it is bred, grown, and processed, this workaround is intended to deliver the same dangerous compound used as a preservative, albeit under a more innocuous name.

The answer to concerns of consumers from some organizations is to develop a certified organic version of celery powder.

How incredibly disingenuous. 

If the research is successful — and I don’t know any professionals who believe it will be (due to the copious amounts of nitrogen fertilizer required, which is unavailable in organically approved forms) — this would equate to developing a “certified organic carcinogen.” 

As I said, how disingenuous.

According to the Agency for Toxic Substance and Disease Registry, nitrates in celery powder react with amino acids in the digestive system to create nitrosamines.

These are reported to cause:

  • Non-Hodgkin’s lymphoma
  • Cancers of the esophagus, larynx, stomach, bladder, colon, prostate, and thyroid

Do you think that sounds like a material that would comply with the law requiring approved substances not be deleterious to human health?

The International Agency for Research on Cancer, an arm of the World Health Organization, assessed the risk of nitrates and processed meats and classified them as a group 2A “probable carcinogen.”

They also state that, in addition to being a likely carcinogen, foods preserved with celery powder may contain even more nitrates and nitrites than foods preserved with synthetically manufactured versions of the same preservatives.

I ask this body to err on the side of caution by reviewing the citations in our full written comments, including statements from Consumer Reports and the American Cancer Society, before siding with industry lobbyists.

In closing, I’d like to add that we have certifiers violating the law by accepting hundreds of thousands of dollars in payments, over and above certification fees, from some of the agribusinesses they certify (and certifiers are here today lobbying on behalf of their “clients”).

We have unregulated material review organizations where, literally, 99% of their revenue comes from commercial entities with interests in materials.

It’s imperative that this body act impartially to protect the integrity of the organic label, the health and well-being of organic eaters, and the livelihoods of farmers and ethical business people.

Thank you for your time.

Mark Kastel

Executive Director



I want to remind members that whatever is in compost will bioaccumulate in the soil and that certain plants are very adept at uptaking those compounds. We’ve already had disasters.

DL Methionine

Please understand that, despite the industry telling you that this material is necessary for humane animal husbandry, it is a production tool given to increase egg laying.

In terms of feather pecking and other aggressive behaviors towards their flock mates, these problems do not exist on family-scale operations where birds are allowed legitimate access to the outdoors. Unfair competition is preventing those farms from scaling-up.

In all the commercial organic broiler operations I have visited, generally with 20,000-30,000 bird buildings, I’ve never seen a single bird outside. We aren’t talking about porches here. 

Even in most moderate-sized organic laying operations, I’ve never seen more than 1-3% of the birds outside at a given time.

We’re not talking about new rulemaking being phased-in. We’re talking about certifiers that are not enforcing the current law and the NOP looking the other way. If the laws were enforced, methionine would not be necessary for the preservation of these birds.