Carrageenan in organics, algae harvesting and hydroponics

October 26, 2016

National Organic Standards Board
1400 Independence Avenue, SW Room, 2648-So, Ag Stop 0268
Washington, D.C. 20250-0268

Docket # AMS-NOP-16-0049

Dear NOSB Members,

PCC Natural Markets is the largest consumer-owned retail grocer in the United States. We have 11 stores in six cities of western Washington and more than 56,000 active member households.

Our commitment to organic agriculture is built into our overarching Ends Policies that declare our purpose is to create an environment where the organic supply chain can thrive. We maintain certification as an organic handler for our produce, meat and seafood, bulk grocery, deli cheese, and espresso departments to ensure organic integrity is maintained to the shoppers’ cart. We also are an active participant in the Non-GMO Project.

We have comments on the following topics:

  1. Carrageenan
  2. Marine algae listings
  3. Hydroponics

I. Carrageenan

PCC Natural Markets strongly supports the subcommittee vote NOT to relist carrageenan.

Our primary reason is that the Organic Food Production Act’s clear intent is to not allow synthetic additives whose primary purpose is to recreate or improve texture.

See §205.600 (b) (4): “The substance’s primary use is not as a preservative or to recreate or improve flavors, colors, textures, or nutritive value lost during processing, except where the replacement of nutrients is required by law.” We believe that use of carrageenan has contradicted the intent of OFPA, is illegal, and that it must be delisted.

Our second reason is that carrageenan is not essential to any food. It is not necessary as an additive to heavy cream in order to make it whip. Certainly the market is demanding products with the fewest possible ingredients and no synthetics. It is not necessary; consumers want foods without ingredients that they would not eat as as standalone food on its own.

Our third reason is that organic consumers are rejecting carrageenan in the marketplace and choosing alternatives without carrageenan, such as non-organic, non-GMO cream. This has a net result of reducing purchases of organic foods.
Just because something comes from a natural source does not mean it is wholesome, healthful or safe. The trade group for carrageenan manufacturers (Marinalg) has concluded it “could not reliably determine” the levels of degraded carrageenan in products, and that industry data from 2005 revealed that levels of degraded carrageenan contaminate all food-grade carrageenan. Consumers are increasingly aware that research shows carrageenan is a known carcinogen in animal models and is linked to human gastrointestinal cancers, inflammatory bowel disease (especially ulcerative colitis), and other gastrointestinal diseases.

PCC Natural Markets has told our vendors we’re not accepting new, certified organic products with carrageenan.

OFPA clearly intended to disallow texturizers and we do not believe it should be allowed in organic foods.

II. Marine algaes: discussion document and listings

PCC Natural Markets appreciates NOSB’s plan to fully review the many seaweed species utilized in organic handling. The nine marine plant materials currently listed under §205.606 can be derived from many different seaweeds or algae, and some may have ecological consequences when harvested. Seaweeds are integral species within marine ecosystems around the world, and without considering sustainable harvesting techniques there may be significant harmful effects. Some main seaweed species commonly used in organic production include, but are not limited to: rockweed (Ascophyllum nodosum), sea bamboo (Echonia maxima), Irish moss (Chondrus crispus), Pacific Kombu (Laminaria japonica), and wakame, (Undaria pinnatifida).

Seaweeds, such as rockweed, Pacific Kombu, and wakame contribute to a highly productive habitat. They help reduce the physical stresses of the intertidal habitat and provide a habitat and food source for numerous invertebrates and fish. They also maintain water quality and provide a physical barrier against waves, protecting the shore.
That’s why certain species that are slow to regenerate from harvesting or have substantial ecological repercussions from their removal may not be compatible with organic principles. NOSB’s review of marine plant materials should identify these species and develop recommendations that would restrict their use for marine materials on the National List. PCC urges you to refer to the research submitted by the Center for Food Safety and Beyond Pesticides on this subject.


A lack of seaweed within a marine ecosystem may have many ecological consequences. According to the Maine Department of Marine Resources, studies have shown that by removing significant portions of kelp for a habitat, the abundance of dependent organisms, such as small fish, fell by as much as 85 percent. Without a thriving fish community, birds living around these marine ecosystems were less successful searching for food.

Seaweed also is critical to the marine environment because of its bioremediation capabilities. Influxes of pollutants along the coastline are common and bring contaminated water into the marine ecosystem. Algae are capable of taking up a wide range of pollutants, notably excess nutrients and heavy metals.
Brown algae in particular has been shown to be a highly effective in absorbing various metals, such as lead, cadmium, copper, zinc, and nickel, from aqueous solutions. Algae contaminated with heavy metals should not be allowed for use in organics.


Some seaweed species have relatively rapid growth rates and reproductive techniques that allow for replenishment when they’re harvested modestly. Seaweed harvesting must ensure the proper stem length is left attached to the underlying substrate. Reproduction will then occur from this stem, promoting a second generation of seaweed growth.

The species replenishment rate and frequency of harvest are, therefore, critical factors impacting future seaweed generations and the marine habitat. Failing to take species and harvest rates into account could mean seaweed plots are exploited quickly. Over time, this could result in long-lasting damage to the marine ecosystem.

Overharvesting may also mean the population eventually will consist only of young seaweeds that not only are smaller than older seaweeds, but may then be harvested before their full life cycle is completed. This could have impacts on future generations of seaweed.

Some studies have shown that fallow periods are necessary for sustainable harvesting. Fallow periods also prevent faster growing species from taking over. Many species reach peak size after two or three years.

Homogeneity within a seabed also is cause for alarm when it comes to the spread of disease or invasive species. As with terrestrial agriculture, focusing on the production of any few select species will lead to monoculture plots of those species. Monoculture seaweed plots also then are susceptible to diseases and may limit the resources available to other organisms in the ecosystem. Additionally, some native seaweed beds are wiped out to make room for more profitable species. While these seaweeds of interest can be grown all around the world, they currently are being introduced to non-native areas. Various studies have elaborated on the detrimental effects of invasive seaweed cultivation.

Rakes, knives, and mechanical harvesters are the three main methods for harvesting all species of seaweed. All three have drawbacks.

The use of rakes or knives is labor-intensive and time consuming, and runs the risk of human error in cutting plants past the length that would allow for regrowth of living stems. On the plus side, rakes and knives reduce the potential harm of by-catch and impacts to small fish, invertebrates, and amphibians.

Mechanical harvesters are designed to leave the proper stem length intact, but may have detrimental effects to the seafloor. Commercial harvesters claim kelp trawling removes only adult canopy kelps, leaving understory plants undisturbed. However, algae recovery is very slow after a disturbance.

Some mechanical techniques use blades, nets, suction methods, or dredges to harvest long the seabed. These techniques are non-selective, meaning they often lead to large numbers of by-catch. The capture and injury of non-target species caught as by-catch can have negative impacts on the biodiversity in these harvested areas. Conservationist groups are concerned that mechanical methods alter the physical orientation of the seafloor, damage sedentary species (such as corals and oysters), increase an ecosystem’s vulnerability to stressors, and in turn negatively impact the habitat productivity.

It may be both ecologically and economically efficient to curtail frequent harvesting and provide a fallow period for seaweed to rejuvenate after harvest.


A full review of marine materials allowed in organic production and handling is important to ensure that allowed materials are not negatively impacting the environment. This is not a small undertaking, and NOSB should invest the time and resources to ensure the review is productive.
Harvesting rates, techniques, location, regeneration rates, risk of invasive species, and biodiversity must be considered. PCC joins the Center for Food Safety in encouraging NOSB to request and conduct species-specific research to identify what marine species may be most suitable for organic and prohibit those whose harvest poses the greatest ecological risks.

III. Hydroponics

NOSB determined in 2010 that U.S. organic law requires plants to be grown in soil with the focus on enhancing soil fertility. The board determined that growing plants in water or air, using a mixture of natural and synthetic nutrients, does not meet the letter or spirit of OFPA.

No rules for hydroponics are in force, yet NOP has allowed certification of hydroponic operations (by USDA accredited agents) to grow plants in synthetic additives, in artificial lighting, and to label the products organic.
It is distressing that NOP has ignored this NOSB recommendation. We urge USDA to adhere to the conclusions of our organic peers on NOSB.

Thank you for the opportunity to comment,

PCC Public Affairs

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