Inputs Made from Genetically Engineered Materials

How do the USDA standards address GMOs?

By Peter Bungum

In 2002, the OMRI Advisory Council developed a process for addressing genetically modified organisms (GMOs) in inputs, and OMRI continues to use this process. This article, as well as articles on GMOs as Processing Inputs and GMOs as Livestock Inputs, reflect OMRI's historic and current stance on addressing GMO materials in the absence of further regulatory clarification. 

The U.S. regulatory status of genetically engineered (GE) materials in inputs for organic systems is, to some degree, ambiguous. The Organic Food Production Act of 1990 does not mention biotechnology, genetic engineering or genetically modified organisms (GMOs), but the National Organic Program (NOP) standards adopted in 2002 prohibit the use of GMOs in the following way: “the product must be produced and handled without the use of excluded methods.” Here OMRI interprets “product” to mean the output or final food product. The NOP regulations and the guidance published to clarify the use of GE technology and GMOs do not specifically focus on inputs. In the 2011 Policy Memo 11-13, the NOP answered questions concerning GMOs, focusing on intent and process evaluation, and stating that crops containing unintended or inadvertent GE substances would not result in the loss of organic status. 

The organic industry relies heavily on products and waste materials from conventional farming systems, which can include GE products. The ability to source conventional byproducts as inputs for organic systems makes organic farming economically viable. For example, compost used on an organic farm can be made from nonorganic feedstocks, and soybean meal grown with conventional fertilizers and pesticides is an allowed input for soil fertility. 

Because the USDA organic regulations do not specifically address this question, OMRI developed a GMO review process in 2002. OMRI’s process prohibits the use of GE technology in products that have the potential to express the GE trait.4 OMRI considers the specific protein coded by GE DNA to be the ultimate expression of the trait, and depending on the Use Class of the product, OMRI may consider the presence or absence of the specific protein encoded by the GE DNA as a point of determination whether to allow or prohibit the ingredient. Additionally, products are not allowed to contain DNA that OMRI considers to be readily transferable to another live organism. 

To assist in making product decisions, OMRI follows a stepwise evaluation which is specific to each product Use Class: Crops, Livestock or Processing and Handling. These decision trees were designed by the OMRI Advisory Council and are not an official policy of the NOP or USDA, but they are frequently referred to and used by stakeholders. OMRI’s policy on GMO determination is presented at §2.3 of the OMRI Standards Manual; examples and the decision trees appear in Appendix B of the OMRI Standards Manual.