Hello all,

I am writing to ask for support and action on the NOSB recommendation for sunsetting Streptomycin for fireblight control.

Here are the facts that I see:

-          The crops committee has already decided that all antibiotics should be dropped from fruit production.

-          While antibiotics were originally produced naturally, the products we use are approved synthetics. I am not a chemist but I assume there may be a way of making strep organically like Entrust. I doubt there is enough demand that any company will develop a process for it. Synthetics should not be a part of organic production.

-          We are going to lose strep. There is no way that we will make it an approved product in the long term. I think the best we can hope for is a five year extended sunset and then it will be gone.

OTFA will take a positive approach with the NOSB and agree with phasing out antibiotics. We suggest we reduce the use by limiting it to post infection application and we promote the use of new products as protectants. We also promote and educate growers and nurseries about new resistant rootstocks.

Here are the steps we are taking to address this recommendation.

Submitting a written comment from the Organic Tree Fruit Association

Asking members and others to submit a written letter supporting this position

·         The OTFA requests an annotation to the current rule for streptomycin, limiting the use of antibiotics to post infection use only. We would like this limited use to be allowed for five years while growers learn to use the new protectant products and begin planting the field immune rootstocks.

·         The Organic Tree Fruit Association (OTFA) agrees with the NOSB in phasing out the use of antibiotics in tree fruit production. We feel the integrity of organic food production requires this synthetic substance be limited and eventually banned from organic fruit.

·         The choice of resistant varieties and rootstocks should be the first line of defense, but these varieties and rootstocks need to be commercially available. The delayed sunset would allow for a response to an increased market demand.

·         Additional products are available for use against fireblight. Biologicals-Serenade Max, Bloomtime, Biological FD, BlightBan C9-1 Barriers- Surround. Most of these products are new to tree fruit production or specifically to the prevention of fireblight. While studies have shown promise, the best practices will take a few years to develop. Fruit growers will need more information on how to use these products. OTFA intends to help develop practices and disseminate the information as it is developed.

Verbal comments at the NOSB meeting, supporting our concerns and position.

Again, I strongly urge all of you to submit a public comment in support to the NOSB. Public comments are due by April 10^th.  You can submit the comments at http://www.regulations.gov/#!documentDetail;D=AMS-NOP-11-0014-0001

Thank you for your consideration- Jackie Hoch