Hydrogen Chloride (Crops 2021 Sunset Survey)

Overview and Survey Questions

This survey is for the substance HYDROGEN CHLORIDE

Uses in organic crop production: Allowed for delinting cotton seed for planting.

Reference on the National List: §205.601(n) Seed preparations. Hydrogen chloride (CAS # 7647-01-0)—for delinting cotton seed for planting.

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* 1. Please describe the types of organic products produced or handled on your operation:

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* 2. How many states are your products sold in? Are they exported to other countries?

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* 3. How many years has your operation been certified organic?

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* 4. Which organic products do you use the substance on/for? (e.g., lettuces, fruit trees, broiler chickens)

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* 5. What function does the substance provide and why is it necessary? (e.g., to control a specific pest or disease, sanitation, etc.)

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* 6. With what frequency does your operation use the substance? (e.g., seldom, as needed when a certain condition arises, routinely, etc.)

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* 7. Have you tried using any natural substances as an alternative to the substance? (e.g., natural oils instead of synthetic pesticides) If so, please describe the availability and efficacy of the alternative substances:

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* 8. Are there any other management practices that would eliminate the need for the substance? (e.g., hand weeding instead of using an herbicide; or using a particular harvesting practice to avoid a disease instead of using a fungicide). If so, please describe the efficacy of the alternative management practices:

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* 9. Describe the effects to your operation if you were to no longer be allowed to use this substance in organic production:

Agronomic effects (effects to health of crops or livestock):

Environmental effects (effects to environment if the substance was no longer allowed; effects to environment from potential alternatives):

Economic effects (effects to economic health of your operation):

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* 10. On a scale from 1 to 5 stars, rate the overall necessity of this substance for your organic operation:

Unnecessary (don’t need it at all)

Neutral (nice to have but could live without it)

Critical (would leave organic without it)

Unnecessary (don’t need it at all)

Neutral (nice to have but could live without it)

Critical (would leave organic without it)

Thank you for completing this survey!

OTA will incorporate this information into our comments to the NOSB. We also strongly encourage companies to submit their own comments directly to the NOSB regarding your use of this substance. If you would like assistance or guidance in submitting comments to NOSB, please contact Johanna Mirenda, OTA Farm Policy Director, at jmirenda@ota.com.