7.1 Apiculture #
Does the three-year transition period apply to apiaries? (121)
No. The apiary site must comply with 184.108.40.206 which specifies that 12 months of organic hive management is required prior to the harvest of organic honey.
New production sites in apicultural operations #
When a certified organic apicultural operator wants to add new production sites, does the application for those new sites need to be received 12 months prior to first harvest of honey on the new sites? (312.1)
No. Organic operators just need to list new production sites (fields, gardens, etc.) on their annual application for certification to be inspected along with the rest of the operation.
Does the CB need to inspect new sites before they are added to an existing organic honey operation? (312.2)
No. The operator must document that the new sites comply with organic standards, and include this documentation in their annual application for certification.
Buffer zone #
Is a transition period required between the last use of a prohibited substance in the buffer zone and the time when the bees are feeding? (124, 278)
No. There is no set transition period required for the apiary buffer zone. No prohibited substances, other than fertilizers (see 7.1.10), can be present when bees are foraging. As such, consideration must be given to chemically persistent materials previously applied that could still present harm to the bees. For example, the nectar and pollen of plants grown from seed treated with neonicotinoid pesticides can contain residues of the pesticide.
Does any use of a prohibited substance within 3000 metres of an apiary automatically disqualify the honey from achieving compliance with the standard? (115.1, 277)
No – not always. All types of fertilizers are allowed. However, sewage sludge, GE crops and agricultural pesticides that prohibited by the standard, including systemic seed treatments, are not allowed (7.1.5). Other sources of potential contaminants should be assessed as to the level of risk they present. For example, if the risk of contamination is low, products prohibited by the Standard that are used by households within the buffer zone and be tolerated.
What potential sources of contaminants within the buffer zone need to be considered? (115.2)
Organic honey production typically cannot take place if the following are found within the buffer zone: high-density housing areas, such as subdivisions; golf courses; garbage dumps or landfill sites; industrial complexes; very busy roads; or commercial non-organic greenhouses/nurseries. There may be extenuating circumstances that must be assessed by certification agencies in each case.
Buffer zones of 3 km may be reduced if natural features restrict bee travel and abundant “compliant forage” is present (7.1.10 a). In this context, “compliant forage” means flowering plants that meet the requirements of the standard even if they are not certified organic.
Adding a nucleus hive #
When adding a nucleus hive to an existing organic apiary, shall it be considered as introduced bees (which are subject to commercial availability) or a replacement colony (which must be produced within operation or another established organic apiary)? (432) – 19 Apr 2019
An added nucleus hive (including both a queen and other bees) would be considered a replacement colony and therefore would be required to be produced within the operation or obtained from another established organic apiary (7.1.9).
Wax for foundation and comb foundation #
Can plastic foundation that has been dipped in non-organic beeswax be used when organic beeswax dipped plastic foundations are not commercially available? (506.1) – Dec. 18, 2020
No. The wax covering the plastic foundation must be organic (220.127.116.11).
Can non-organic wax comb foundation be used when organic sources are not commercially available? (506.2) – Dec. 18, 2020
No. Non-organic comb foundation may not be used. Organic comb foundation from the operation or from another source is required. (18.104.22.168)
Treated hives #
Reading clause 22.214.171.124, does the term “treated hive” apply to the containers present at the time of the treatment only or does it also apply to any clean or untreated temporary containers, such as honey supers in summer time, and unused frames? (391)
The term “treated hive” applies to the container(s) present at the time of the treatment, and not to supers or frames removed from a hive prior to treatment. However, the wax from any honey super frame or brood frame of the treated hive present or added during the 12-month transition period would need to be replaced with organic wax at the end of the transition period in order to return to organic production.
The bees in the colonies, that is the hives plus bees that were treated must also complete a transition period (126.96.36.199 in 32.310)
Non-organic sugar for feeding colony #
188.8.131.52 a permits the use of non-organic sugar for colony feeding under certain conditions. Does this exception allow the use of sugar derived from genetically engineered beets? (363)
No. The allowance in 184.108.40.206 a is for non-organic, non-GE sugar to be used as the GE prohibition in 1.4 supersedes.
Organic beeswax #
Can beeswax be certified as organic? (442)
Yes. Beeswax generated by organic apiculture operations can be certified organic (7.1.1) with two exceptions: 1) when comb foundation was not sourced from organic hives (220.127.116.11); and, 2) when hives have been treated with synthetic allopathic drugs (18.104.22.168).
Pollen substitute #
Does 32.310 22.214.171.124 (a) allow for the use of bee pollen substitute comprised of organic soy and yeast? (572) 7 Oct 2022
No. The only alternative food source permitted in the event of a regional or seasonal shortage of forage and for winter feeding of colonies, are honey and sugar as described in 126.96.36.199.a).
7.2 Maple products #
Buffer zone #
How close to a certified sugar bush can the use of a prohibited substance be allowed, without compromising the certification of the sugar bush? Are buffer zone needed? (13)
A sugar bush has the same buffer requirement as other crops. A minimum of 8 metres is generally required. However, this can be reduced if there are features that effectively buffer the sugar bush, such as permanent hedge rows, windbreaks, or roads (5.2.2). Also, depending on the circumstances, more than 8 metres may be necessary to prevent contamination.
Magnetization of maple water #
In maple production, is it permissible to use an anode that magnetizes maple water in order to keep the minerals in suspension and prevent calcareous deposits in the pan? (304)
No. It is prohibited to use technologies that may alter the intrinsic qualities of the product (7.2.7) and magnetization has that potential.
Use of filtrate for cleaning #
Can the filtrate be used to clean evaporators during the season? (215)
Yes, the filtrate (water that passes through the membrane in the osmosis technique of removing water from sap) may be used to clean the evaporator (188.8.131.52 a 3)
Well water through reverse osmosis #
Does well water meet the criteria for potable water if it has been run through a reverse osmosis filtering system? (430) 19 Apr 2019
Yes. Water purified by reverse osmosis is considered potable.
Rinsing and cleaning of osmosis membrane #
Is it necessary to verify the quality of water used for cleaning/rinsing the osmosis membrane in maple equipment? (230)
Yes. If water is used during the production season, for cleaning/rinsing the osmosis membrane, potability needs to be confirmed (i.e.,, it must meet drinking water standards). (184.108.40.206 a 3)
Heating option for maple syrup evaporator pans #
Can natural gas be used to heat maple syrup evaporator pans? (346)
Yes, heating options, such as wood, heating oil, electricity, propane and natural gas, etc., that do not negatively affect the integrity of the syrup are permitted.
Waxed cardboard as fuel #
Can waxed cardboard pellets be used as fuel in maple syrup evaporators? (373)
Yes. As long as the operator can demonstrate that this type of fuel does not affect the integrity of the maple syrup.
7.3 Mushroom production #
Disease control #
In the production of organic mushrooms, can table salt be used as a spot control measure for disease on mushrooms? (132)
Yes. Refer to the “salt” listing in PSL Table 4.2, column 2.
Does the substrate for organic mushrooms need to be a) certified organic, b) composted? Can conventional straw be used as compost feedstock for a composted substrate used to grow organic mushrooms? (4, 178)
Standard 220.127.116.11 through 18.104.22.168 outlines the requirements.
|Wood||No, but must be free of prohibited materials.||No|
|Manure||5.5.1 (32.310) outlines acceptable sources. Organic must be used if available.|| Yes, and:
1) the compost feedstock requirements in PSL Table 4.2 apply; and,
2) Either the ‘compost produced on the farm’ or the ‘compost from off-farm sources’ criteria in PSL Table 4.2 apply.
|Other agricultural substances (hay, straw or grains, etc.)||Yes if available.|| 1) If organic is not available then the materials must be composted.
2) If composting the:
a) the compost feedstock requirements in PSL Table 4.2 apply; and,
b) either the ‘compost produced on farm’ or the ‘compost from off-farm sources’ criteria in PSL Table 4.2
Non-agricultural substances as mushroom substrate #
Can non-agricultural substances including peat moss be used as a mushroom substrate/growth medium or as a casing layer on top of a mushroom bed without being composted first? (385)
Peat moss is a substance in Table 4.2 of 32.311 which has no specific use or restriction of usage. Therefore, it can be considered as an applicable entry for mushroom production under 7.3.1 of 32.310. Other non-agricultural substances of Table 4.2 can be considered as well unless their annotations restrict the substance to a specific usage which does not include mushroom production. Composting is only mandatory for substances of conventional agricultural origin in mushroom production (22.214.171.124).
Spawn marketed with growing substrate #
When marketing mushroom starter materials containing living spawn (e.g., mycelium loose in grain/or sawdust or embedded in a grow block/log/loaf/brick) as organic, are the components other than the mycelium exempt from the calculation of total percent organic ingredients in the final product? (471) – 17 February 2020
Mushroom starter materials in any format do not fall under Clause 9, therefore a calculation of the percentage of organic ingredients is not applicable. Spawn must comply with 7.3.3 and the makeup of the starter material must comply with 7.3.2.
Feather meal as mushroom substrate #
Can feather meal, compliant with Table 4.2, be used as a mushroom substrate without being composted? (344)
Feather meal made from organic poultry could be used as a mushroom substrate without being composted. 32.310 126.96.36.199 requires that other sources of feather meal be composted.
Frass from insects in mushroom production #
In organic mushroom production, is insect frass considered an ‘other agricultural substance’ as per CAN/CGSB-32.310: 188.8.131.52, and would insect feed need to be organic? Or would the final product need to be composted? (548.2) – 15 June 2022
Without a listing in the PSL, insect frass shall be considered as Animal manure. From an organic source or not, insect frass, shall be composted for use in mushroom production as per 184.108.40.206
Non-organic Potato Dextrose Agar to propagate mycelium #
Can non-organic Potato Dextrose Agar (PDA) be used to propagate mycelium (non-fruiting genetic material) to produce organic mushroom spawn? If so, can it include compounds and micronutrients that are not listed? (451) – 26 Sep 2019
Yes. Non-organic PDA is permitted if it can be demonstrated that organic is not commercially available and the non-organic PDA does not contain GE ingredients (see Table 4.2, Agar) or compounds not listed in Table 4.2 (column 2) of 32.311 (see 32.310 7.3.3).
Hydrated lime in mushroom production #
Can hydrated lime be used as a spot treatment, disease control or disinfectant in organic mushroom production? (562) 8 August 2022
Hydrated lime is permitted for disease control as indicated in Table 4.2 listing, but it is not a disinfectant.
7.4 Sprout, shoots and micro-greens production #
Parallel production of sprouts, shoots and microgreens #
Can organic and conventional sprouts be produced in parallel in the same facility if grown in visually distinguishable containers? (211) 3 May 2022
Section 7.4 of the Standard does not contain or reference any restrictions related to parallel production; therefore, organic and conventional sprouts could be produced in the same facility. As per 4.4.3, an identification system to distinguish organic and non-organic sprouts is required, which may include visually distinguishable containers and other methods.
Sprouts or shoots #
Please describe the difference between shoots and sprouts. (191)
Unlike sprouts, which are usually grown in water, shoots tend to be grown in a growth medium, such as a potting mix. Shoots tend to be cut, while sprouts are harvested and consumed with the roots attached. Production for both must comply with all criteria in 7.4 (Sprouts, shoots and micro-greens production).
Plants sold in pots #
Plants harvested within 30 days of planting fall under clause 7.4 and require the use of organic seeds. What if they are sold in pots to a customer who keeps them beyond the 30 days? Would they still need to be grown from organic seeds? (293)
If the plants are not “generally harvested within 30 days of imbibition” they do not fall under 7.4 (shoots and microgreens) and the organic requirements in 5.3 a) apply.
Soil volume in microgreen production #
Is the soil container volume criteria outlined in 7.5.2 (32.310) applicable to containerized microgreen production (7.4)? (400)
No. 7.5.2 is not applicable to crops harvested within 30 days of imbibition such as microgreen production.
Seed cleaning #
Can synthetic acetic acid be used for the cleaning of seeds used for sprouts, as seeds are neither considered as food nor as a plant (PSL Table 7.3)? (210)
No. Only substances listed for seed cleaning in Table 4.2 (column 2), such as peracetic acid, may be used (see 7.4.7).
Substances for sanitizing seeds for sprouting and sanitizing sprouts, shoots, microgreens #
Which substances are compliant for sanitizing seeds for i) sprouting, ii) shoot and microgreen production, and iii) for sanitizing harvested sprouts, shoots or microgreens? (303)
Substances used for these activities are limited to the following substances of Table 4.2 (column 2): hydrogen peroxide and peracetic acid (peracetic acid listing) and hot water (water listing) (32.310 – 7.47). Chlorination of water shall not exceed maximum levels for safe drinking water. (Table 7.3).
Sprout rinsing #
What are the quality requirements for water used to rinse sprouts, shoots and microgreens? (84)
Excluding chlorine concentration restrictions (see Q&A 150) water quality criteria for sprouts, shoots and microgreens rinse water is no longer specified in the 2020 organic standard. The expectation is that sprouts, shoots and microgreens operations will have a water quality program in place to address overall food safety requirements.
Is the rinsing of sprouts, shoots and microgreens with chlorinated water allowed? If so, in what concentration? (150)
Chlorinated water may be used to rinse sprouts, shoots and microgreens provided the level of chlorine does not exceed the limit for safe drinking water (see 7.4.9 referring to 8.2, and 8.2.1 connecting to the ‘Chlorine compounds’ listing in PSL Table 7.3).
Inert substances and materials as growing media #
Can inert substances and materials be used in production of sprouts, microgreen and shoots produced in water? For shoots and microgreens produced in soil? What about growing on burlap cloth? On coconut coir/fibre? Can the ‘soil’ be sterilized? (299) (358)
For both water-based and soil-based systems, inert containers made of stainless steel and food-grade plastic are permitted (7.4.3). Growing media use is restricted to soil-based systems (7.4.6) and must contain “both a mineral and organic fraction” (7.4.6). Thus sterilizing the ‘soil’ would be counter indicated considering the likely presence of beneficial organisms in the organic fraction required in the growing medium. Burlap, coconut coir or coconut fibre could be used as part of the ‘soil’ or could function as the ‘container’ in a soil-based shoot or microgreen production system. The operator must confirm that these materials are free from and/or have not been treated with prohibited substances.
Organic bean sprout production #
Can bean sprout grown hydroponically be certified organic? (245)
Hydroponics is defined as the “cultivation of plants in aqueous nutrient solutions without the aid of soil” (3.34). As nutrient solutions cannot be used in organic sprout production (7.4.5), it is not considered hydroponics. 7.4 addresses the production of sprouts.
7.5 Crops Grown in Structures or Containers (formerly “Greenhouse crops”) #
Soil/soil-less mix #
Can a greenhouse operator take soil from outside and move it into the greenhouse? (267)
Yes, providing the soil has not been exposed to substances prohibited by the Standard for 36-months (See ‘soil’ listing Table 4.2 – column 1).
Does the use of a “peat moss/compost etc. mix” satisfy the requirements of 220.127.116.11 for “soil used in a container system”? (25) 8 August 2022
It depends. 18.104.22.168 allows for container-grown production with soil. A compost and peat moss mixture may not contain the mineral fraction that is required, depending on the compost feedstocks. This fraction of the mix needs to contain at least 2% minerals by dry weight or volume. This same soil requirements applies to annual seedling production per 5.3.3. Compliant soil is not required for early propagule stages before nutrition is necessary. (Ref Q&A 204.2).
Growing media for seedlings #
Can annual seedlings be grown in a soilless media, even for the initial phase of propagation (1-2 weeks), and comply with organic standards? (204.1) 7 Oct 2022
It depends. Hydroponic and aeroponic production are prohibited, meaning that any plant nutrition must take place in a soil-based media that is compliant with 22.214.171.124 (per 5.3.3). However, initial propagation of annual seedlings, when no plant nutrition takes place, can happen in a soilless media.
Growing media for propagules #
126.96.36.199 describes acceptable soil composition for container systems. However, layering and cutting propagation techniques may require an initial soilless rooting medium that provides no nutrition to propagated plants (water, moist air, perlite, vermiculite, sand, peat moss). Can soilless media be used for cutting and layering plant propagation? (204.2) 7 Oct 2022
Plant nutrition must be based on soil as defined in 3.73 and 188.8.131.52 of CAN/CGSB-32.311. This nutrition cannot be brought through hydroponic or aeroponic production methods. However, when a propagule needs no nutrition (cutting, layering, initial seed sprouting stage), it is possible to use a medium that does not meet criteria of 184.108.40.206 of CAN/CGSB-32.310 as long as it does not contain prohibited substances (see 1.5) and it is composed only of substances listed in Table 4.2 (Column 1) of CAN/CGSB-32.311.
Use of a prohibited fungicide in greenhouses #
If a grower covered the soil in a greenhouse container system and then sprayed a prohibited substance, can the soil be used in containers in subsequent cropping cycles if tests show that it does not contain any residues of the prohibited substance? (477.1) – 29 June 2020
No. Residue testing cannot be used as a substitute for required organic management practices; organic operators must not apply prohibited substances as per 1.5.
Could this container soil be used for organic production after 12 months? (477.2)
No. Even though the soil was covered, and testing was done 7 months later showing no residue – 36-months of transition is needed from the fungicide application for a compliant soil (see ‘Soil’ Table 4.2 of PSL). The 12-month period is only applicable to new operations per 5.1.1. Furthermore, keep in mind it is up to the CB if there was deliberate abuse alternating between organic and non-organic methods in this production unit which may lead to decertification. (See SIC Q&A #6)
Composition of growing media #
Does a growing medium containing a pinch of sand, 10% compost and the balance peat moss meet the requirement of 220.127.116.11? (454.2) – 2 December 2019
No. The intent of this clause was to establish the profile of the required soil structure to ensure sufficient air and water drainage and nutrient holding capacity.
May coconut coir be part of a growing medium used in container growing systems? (454.3) – 2 December 2019
Yes. Coir may be used. It is covered by the “Plants and plant by-products” listing in Table 4.2
Could a soil media blend of coir, peat moss, perlite and compost be used to grow perennials? (454.4) – 2 December 2019
No. Soil used in containers to grow perennials should also contain a mineral fraction that is not covered by perlite. It should contain sufficient sand, silt or clay to contribute to the physical soil structure.
Scope of 18.104.22.168 #
Does section 22.214.171.124 refer to all growing media products used in a container system, or solely professional products used in greenhouse growing? (498.1) 14 June, 2021
Yes. 126.96.36.199 refers to any growing media used in a container system.
Applicable exception in 188.8.131.52 #
Does the exception for seedling/starter mixes (184.108.40.206 d) only pertain to the 10% compost, or is there an exception for the 2% mineral fraction as well? (498.2) 14 June, 2021
Seedling/starter mixes may contain less compost, but must contain a 2% mineral fraction per 220.127.116.11 c & d.
Compost in seedling/starter mixes #
Do seedling/starter mixes need to contain any compost at all? (498.3) 14 June, 2021
No. 18.104.22.168 d does not indicate a minimum compost content.
Disposal of greenhouse soil #
Under 32.310, clause 7.5.9, can operators dispose of greenhouse soils in cases where there is a risk of disease or pest propagation? (465) – 17 February 2020
Disposal of greenhouse soil to minimize the spread of a transmissible pest or disease is permitted only when a regulatory directive has been issued requiring such a practice “treatment” (32.310, 4.4.6). In the absence of such a directive, greenhouse soils must be reused as per 7.5.9.
Soil and compost requirement in greenhouse production #
Is biochar in a soil mix considered part of the mineral fraction? (424.1) – 19 Apr 2019
No. Biochar is considered organic matter.
Are worm castings and vermicompost considered compost, and could they be used for the 10% requirement in 22.214.171.124 d? (424.2) – 19 Apr 2019
Yes. As they are both “products of carefully managed aerobic processes” (see ‘compost’ definition 3.19). Please also refer to 32.311 Table 4.2 Worm Castings.
Can the additional compost applications required in 126.96.36.199.a be in the form of compost tea? (424.3) – 19 Apr 2019
No. Compost tea does not contribute to organic content of the soil. Its use is twofold. A source of soluble nutrients and beneficial microorganisms.
Mineral fraction of soil in containers #
For container production systems in greenhouses is the mineral fraction requirement (188.8.131.52c) met if the “soil” contains either perlite or vermiculite? (408)
No. That was not the intention of the standard. Even though both are heated forms of mineral compounds (perlite/volcanic glass, vermiculite/expanded mica) the requirement is some sand, silt or clay would be included in soil mixes.
Rock mineral compounds as mineral fraction #
Can rock mineral compounds, such as dolomite or gypsum, added to a soil/growing media be considered part of the mineral fraction as required in containerized production (184.108.40.206 e)? (563) 19 December 2022
Yes. Sand, silt and clay as described in 220.127.116.11 e) refers to particle size and would encompass rock mineral compounds (excluding perlite and vermiculite) permitted by this standard
Forestry by-products as greenhouse compost #
Can bark or forestry by-products alone fulfill the 10% compost criteria for greenhouse container growing? (461.2) – 17 February 2020
No. Compost is a product of a carefully managed aerobic process (32.310 3.19).
Scope of 18.104.22.168 #
Does 22.214.171.124 apply to determinate (non-staked) varieties, or only to indeterminate (staked) varieties grown in containers? (342.1)
126.96.36.199 covers containerized semi-indeterminate and indeterminate varieties grown in greenhouses typically for an extended period (e.g., 7 months or more) and that are supported by a trellis system (e.g., stakes, strings or wires). 188.8.131.52 is not applicable to non-staked determinate varieties or crops with shorter production cycles (e.g., where harvest is finished within a period of less than 7 months), but the volume of soil needed is commensurate with the length of the crop cycle. See 184.108.40.206.
Artificial lighting as a supplement to natural light #
Are systems reliant only on artificial lighting allowed under COS? (342.2)
Microgreens and shoot production may use systems reliant only on artificial lighting. For greenhouse crops, however, artificial lighting is permitted only as a supplement to natural light (see 7.5.4). Note: The organic greenhouse standards were not developed with growth chamber-like systems in mind.
Sunlight calculation in greenhouse #
How much sunlight is needed to fulfill the requirement of primary source of light as indicated by 7.5.4? (551) – 15 June 2022
The photosynthetically active radiation (PAR) coming from sunlight must exceed 50% of the light delivered to the photosynthetic area over the total crop production period. This will need to be demonstrated by the operator If supplemental light is used (beyond on-farm seedling production).”
Parallel production #
Does the exemption from the rule prohibiting parallel production allow greenhouses to transition only part of their operation? (109)
Yes, the propagation portion of the operation may practice parallel production per 5.1.4.
Is parallel production prohibited for greenhouse crops? (285)
The Standard prohibits parallel production in annual crops including those grown in greenhouses with exceptions outlined in 5.1.4. However, if visually distinguishable organic and non-organic crops are grown, this is considered to be split production (5.1.3), which is permitted if: greenhouse systems (air, water, etc.) are sufficiently segregated so as to eliminate contamination risk of the organic crop by prohibited substances (1.5).
7.6 Wild Crops #
Wild seaweed #
Can wild seaweed meal be certified? (244)
Yes, until January 14, 2021, seaweed meal can be certified under Section 7.6 Wild crops if it is used for food or livestock feed. After this date, seaweed products will need to be certified under the Organic Aquaculture Standard CAN/CGSB-32.312.
Buffer zone around wild crops #
Can wild harvest sites be located less than one kilometre from potential sources of environmental contamination such as golf courses, etc., if it is demonstrated that the wild crops are completely isolated from contact with prohibited substances by a clearly defined buffer, in accordance with section 7.6.4? (343.1)
No. There is no latitude in 7.6.4 to reduce wild crop buffer zones, where required, to less than 1 km.
In the event that wild harvest cannot be certified (if 1 km requirement cannot be attained), is parallel production prohibited between crop production (plantation) and wild harvest? If so under what circumstances might it be allowed? (343.2)
If the wild harvest cannot be certified, parallel production from an existing organic plantation would be permitted; however, a new organic plantation could not be established. (3.52, 5.1.4 and 5.1.5)
Weed control for wild crops #
Can salt be used for weed control on the ground where organic wild harvested crops are stored? Even if that storage area is on a rock outcrop? (367)
No. First, the wild harvest area is to be “relatively undisturbed” (7.6.3) so using salt as an ‘herbicide’ in the area, even on a rock outcrop, is prohibited as it would change the ecosystem. Secondly, salt is not authorized as an herbicide in Table 4.
Honey harvested from wild bees #
Can honey harvested from wild bees be certified to the “Wild Crop” requirements in Clause 7.6? (382)
No. Wild animal products are not covered by the Canadian Organic Standards.
7.7 Organic insects #
Gelling agents for crickets #
Can gelling agents such as guar gum and xanthan gum be added into drinking water/feed for crickets? This will stop crickets from drowning especially as they are small when they first hatch. (511) 24 March 2021
Yes. Gelling agents are permitted providing they are organic. Non-organic gelling agents are not permitted as none are listed in PSL Table 5.2.