The US Department of Agriculture recently released the Recommendations and Discussion Documents late yesterday for the November meeting of the National Organic Standards Board. A copy of the relevant section is attached in pdf format. In addition, the notes from the Crops Subcommittee through mid-August are also available.
The Crops Subcommittee work is organized in three parts:
I. Crops Subcommittee states that water based production systems are not allowed under current regulations. The Crops Subcommittee proposes to allow water based production with a vote failing to approve the measure by a 2 to 5 vote. Nonetheless, the Crops Subcommittee will forward the recommendation to the full NOSB with the idea that it will fail to gain the 10 votes (of 15 members) necessary to recommend a change to policy.
II. If the NOSB chooses to recommend to not allow water based production systems, the Crops Subcommittee would like the NOSB to consider making clear regulations pertaining to what container systems using “solid” substrates as a growing media would be allowed. The Crops Subcommittee is distributing a discussion document regarding concepts that need to be debated further prior to recommending new regulations limiting container production systems.
III. The Crops Subcommittee believes that it will take what it learns over the next few weeks to create a proposal recommending specific changes to the regulations regarding non-water based container systems to be ready for the Spring 2017 NOSB meeting for a vote.
Call for Prohibition of Hydroponic and Aquaponic Systems
The first section contains a 2 to 5 vote against changing the current standard to allow for water based systems (“bioponic”) systems in the USDA standard. The Crops Subcommittee claims that the 2010 recommendation established the NOSB position on water based systems; therefore, the technical proposal is to state that they are proposing to overturn that existing NOSB policy and would need a 2/3rds majority to make a change to the policy. In short, rather than stating that they are attempting to overturn existing USDA policy and needing a 2/3rds majority to recommend changing the USDA policy, they have turned NOSB operating procedures on their head to require a 2/3rds majority to change the 2010 NOSB recommendation.
Crops Subcommittee Modifies Task Force Definition of “Bioponics”
The Crops Subcommittee changed the definition of “bioponics” given in the USDA Hydroponic and Aquaponic Task Force Report – “A contained and controlled growing system in which plants in growing media derive nutrients from natural animal, plant and mineral substances that are released by the biological activity of microorganisms.” The new definition made by the Subcommittee added the words “and delivered in water” to the definition. While this technically makes nearly all fertigation systems part of “bioponics,” it is likely that the Crops Subcommittee is attempting to isolate production methods such as misting, ebb and flow, deep water raft and NFT systems from other forms of container growing systems.
Water Savings of Organic Systems Not Relevant
It is interesting to note that the Crops Subcommittee report including the assertion that water savings are not really relevant in the consideration of organic production systems and whether water based systems can be certified as organic by USDA as found in the following quote from the CS analysis.
“While production of the crop in a bioponic system can require less water to grow the crop than field growing, this ignores the earth’s water cycle, where “excess” water is not lost or wasted, but is continually recycled either by recharging the ground water resource or evaporating into vapor to produce rain, snow or fog.”
Discussion Document Regarding Substrate Container Systems
The second section discusses changes that need consideration if water based container systems are excluded from the USDA organic program, but some containers are still included. It sources information primarily from the 2010 NOSB Recommendation, both the pro- and anti-container sections of the Task Force report and regulations of other countries in its discussion of certain points and definitions. Again, it is not in a proposal format and would not be ready for a formal vote at the Fall NOSB meeting. It is intended to be the basis for the discussion so that a formal proposal will be available for a vote at the Spring 2017 NOSB meeting.
Exceptions from Crop Requirements Can Be Interpreted for Certain Crops in Existing Regulations
The CS Report also makes certain assumptions that certain plants and methods are automatically part of the USDA program if they are mentioned in some way in the current regulations. Since sprouts have an exemption for chlorine use and plantlets need to be grown from organic seeds when available, the Crops Subcommittee asserts that those plants are accepted by regulation to not have to be grown in the soil. [Editor’s note – I could not find anything in the current regulations making the direct claim that those products are exempt from crop requirements.] They also assert that mushrooms are like yeast and microorganisms, so they should not be subject to the crop production rules.
Non-wild harvest aquatic plants excluded
The Crops Subcommittee also states that cultivated plants in aquatic systems (like watercress and sea weed) are in fact presently excluded by the current regulations. The Crops Subcommittee suggests that these types of farmed aquatic plants need a specific regulation written to accommodate them to the organic program.
Transition Period for Land under Outdoor Container facility
The Crops Subcommittee asserted that crops grown in non-fully enclosed greenhouses are subject to the three year transition period. Crops grown in enclosed structures with impermeable floors would be subject to requirements that would have to be determined.
Containers and Growing Media
The Crops Subcommittee refers to other proposals made by the anti-container section of the Task Force as well as regulations in other countries regarding the volume and composition of the substrate used when growing in containers. These ideas include the percentage of compost included in the substrate and the necessary size of the container. The Crops Subcommittee suggests that this could vary depending on the specific crop being grown.
The Crops Subcommittee recommends that restrictions be placed on the amount of nutrients that are delivered in a liquid format rather than a solid format. They did acknowledge that this requirement is not enforced for current soil systems. Nonetheless, the Crops Subcommittee wrote “In order for container production to be certified organic, there may have to be greater efforts made than for growing crops in soil.”
Crops Subcommittee States that Biology in Container Systems is Not Substantiated
The Crops Subcommittee stated that the diverse microbial populations found in container systems cannot be considered equivalent to the biology happening in soil environments. It appears that the Crops Subcommittee rejected the biology data provided on page 175 (page 60 of Section 2) of the Task Force Report stating that it did not provide “solid information … about the specific microbes and their roles.” It is unclear what additional information would satisfy the Crops Subcommittee or other members of the NOSB.
Crops Subcommittee to Delay Debate on Supplemental Lighting, CO2, Peat Moss
The Crops Subcommittee stated that they will delay debate on other issues dealing with greenhouse production systems (whether in containers or in the soil) until after it has addressed the other previously stated issues.
What the Crops Subcommittee Hopes to Achieve on this Subject at the November NOSB Meeting
Here is the direct statement from the Crops Committee on their expectations of what should be discussed at the Fall NOSB meeting:
1. For container production of crop plants which of the suggestions made in the discussion above should be recommended as standards? Why?
For example, container size, amount of compost or soil in growing media, stipulation about liquid vs. solid nutrition sources, and varying requirements for different crop types.
2. Do you have other suggestions about certified organic container production?
The Crops Subcommittee will work on converting the discussion document into a more concrete proposal based on the results of their vote regarding water based systems and the comments they receive during the Fall NOSB meeting cycle. The Crops Subcommittee would hope to have specific proposed regulations available for a vote at the Spring 2017 NOSB meeting.
In short, the Crops Subcommittee is recommending moving organics away from the current policy that allows growers flexibility to meet their site specific conditions as long as they follow the principles of cycling of natural nutrients using a biological process and using only approved inputs to a policy of “picking and choosing” methods approved on a case-by-case basis by the National Organic Standards Board. Given that soil-based tomato growers are the driving industry force pushing for a change to the regulations, we should assume that they will continue pushing to ban substrate systems as well in order to achieve the economic relief from competition that they are seeking.
NOSB MEMBERS AT SPRING 2016 MEETING
Coalition for Sustainable Organics to Meet October 5th Meeting in Oxnard, California
The Coalition is holding a meeting at the Embassy Suites Mandalay Beach Hotel in Oxnard, California beginning with lunch at 12 noon and ending around 5 PM. The meeting is open to all CSO members as well as other interested growers and industry providers that will be impacted by the efforts to restrict container production methods. We plan to work with you at the meeting to understand the impact of the proposals and to further refine our comments and efforts. Please RSVP toinfo@coalitionforsustainableor
The preliminary agenda includes:
· Review the history of the issue with USDA
· Review the actions of the Coalition to date
· Analyze how the recommendations to modify the current USDA organic regulations will impact growers current and planned organic production systems
· Determine any changes in our messaging for the National Organic Standards Board, the organic industry, members of Congress and the retail and food service trade
· Coordinate our efforts for the fall NOSB meeting
· Discuss ways to become more involved with the issue and with the Coalition for Sustainable Organics
Opportunity to Submit Comments for Review by the NOSB and USDA
While the USDA National Organic Program will not release any proposals until late September, the USDA has opened the official comment period for the November NOSB meeting. Once there is there is a proposal, the CSO will work with producers to develop a detailed formal response.
USDA has posted comments submitted through September 25. With respect to the matter of organic certification for container production methods, there are roughly 85 comments in favor of continued certification and 35 comments against certification.
Comments like these remind the USDA and the NOSB that container production systems are sustainable, legitimate and sensible, and it is important to preserve our systems as part of the organic family. Your voice does have the power to make a major impact with the people deciding the fate of the industry right now.
Again, if you have commented already, thank you. If you have not or you have not reached out to your employees to submit comments, please do so before the National Organic Standards Board sets a plan in motion to revoke organic certification of systems you use currently or would like to use in the future.
You can submit comments by clicking on the following link and then following the instructions.
Please find a draft of comments that will help us communicate our core message to meet the immediate needs of the organic movement. We will work with you to develop a more specific response to the proposal set forth by the Crops Subcommittee.
Dear National Organic Standards Board (NOSB),
This letter is in support for continued organic certification of container and greenhouse growing methods. We face evolving challenges in farming food with respect to limited resources such as water, land, labor and natural resources that are more severe than ever before. Container growing methods help us meet those challenges of sustainability while fulfilling the legitimate and original intent of the organic movement to use biology to cycle natural inputs while avoiding prohibited substances.
It would be a significant setback to the industry to change the current sensible USDA policy by prohibiting container growing, as this is currently a prevalent and effective practice across the country.
Thank you for your consideration on this urgent matter.
Your name here
In addition, please consider registering online to provide oral public comments at the Fall NOSB meeting. This will be your opportunity to directly address members of the NOSB. Oral public comments are scheduled in two (2) blocks:
Thursday, November 3, 2016, 1:00 – 4:00 p.m. ET, via webinar; (3 minute comment slot)
Wednesday/Thursday, November 16-17, 2016, at the face-to-face meeting in Saint Louis, Missouri; (3 minute comment slot)
Membership in the Coalition for Sustainable Organics
Please consider joining the Coalition for Sustainable Organics. Your membership makes our voice much more powerful in influencing the struggle to keep container methods in the USDA organic program. http://coalitionforsu