By Lee Frankel and the Coalition for Sustainable Organics
“Conflicted” is the most common sentiment of National Organic Standards Board members moving forward on the issue of the role of containers in the USDA organic program
The members of the Crops Subcommittee of the NOSB who wrote the Discussion Document calling for the elimination of hydroponic, aquaponic and aeroponic production methods from the USDA organic program presented the basis for their document and then invited feedback from each of the board members individually at the recently concluded Spring 2017 NOSB meeting in Denver. The most common theme emerging from the thoughts shared by the board members was the sense that they were “conflicted.” Most board members expressed that they thought organics is primarily about the soil, but that container systems seemed to have an important place as well in organics.
On one extreme, there are still board members that would like the ultimate decision to result in as large a restriction of supplies as possible to help raise prices for small organic farms that harvest their crops from the soil. At the other extreme, one member urged the board to make sure that the entire spectrum of container definitions and issues were fully studied and discussed before votes to restrict production systems such as aeroponics and aquaponics to move forward. Most members expressed a desire to find some type of “compromise” that would restrict some current production of organics, but to include enough container production systems to avoid the rise of a strong competitive label (similar to non-GMO certified) for growers using container production systems.
Agreements by NOSB Regarding Process to Make Decisions on Containers
The board members also expressed a sense of conflict in pushing forward in an expedited manner to give more certainty to growers and the organic trade in resolving the issue of what systems should or should not be allowed under the USDA organic label. At the same time, they also expressed concern about making sure that they had enough information to make an informed decision and that the organic community would have a chance to fully vet and respond to any proposal so that any decision by the NOSB would have credibility in the eyes of the industry, USDA and elected officials.
One board member specifically expressed concern that the animal welfare rule is suffering delays and is under attack by some organic producers because not all aspects of the rule were well justified and explained during the policy development process. Some would like to minimize the risk to the credibility of any future proposed rule by making sure that the NOSB allows time for real public input and participation, even if it means delaying a vote until the Spring of 2018.
As part of the effort to create more consensus with the entire board, the Crops Subcommittee invited and expects all members of the board to participate on the conference calls of the Subcommittee when the issue of containers is discussed. If the NOSB completes their analysis quickly, we may see a formal proposal by the Fall 2017 NOSB meeting. If the members of the NOSB do not feel ready to have a more complete proposal ready by then, they may present yet another discussion document in the Fall with the expectation of having a formal recommendation ready for the Spring 2018 meeting.
Most Frequent Requests for More Information
The members of the board identified several items either during their formal discussion or through questions asked to the public presenting testimony. Those items included more detailed information about
- the quantity and diversity of biology in various productions systems,
- the composition of substrates used in container systems,
- the types of fertility sources used, and
- the market volume and/or market share for product grown in containers.
The members also expressed an interest in visiting more operations to better understand the diversity of the production systems as well as the commonality between different operations. They requested to the USDA to investigate if a budget could be obtained for all the members of the NOSB to visit farms together and what public meeting requirement may exist that could restrict NOSB members’ ability to gather outside of a formal meeting.
Please let us know if you are willing to host a visit from either NOSB members in your area or for a visit by the full board.
Summary of Written Comments and Public Testimony
Members of the public including farmers, consumers and trade associations submitted over 1,000 written comments regarding the proposed restrictions on container production systems. Nearly all were letters speaking in general terms. Many wrote in support of the sustainability, efficient resource use, legitimacy and sensibility of continued certification for growers incorporating containers in their production. The other side focused on the necessity of active soil management as a requirement for organic systems. Just a few submissions went into more detail responding to the questions posed by the Crops Subcommittee regarding container production and the use of nutrition delivered in liquid form to the biology surrounding the roots of the plant.
Supporters of container production systems outnumbered during the verbal testimony section of the meeting by over a 2 to 1 margin of those stating the organics should only be produced in soil with limited exceptions. The NOSB members seemed much more engaged with their questions to speakers compared to the 2016 NOSB meetings.
Leading points made by the pro-container side included the following:
- Containers allow for more efficient use of land, water and fertility inputs relative to soil systems;
- Growers should not be asked to incorporate wasteful production practices or inputs in order to meet an arbitrary requirement for certification;
- Virtually all nutrients are taken up by a plant in a liquid form by the root;
- While everyone would like strong and clear regulations, we should make sure there is flexibility for future improvements in production practices since we are in the early stages of understanding optimal biological balances and plant needs in container systems;
- The definitions proposed in the discussion document are unclear to allow for a clear classification of production methods; therefore, the NOSB should consider first defining required root zone dynamics first; and
- Organic consumers overwhelming look to a clean product that is healthy for them as a top priority over issues such as the growing media of the plant.
Leading points made by the anti-container side included the following:
- Organics is primarily about improving the health of the soil;
- Attempts to define organics based upon biology or inputs are wrong;
- Eliminating competition coming from organics grown in containers will help allow small farms to benefit from higher suppliers based on restricted supplies; and
- Exceptions should be made for plantlets and nursery stock that benefit soil farmers.
Join the Coalition for Sustainable Organics
Please consider joining the Coalition for Sustainable Organics. While we have made significant progress in strengthening the legitimacy of container production systems with members of the National Organic Standards Board and with the active members of the organic establishment, much more work needs to be done to secure your right to continue to select the most appropriate site specific solutions and production methods for your operations. The Coalition will continue to educate the NOSB, USDA and elected officials, but we need your help. Your membership makes our voice much more powerful in influencing the struggle to keep container methods in the USDA organic program.