13
Jul
Take Action: Demand to Keep the Soil in Organic, Reject the Labeling of Hydroponic Crops as Organic!
(Beyond Pesticides, July 13, 2020) Soil is central to organic production. Therefore, hydroponic operations should not be considered eligible for organic certification, and the National Organic Program (NOP) must take a clear position in opposition to hydroponics and other non-soil-based methods in organic production, including containers. Organic farmers and consumers strongly agree that organic production must be soil-based.Â
Tell NOP hydroponics is not organic! Educate your congressional representatives and senators.
NOP authorizes the certification of hydroponic operations as organic. This undermines the authenticity of organic farming and creates unequal competition, market instability, and consumer distrust in organic certification.
Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on environmentally beneficial methods such as green manure, crop rotation, and biological pest management.
On March 3, 2020, the Center for Food Safety (CFS) filed a lawsuit challenging the USDA’s decision to allow hydroponics operations to be certified organic. Organic farmers and consumers believe that the organic label means two things: grown in the soil and farmed in a manner that builds soil biology and the natural cycling of nutrients. Hydroponics meet neither of these requirements and involves methods of growing crops that is dependent on soluble synthetic nutrients.
Soil Ecology Supports Healthy Crops
Historically, perhaps the most important principle of organic production is the “Law of Return,†which, together with the rule “Feed the soil, not the plant†and the promotion of biodiversity, provide the ecological basis for organic production and land management. Together these three principles describe a production system that works with natural systems.
The Law of Return says that we must return to the soil what we take from the soil. Non-crop organic matter (residue) is returned directly or through composting plant materials or manures. To the extent that the cash crop removes nutrients, they must be replaced by cover crops, crop rotation, or additions of off-site materials, when necessary.Â
Although some hydroponic producers may compost residues, they do not return the residues to the hydroponic system and close the loop. Inputs of organic matter reported by hydroponic practitioners are produced off-site, with no return to their production system. While most organic growers depend on some off-site inputs, most of the fertility in a soil-based system comes from practices that recycle organic matter produced on-site.
The cycling of organic matter and on-site production of nutrients—as from nitrogen-fixing bacteria and microorganisms that make nutrients in native mineral soil fractions available to plants—is essential to organic production. The Law of Return is not about feeding plants, but about conserving the biodiversity of the soil-plant-animal ecological community.
“Feed the soil, not the plant†reminds us that the soil is a living superorganism that supports plant life as part of an ecological community. We do not feed soil organisms in isolation, to have them process nutrients for crop plants; we feed the soil to support a healthy soil ecology, which is the basis of terrestrial life. Feeding the soil is intended to support the soil ecosystem is intrinsically counter to a hydroponic system. Hydroponics, in bypassing the soil ecology, rely on added plant nutrients that feed the plants.
Additionally, creating a structure to house hydroponic goes against the legal requirement in federal organic law: “The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.â€Â
Biodiversity Conservation
Finally, biological diversity is important to the health of natural ecosystems and agroecosystems. The definition of “organic production†in the federal organic regulations requires the conservation of biodiversity. As stated in the NOP Guidance on Natural Resources and Biodiversity Conservation (NOP 5020),
The preamble to the final rule establishing the NOP explains: “The use of ‘conserve’ [in the definition of organic production] establishes that the producer must initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would diminish it. Compliance with the requirement to conserve biodiversity requires that a producer incorporate practices in his or her organic system plan that are beneficial to biodiversity on his or her operation.†(76 FR 80563)Â
Biodiversity promotes ecological balance, which protects farms from outbreaks of damaging insects and disease. It supports the health of the soil through the progression of the seasons and stresses associated with weather and farming. It supports our health by offering a diversity of foods. On a soil-based organic farm, many practices support biodiversity—from crop rotations to interplanting to devoting space to hedgerows and other non-productive uses. Many of these practices can and should be used by farmers producing food in greenhouses. However, hydroponics is considered a monocultural environment that does not support biodiversity. Thus, it is not enough for a hydroponics producer to say it is not diminishing soil and plant biodiversity—the operation must take active steps to support biodiversity.
Organic production allows exceptions to soil-grown produce like mushrooms, which grow on ecologically appropriate substrate such as manure or wood and sprouts. Sprouts are not required to be grown in soil because sprout production is a way of processing seeds. However, these exceptions imply that organic production is soil-based.
The ecological system of a hydroponic nutrient system is more like a fermentation chamber—a means of processing plant nutrients—than the soil ecosystem of an organic farm.
Integral to the Organic Foods Production Act (OFPA) is the understanding that soil is alive, not merely a medium for supporting plants, as is the case, to a large extent, in  “conventional†chemical-intensive agriculture. “Conventional†farmers pour poisonous synthetic fertilizers into soil without the protecting the ecological community. Interestingly, in defining organic in OFPA, organic producers compared conventional agriculture to hydroponics because it bypasses the soil.Â
Practitioners of hydroponics have learned the value of biology in their nutrient solutions. However, the biology of fermentation tanks is not “soil ecology,†although it is merely an artificial mimic of soil ecology and a reductionist approach to manipulating nature.
Threatening the Value of the Organic Label
Organic farmers and consumers view the current interpretation of organic as a threat to the integrity of the organic seal, impacting every organic farmer and consumer in every state. The consideration of hydroponic production in organic is an issue that impacts every aspect of the organic industry. Members of the organic industry consistently rank this issue, maintaining consumer’s confidence in the organic seal, as a top priority and mandatory to their success.
However, it is critical that we address any compliance limitations of organic certification systems when it occurs and ensure corrective action in a timely fashion with full transparency. Without this kind of response, public trust in the organic food label will suffer dramatically. Additionally, to the extent that the enforcement system is known to be highly rigorous, it will decrease the likelihood of aberrant behavior.
One factor leading consumers to purchase organic produce is its perceived greater nutrient value. Research supports that perception—showing that nitrate concentrations in leafy vegetables are significantly different for hydroponic, conventional, and in-ground organic systems, with desired nutrients generally more concentrated in organic vegetables.
Prior to the coronavirus outbreak, the organic industry was meeting with congressional staff to explain its position. We need your help to continue that effort as your outreach to NOP and your elected official is critical to our success.
Because of the high turnover of congressional staff, groups opposing this policy need to continuously educate our elected officials on this issue.
We urge you to take action by sending a letter to NOP and your congressional representative.Â
Tell NOP hydroponics is not organic! Educate your congressional representatives and senators.
Thank you!
The Beyond Pesticides Tea
Letter to Congress
I am writing to request congressional oversight of the National Organic Program (NOP) on a matter that goes to the core of organic production—soil. In allowing USDA organic labeling of hydroponically grown food, NOP is violating the law.
Soil is central to organic production. Therefore, NOP must take a clear position in opposition to hydroponics and other non-soil-based methods in organic production, including containers. Organic farmers and consumers believe that the organic label means two things: grown in the soil and farmed in a manner that builds soil biology and the natural cycling of nutrients. Organic farmers and consumers strongly agree that the organic label requires two things: grown in the soil and farmed in a manner that builds soil biology and the natural cycling of nutrients. A failure by NOP to enforce these requirements in federal law will ultimately have dire adverse economic consequences for the organic market.
NOP authorizes the certification of hydroponic operations as organic. This undermines the authenticity of organic farming and creates unequal competition, market instability and consumer distrust in organic certification. On March 3, 2020, the Center for Food Safety (CFS) filed a lawsuit challenging the USDA’s decision to allow hydroponics operations to be certified organic.
Organic farming and soil are inextricably linked. The microorganisms in healthy soils interact in a symbiotic manner with plant roots, strengthening the plant, enabling it to resist diseases and facilitating the water and mineral uptake. The essence of organic production is maintaining and enhancing the organic matter content of soil by relying on methods such as green manure, crop rotation, and biological pest control.
Historically, perhaps the most important principle of organic production is the “Law of Return,†which, together with the rule “Feed the soil, not the plant†and the promotion of biodiversity, provide the ecological basis for organic production. Together these three principles describe a production system that works with natural systems.
The Law of Return says that we must return to the soil what we take from the soil. Non-crop organic matter (residue) is returned directly or through composting plant materials or manures. To the extent that the cash crop depletes soil, organic production systems replace them with cover crops, crop rotation, or additions of off-site materials, when necessary. Hydroponic producers do not return the residues to the hydroponic system, closing the loop.
“Feed the soil, not the plant†reminds us that the soil is a living superorganism that supports plant life as part of an ecological community. We do not feed soil organisms in isolation, to have them process nutrients for crop plants; we feed the soil to support a healthy soil ecology, which is the basis of terrestrial life. Feeding the soil has a positive impact on the ecosystem, which cannot be done with hydroponics. Hydroponics rely on added nutrients, added to feed the plants, not the ecosystem.
Finally, biological diversity is important to the health of natural ecosystems and agroecosystems, protecting farms from outbreaks of damaging insects and disease. The definition of “organic production†in the organic regulations requires the conservation of biodiversity—the producer must “initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would diminish it.â€
Organic farmers and consumers view allowing hydroponics in organic as a threat to the integrity of the organic seal, impacting every organic farmer and consumer in every state.
Thank you for pushing for congressional oversight to protect public trust in the organic label and ensure the growth of the organic market.
Letter to USDA
It is absolutely essential to any government or private standard setting process that enforcement and compliance operate effectively and is trusted by the public. Without an effective enforcement system, the value of the USDA organic label is undermined in the market. Whether related to imported or domestically grown food, enforcement against fraud and an assurance of compliance with organic standards is critical to the ongoing growth and stability of the organic market. Fraud is a problem when, for example, crops are grown with prohibited inputs, when livestock do not get the required access to pasture, and when crops are produced in artificial media and, therefore, not in compliance with organic standards.
Consumer trust and organic farmer and handler investments are jeopardized by ineffective oversight and enforcement of organic standards by USDA. USDA and accredited organic certifying agents are generally meeting expectations, but the enforcement process has fallen short in several instances, particularly in allowing hydroponic production, and additional actions are needed to safeguard the integrity of the organic label.
Contrary to a 2010 recommendation by the National Organic Standards Board (NOSB), the National Organic Program (NOP) has been allowing hydroponics operations to be certified as organic. This reversal of an NOSB decision without any new scientific information undermines the NOSB process and will have a devastating long-term impact on the credibility of the organic label. In response, organic stakeholders, including growers, consumers, processors, and retailers, have come together around an add-on label that will inform consumers that their organic food has been grown in the soil and managed in accordance with the intent and spirit of Organic Foods Production Act, which requires that organic growers “foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.†This add-on label will provide transparency so that consumers can be assured that farmers are engaged in the practices of soil-based agriculture, which are foundational to the principles and values integral to the law.
From its very beginnings, the organic sector has been driven by an alliance of farmers and consumers who defined the organic standards as a holistic approach to protecting health and the environment, with a deep conviction that food production could operate in sync with nature and be mindful of its interrelationship with the natural world—protecting and enhancing the quality of air, water, land, and food. These standards, integral to organic, certainly do not preclude the adoption of other methods that can identify themselves as offering other assets, but adherence to the principles of organic cannot be compromised if we are to sustain the organic market in the future. So, from this perspective, we have a serious fraud and enforcement problem with the current allowance of certified organic hydroponic production.
Please tell certifiers that hydroponic production cannot be certified organic.
Thank you for your attention to this serious matter of public trust in the organic label.
Organic production needs to be soil based.
July 13th, 2020 at 11:35 pm