30
Sep
Recent Census Shows 24 Percent Jump in Organic Sales; Integrity Issues before Organic Board
(Beyond Pesticides, September 30, 2024) Public Comment Period on Issues of Organic Integrity Closes Today. Farming is a notoriously risky enterprise, and organic farming presents further challenges along with its multiple benefits. Generally, organic has made great strides over the last several years and is strongly supported by American consumers, findings in the latest U.S. Department of Agriculture (USDA) Census. Even late this year, there is the prospect of several more important changes that will improve the organic certification process and some issues that will take more policy changes to resolve in the future. As a part of this process to ensure the integrity of the USDA organic label and the permitted production practices, Beyond Pesticides urges that the public submit comments TODAY (the last day for the comment period) on issues currently before the National Organic Standards Board (NOSB). See two sets of comments on key issues that can be submitted with one click each. Click here on issues related to use of plastic, nonorganic ingredients in processed food, and seeds and plant starts. Click here on inert ingredients, contaminants in compost, and drugs in livestock production.
U.S. agriculture overall has remained fairly robust between the USDA Census in 2017 and the most recent one in 2022. USDA released its report comparing the two years last February.
The number of organic farmers between 35 and 44 years old grew by 15 percent, and the percentage of female principals rose by 3 percent. And, total organic product sales jumped by 24 percent, despite the intervention of the Covid pandemic. However, organic has experienced slower growth than the full sector. The number of certified organic farms dropped by four percent over the five-year interval; worse, the number of transitioning farms fell by more than half. This is not just an agricultural issue, this is a societal issue, given the need to adopt land management practices that eliminate petrochemical pesticides and fertilizers and adopt practices that reverse the existential health, biodiversity, and climate crises. “These statistics show that organic land management is still not recognized by the government as performing a social good that requires significant public investment if we are to replace unsustainable practices that are having dramatic adverse effects on people’s health, the health of the ecosystem, and weather, resulting in life-threatening events,†said Jay Feldman, executive director of Beyond Pesticides.
The success of organic agriculture has produced some pressures on organic certification that may not have been anticipated. As consumer demand grows, uncertified producers have an incentive to sneak under the organic umbrella. Many cases of fraud, both inside the United States and in imports, have revealed holes in the certification chain; and for years many organic advocates have been concerned about non-organic ingredients and techniques being allowed under the certification stamp, violating organic principles without proper vetting.
The organic context
Valid and encouraged constructive criticism of organic must be put in the context of a chemical-intensive food system that contributes to adverse impacts on people, workers, and the environment. The organic discussion begins with what is known about contaminants generally in the food supply, both domestically grown and imported. Central to this discussion is the adequacy of regulations governing pesticides and the laws and regulations under the Federal Insecticide, Fungicide, and Rodenticide Act—the degree to which there is adequate protection from levels of pesticide residues in food, air, water, and land, as well as the occupational exposure to farmworkers and farmers. There are numerous General Accountability Office reports that capture the issues, as well as numerous Office of General Counsel reports, academic studies, and scientific articles. (See Beyond Pesticides’ Resources)
The discussion also starts with what is mandated under the Organic Foods Production Act, where virtually all synthetic pesticides are prohibited as are all synthetic fertilizers. From this perspective alone, a look at pesticide use that intersects with current public health issues (major diseases associated with pesticides in the scientific literature), biodiversity decline, and climate, it is undisputed that organic is an improvement in the protections it offers. All the pesticides that have gotten headlines in the media (neonicotinoids, glyphosate, dicamba, 2,4-D, and genetically engineered crops, which have increased reliance on herbicides) are prohibited in organic by statute. Biosolids are prohibited, which is where much PFAS is making its way onto farms as fertilizer.
With respect to the inspection and certification system that exists with organic labeling—there is nothing like this type of system in conventional (chemical-intensive) agriculture—a system that establishes compliance with the law and the requirement for an organic systems plan. Whether domestic or international, the certification system must meet U.S. standards if it is going to be sold in the U.S. as organic That means that the same system of oversight is required by the certifiers. Will there be those who break the law? Of course. So, while increased funding has gone into the National Organic Program (NOP) at USDA, more funding for oversight and stronger standards will be helpful.
Organic is a practice-based standard that requires practices and limits the allowance of synthetic inputs to the National List of Allowed and Prohibited Substances. It is reviewed on a five-year sunset cycle, with clear prohibitions. When there is drift or runoff from off-site, the law provides for a small fraction of what is allowed in conventional agriculture on food, but in most cases, organic farms are required to set up buffers to prevent drift from neighboring fields/sites. Organic advocates point to the need for continuous improvement and use the transparent public engagement process through the NOSB to advance organic integrity.
Ongoing Challenges with USDA on organic
First, the USDA set a March 19, 2024 enforcement deadline for its Strengthening Organic Enforcement (SOE) policy. The SOE aims to correct some of the porous boundaries in organic oversight. One of its principal steps is to require the middle parts of supply chains to certify that the products they are handling are truly organic. This includes traders, brokers, buyers and sellers, according to Food Business News—not just the producers, packagers, labelers, and processors currently covered. Organic companies typically hire a third-party consultant to shepherd them through certification. The new requirements produce a swarm of new entities needing certification, creating a backlog. And according to one certifier, if some middle-of-the-supply chain companies remain noncompliant, they will put everyone else at risk of unacceptable delays as the enforcement requirement rolls through the system. On September 19, a bipartisan group of U.S. representatives asked NOP to extend the deadline for compliance with the SOE because third-party certifiers cannot keep up.
Another part of the SOE aims to prevent imports of products falsely claiming to be organic by imposing a requirement that all organic goods are certified at the borders. A shocking case came to light in 2023 when an Oregon hazelnut grower, Bruce Kaser of Pratum Farm, discovered that low-cost hazelnuts from Turkey and elsewhere, claiming to be organic, were skating through regulations required of U.S. growers. He had noticed that the prices of the imported nuts were far closer to the prices of conventional nuts than market rates for organic nuts. Mr. Kaser first filed a complaint with USDA against certain foreign certifiers (Bio Inspecta AG, Ecocert SAS, Bioagricert, Letis, and CCPB SRL) and then filed a lawsuit. The complaint charges that the imports were ushered in under the USDA’s “group certification†provision, which is designed to help small landholders in cooperatives and indigenous communities reach wider markets. The groups are supposed to be small entities geographically near each other. The plaintiff submitted an exhibit alleging that the Turkish growers listed in certificates were actually a nut shelling company and that there was no evidence the farms that were the source of the hazelnuts were inspected according to USDA rules. Nor were they located in the same region. The suit is being opposed by a group of U.S. companies who filed an amicus brief, alarmed that a win for the plaintiff would endanger legitimate certified groups. The case is pending. (For more, see Organic Insider and the criticism that SOE does not address the grower group problem.)
A second crucial event this year, the USDA’s NOSB meeting in Portland, Oregon will occur on October 22-24. Again, public comments are due by September 30, 2024, at 11:59 pm EDT.
The Board will consider a number of important issues, analyzed here by Beyond Pesticides. For example:
- Inert ingredients – Beyond Pesticides’ position is that so-called “inert†ingredients must be evaluated according to their risks to human health and the environment, their necessity in organic production, and their consistency with other organic practices.
- Compost – Beyond Pesticides objects to the proposal that feedstocks for organic compost could include synthetics like “compostable†tableware.
- Meloxicam – an NOSB subcommittee proposes to allow the non-steroidal anti-inflammatory drug to be used in livestock, which Beyond Pesticides opposes in the absence of an independent review of the drug’s health and environmental effects.
- Nonorganic ingredients – an NOSB subcommittee proposes to remove a nonorganic ingredient (dried orange pulp), which is available in organic form, a proposal Beyond Pesticides supports.Â
- Organic seeds and starts – Given the limited availability of organic seeds and starts, Beyond Pesticides urges that the development of this becomes a priority,Â
- Use of plastics in organic – Beyond Pesticides urges that efforts to remove the use of plastics in organic production and packaging become a research priority for USDA.
To round out the fall roster of important organic developments, organic practitioners are on tenterhooks awaiting resolution of the Farm Bill. Barred from passage by recalcitrant and bitter Congressional infighting, it has limped through a year-long extension whose September 30 expiration is expected to be pushed to December 20—after the election. See Beyond Pesticides’ May 24 Daily News Blog for a breakdown of the bill’s organic provisions. For a list of other pending bills, parts of which have been incorporated into the Farm Bill, see the Organic Farmers Association. These bills’ provisions include requiring the USDA to create a safety net for organic dairy farmers, improve data collection in the organic dairy sector, crack down on corporate consolidation, and even phase out concentrated animal feeding operations (CAFOs).
There remain fundamental problems with federal regulation of food quality and agricultural resiliency standards. The USDA is the frontline actor that urgently needs to protect organic at every level from attempts to blur or widen definitions and dilute the precision of regulations.
One insidious example is corporations’ efforts to sneak technologies under the organic umbrella that violate the spirit of organic. For example, Hans Eisenbeis of the Non-GMO Project told Organic Insider in January 2023 that “Biotech companies that use [genetic engineering] techniques like precision fermentation and synthetic biology are coming for organic and regenerative systems and markets.â€
This trend is part of a larger problem, which is that the relationship between “regenerative†and “organic†must be clarified. See Beyond Pesticides’ August 19 Daily News Blog for an analysis of how the term “regenerative†lacks a precise definition, especially in regulatory terms. In our May 24 blog, we stress that the term “regenerative†does not have a meaningful use but is “being advanced as a loosely defined alternative to the organic standard and label, which is transparent, defined, certified, enforced, and subject to public input.†The term has been adopted in greenwashing campaigns by such agribusiness behemoths as General Mills, Cargill, Unilever, and Walmart.
The California Board of Food and Agriculture is attempting to define the term, but there is no indication of when it may succeed. Beyond Pesticides takes the position that any definition of “regenerative†must start with and incorporate organic standards, and build on the requirements established for organic, ranging from a certification and enforcement system to baseline practices and collection of real-time data affecting approval of allowed substances. In other words, there is no regeneration without organic.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Sources:
United States Summary and State Data Volume 1 Geographic Area Series
Part 51 AC-22-A-51
Issued February 2024
https://www.nass.usda.gov/Publications/AgCensus/2022/Full_Report/Volume_1,_Chapter_1_US/usv1.pdf
Fall 2024 NOSB Meeting
Beyond Pesticides
https://www.beyondpesticides.org/programs/organic-agriculture/keeping-organic-strong/fall-2024-nosb-meeting
The World of Organic Agriculture Statistics and Emerging Trends 2024
Research Institute of Organic Agriculture
https://orgprints.org/52272/1/1747-organic-world-2024_light.pdf#page=232
To Make Regenerative Meaningful, It Must Require Organic Certification as a Starting Point, according to Advocates
Beyond Pesticides
May 28, 2024
To Make Regenerative Meaningful, It Must Require Organic Certification as a Starting Point, according to Advocates
Certified Organic Principles and Practices Embraced by Farmers and Consumers; Fed Standards Eroding
Beyond Pesticides
August 19, 2024
https://beyondpesticides.org/dailynewsblog/2024/08/certified-organic-principles-and-practices-embraced-by-farmers-and-consumers-fed-standards-eroding/
What Is Regenerative Agriculture? A Review of Scholar and Practitioner Definitions Based on Processes and Outcomes
Newton et al.
Frontiers in Sustainable Food Systems 2020
https://www.frontiersin.org/journals/sustainable-food-systems/articles/10.3389/fsufs.2020.577723/full
