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• USDA Must Foster Soil Fertility for ALL Organic Labeled Products

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The failure of the National Organic Program (NOP) to consistently require soil-building practices for certification of organic farms presents a serious threat to organic integrity. As a result of this failure, some growers using hydroponic and other practices that do not build the soil are allowed to sell produce as organic. Such produce is not labeled as “hydroponic” or “container-grown.”    

>> Tell USDA to protect organic integrity and follow organic law by fostering soil fertility for ALL organic labeled products.

The Earth needs many more real organic farms that support soil health, help sequester carbon dioxide, and avoid the use of materials like soluble nitrogen fertilizers that contribute many times as much warming potential as carbon dioxide. By a decisive vote in 2010, the U.S. Department of Agriculture's (USDA) National Organic Standards Board determined that hydroponic and aquaponic operations are inconsistent with OFPA and do not qualify for organic certification. 

USDA has an open comment period—closing Monday, January 22—regarding the information that is collected during the organic certification process. To comply with the Organic Foods Production Act (OFPA), the National Organic Program (NOP) must collect information from all certified organic crop producers and all accredited certifying agents on how certified organic crop production operations “foster soil fertility” to verify compliance with OFPA 6513(b). 

At the present time, the NOP accredits certifying agents that certify soil-based crop producers who comply with the soil fertility requirements of OFPA and regulations. Simultaneously, the NOP accredits certifying agents that certify hydroponic, container, and other soilless crop production systems that do not comply with the soil fertility requirements of OFPA and NOP regulations. 

Soil-based organic production systems sequester carbon, fix nitrogen, build soil health, increase the water-holding capacity of soils, prevent soil erosion, foster the cycling of resources, promote ecological balance, conserve biodiversity, and provide numerous ecological services. Hydroponic, aquaponic, and other soilless container growing systems do not sequester carbon, fix nitrogen, increase the water-holding capacity of soils, recycle nutrients, prevent erosion, enhance biological diversity, or protect ecological balance, yet the USDA currently allows such operations to be certified “organic.”  

There are significant differences between soil-based and soilless crop production systems, but there is no data available to determine how much of the U.S. organic market is comprised of the products from these two different production systems, since the products of both systems are labeled “organic” and allowed to carry the “USDA Organic” logo. Likewise, USDA has no data to research and compare the environmental and health impacts of these systems, since the products of both systems are labeled the same. 

This comment period provides an opportunity to tell USDA that its failure to require data that can support an organic farm's compliance with the soil-building requirements of OFPA undermines organic consumers' trust in the integrity of the organic market. 

>>Tell USDA to protect organic integrity and follow organic law by fostering soil fertility for ALL organic labeled products.

The target for this Action is the U.S. Department of Agriculture via Regulations.gov.  

Thank you for your active participation and engagement!

Comment to EPA:

The Earth needs many more real organic farms to support soil health, help sequester carbon dioxide, and avoid the use of materials that contribute many times as much warming potential as carbon dioxide. USDA’s failure to require information to ensure consistent application of the Organic Foods Production Act (OFPA) threatens the integrity of organic products upon which I depend.

At 6513(b)(1), OFPA states, “An organic plan shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” OFPA 6513(g) states, “An organic plan shall not include any production or handling practices that are inconsistent with this chapter.”

NOP now accredits certifying agents that certify soil-based crop producers who comply with the soil fertility requirements of OFPA 6513(b)(1) and 7 CFR sections 205.2, Natural Resource Protection; 205.203 Soil Fertility and Nutrient Management; and 205.205 Crop Rotation. NOP also accredits certifying agents that certify hydroponic, container, and other soilless crop producers who do not comply with those same requirements.

Soil-based organic production systems sequester carbon, fix nitrogen, build soil health, increase the water-holding capacity of soils, prevent soil erosion, foster the cycling of resources, promote ecological balance, conserve biodiversity, and provide numerous ecological services, while hydroponic, aquaponic, and other soilless container growing systems do not, yet USDA allows such operations to be certified “organic.”

Despite significant differences between soil-based and soilless crop production systems, USDA has no data to determine or research how much of the U.S. organic market is comprised of the products from these two different production systems, since the products of both systems are labeled “organic” and allowed to carry the “USDA Organic” logo and compare the environmental and health impacts of these systems.

NOP must collect data on the type of production system used by certified organic crop producers to determine the number of soil-based vs soilless crop production operations and products, both foreign and domestic, that are being certified as “organic” under NOP. Accredited certifying agents must ask specific questions to assess all crop operations’ compliance with OFPA 6513(b)(1), since the law states that organic crop plans “shall contain provisions designed to foster soil fertility.”

In order to “assure consumers that organically produced products meet a consistent standard,” NOP must require that accredited certifying agents who certify hydroponic, aquaponic, and other soilless container systems provide data to NOP—and make it publicly available—on the number of such operations that they certify; the amount of acreage or square footage in soilless production; the types and quantities of crops produced using soilless production methods; the expected vs actual yields from soilless operations; the value of the crops produced using soilless production methods; the labels and brand names used on all such products; the countries of origin; and the markets where these products are sold.

The U.S. is the only country where soilless crop production systems are being certified as “organic,” so collection of the information cited above is needed to verify compliance with trade agreements in international organic markets.

USDA has issued no rules governing the soilless production of “organic” crops, so it is incumbent on USDA to collect accurate and detailed information on both soil-based and soilless crop production systems that are being certified as “organic,” in order to comply with OFPA Sections 6501(2), 6513(b), and 6513(g), and 7 CFR Part 205.2, 205.203, and 205.205.

Thank you.