25
Sep
Comment by October 11 to Protect Organic Integrity: Keep the Soil in Organic
(Beyond Pesticides, September 25, 2017) As the comment period officially begins for the Fall 2017 National Organic Standards Board (NOSB) meeting, a major 
controversy is coming to a head on allowing hydroponics to be certified organic. Contrary to prior recommendations of the NOSB, the National Organic Program has allowed some hydroponics operations to be certified. The NOSB will consider motions at this meeting that could stop this practice.
Make your voice heard on this and other issues by submitting comments NOW on what materials and practices are allowed in organic production! An easy way to speak out is to go to our website, find our positions, write your comments (using our summary –feel free to cut-and-paste our comments), and submit your comments on the government website. [Unfortunately, for those who are not familiar with commenting on these critical organic integrity issues, this action requires that you post your comments on the government’s ‘regulations.gov’ website. We have simplified this process through our Keeping Organic Strong webpage.]
Beyond Pesticides provides you with our positions, which you can use as the basis for your comments. Please feel free to develop your own comments or cut and paste ours. If you cut and paste our comments into regulations.gov, please first put a personal note of concern in order to reflect the importance of these issues to you as an organic consumer, farmer, or other concerned party.
Some major issues being considered at the Fall meeting are:
Hydroponics
Organic production is soil-based and is defined by principles concerning the grower’s relationship to the soil. The “Law of Return,” the rule “Feed the soil, not the plant,” and the promotion of biodiversity, provide the ecological basis for organic production. The Law of Return says that we must return to the soil what we take from the soil. The dictum to “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. Finally, biological diversity is important to the health of natural ecosystems and agroecosystems. Biodiversity promotes 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. Hydroponics is not consistent with these principles.
The of the 2010 Subcommittee of the Hydroponics Task Force convened by USDA reminds us of these foundations, but also contrasts organic production and “conventional” chemical-intensive agriculture. At the time of the passage of the Organic Foods Production Act (OFPA), the organic community’s characterization of soil as alive was viewed with amusement by the “conventional” agriculture experts, who saw soil as a structure for supporting plants, while farmers poured on synthetic nutrients –and the poisons that had become necessary to protect the plants growing without the protection of their ecological community. Interestingly, organic producers at that time compared conventional agriculture to hydroponics.
The term “container” is very broad, encompassing pots in various sizes and shapes, as well as beds that are not in direct continuous contact with the earth –such as rooftop gardens, or gardens in areas where an impervious layer protects plants from contaminated earth beneath. We support eligibility for organic certification of containers where the soil is managed organically. As discussed above, managing the soil organically involves many things –most could not be done in pots or most other containers, but would be possible in large beds. In particular, the organic regulations must be followed to the letter.
Containerized culture may be eligible for organic certification under limited circumstances in which organic soil-building and other organic practices are used. These are essentially the same practices that would be required for growing in permanent beds in the soil.
We support the proposals of the Crops Subcommittee majority for prohibiting hydroponics and delineating acceptable practices for organic containers.
Marine materials (Seaweeds and products of seaweeds)
Marine biodiversity is important, and the roles played by marine algae (seaweed) are important to marine biodiversity and ecology. Human threats to marine environments include overfishing, global warming, biological introductions, and pollution. The NOSB should continue its efforts to clarify the identities of species of marine algae used in organic production as well as to develop guidance for the application of the wildcrafting standard to marine algae. Application of scientific names to seaweeds needs to be clarified to ensure protection, and any restrictions need to be justified.
The NOSB must investigate mechanisms for protecting marine ecology from the impacts of over-harvesting marine algae for use in organic products and production. It must also look at natural materials in use in crops and livestock as well as those on the National List. Lastly, the NOSB must protect rockweed (Ascophyllum nodosum) to the extent possible and specifically list it as a prohibited natural.
Seaweeds (marine algae) and products made from them should be allowed as ingredients in organic food, feed to organic livestock, and crop inputs only “when harvested from a designated area that has had no prohibited substance applied to it for a period of 3 years immediately preceding harvest and when harvested in a manner that ensures that such harvesting or gathering will not be destructive to the environment and will sustain the growth and production of the population of the species.”
“Inert” Ingredients in Organic Production
“Inert” ingredients frequently compose as much as 99% of pesticide products. So-called “inert” ingredients are typically not biologically and chemically inert, and are not disclosed to users or others who may be exposed. Due to NOSB scrutiny of active ingredients, “inert” ingredients may be the most hazardous ingredients in pesticide products used in organic production. We urge the NOSB to insist that NOP move forward quickly with implementation of the NOSB recommendations on inert ingredients. Allowing the current lack of movement to persist raises serious compliance issues and threatens the integrity of the USDA organic label.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
