09
May
Take Action: Advocates Call for Strong Organic Mushroom and Pet Food Standards
(Beyond Pesticides, May 8-9, 2024) In its proposal on mushrooms and pet food, the U.S. Department of Agriculture’s (USDA) National Organic Program is following up on recommendations of the National Organic Standards Board (NOSB) to ensure that two areas of organic production are clarified and in compliance with the Organic Foods Production Act (OFPA). The notice raises questions of standards that ultimately grow the organic market while ensuring that the USDA organic label is backed by standards that have integrity and garner the public’s trust. In this spirit, Beyond Pesticides participates in the NOSB review/recommendation process and USDA rulemaking through public comments. [Note: Beyond Pesticides has served on the NOSB for a five-year term (2010-2015) and urges other environmental organization representatives to consider self-nominating for service on the board.] The issues relating to clear standards for mushrooms and pet food have been before the NOSB and in discussion for some time as a part of ongoing efforts to ensure continuous improvement of standards governing the organic sector.
While virtually all in the organic community and industry agree that the USDA proposals are needed and long overdue, Beyond Pesticides points to problems in the proposed rule that need correcting: (i) Re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) Re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources.
>>Tell USDA to ensure that certified organic fungi and pet food are truly organic.Â
In the context of upholding organic integrity and growing the market, Beyond Pesticides offers a perspective that it believes strengthens the value of protecting health and environment through a holistic systems approach to food production and processing—applying the principles and practices to all land management. This contrasts with chemical-intensive farming and land management with its reliance on petrochemical pesticides and fertilizers that contribute to the current existential health, biodiversity, and climate crises.
Mushrooms
Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised of carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards as well. Fungi deserve, and need, their own scope of standards that recognizes their unique biology and fosters consistency in their cultivation and certification.
Additionally, there are already some organic fungal products in the marketplace that are not mushrooms, such as drink powders made from lion’s mane mycelium as well as the fruiting body and mycelium extract dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling but would fit better under a separate fungi scope.
According to the 2021 National Agricultural Statistics Service Organic Survey, commercial organic mushroom production increased from 17 million pounds in the 2010/2011 marketing year to 114 million pounds in the 2022/2023 growing season. In other words, organic mushrooms made up just 2% of total retail market in 2009 and in 2021 rose to 11% of the total market share. This trend is consistent with the 5% increase in total certified organic farms across the United States within the same time period. Not to mention the 13% increase in certified organic commodities in 2021 relative to 2019 numbers, according to the 2021 Organic Survey. Consumers want access to organic food, and to cultivate a robust market tailored regulations must be developed for mushrooms as they defy certain characteristics of other commodities.
Beyond Pesticides makes the following comments: Framing new production standards to include only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for future innovative products to become certified. Conversely, framing new production standards to include all fungi would not only provide a better fit for current organic fungal products but provide ample room for additional markets to develop.
In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. This position is based on the fact that fungi are composed of digested substrate and, as a result, the board said that only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal.
Pet Food
The pet food rule is an effort to bring pet food production and materials standards in line with organic livestock standards, and adding an allowed synthetic amino acid, taurine, to the National List of Allowed and Prohibited Substances. Some pet food manufacturers maintain that the amino acid is necessary to fulfil a macronutrient requirement for cats generally and for dogs during specific periods of their lives.
While Beyond Pesticides supports bringing organic pet food production into conformance with livestock standards when incorporating meat into its products, it disagrees with the NOSB recommendation and USDA’s proposal to allow the use of synthetic taurine for all pet food. Beyond Pesticides maintains that the allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the OPFA, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by a manufacturer, it is difficult to argue that the substance is not available in its natural form. As Nature’s Logic® states on its website:
“Since our foods are made from high levels of animal protein, all Nature’s Logic diets naturally contain sufficient levels of the Omega-3 fatty acids, eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA). They also exceed AAFCO*’s protein amino acid requirements for arginine, histidine, isoleucine leucine, lysine, methionine-cystine, methionine, phenylalanine-tyrosine, phylalanine, taurine, threonine, tryptophan, and valine.”
Therefore, Beyond Pesticides is urging USDA to reject the recommendation to add taurine to the National List for pet food. Note that synthetic taurine has been petitioned and rejected for allowance in baby formula.
Take Action Today! >> Tell USDA to ensure that organic fungi and pet food are truly organic.
Proposed comment to USDA
USDA’s proposed regulations for organic certification of mushrooms and pet food are needed and long overdue, but there are problems that need correcting: (i) Re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) Re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources.
Mushrooms. Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised of carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards. They require their own scope of standards, recognizing their unique biology, which fosters consistency in their cultivation and certification.
There are already organic fungal products in the marketplace that are not mushrooms, but made from mycelium, such as drink powders and dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling, but would fit better under a separate fungi scope. New production standards including only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for innovative products to become certified. Framing new production standards to include all fungi would not only provide a better fit for current organic fungal products, but provide ample room for additional markets to develop.
In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. Since fungi are composed of digested substrate, only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal.
Please modify the proposed mushroom standard to: 1) give fungi—not mushrooms—a separate scope; 2) cover all fungi forms; and 3) require that certified organic fungi be grown on organic substrate.
Pet Food: The pet food rule attempts to bring pet food production and materials standards in line with organic standards. It also adds an allowed synthetic amino acid, taurine, to the National List of Allowed and Prohibited Substances. Some pet food manufacturers maintain that the amino acid is necessary to fulfill a macronutrient requirement for cats and dogs.
I support bringing organic pet food production into conformance with organic standards and incorporating meat into its products. However, I disagree with USDA’s proposal to allow the use of synthetic taurine for all pet food. The allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the Organic Foods Production Act, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by at least one manufacturer—Nature’s Logic®—it is difficult to argue that the substance is not available in its natural form. The original recommendation to add taurine for pet food was made in 2008, and it should be revisited by the NOSB before adding it into the regulations.
I urge USDA to reject the recommendation to add taurine to the National List for pet food.
Thank you.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Source: USDA, Agricultural Marketing Service, 7 CFR Part 205 [Doc. No. AMS–NOP–22–0063] RIN 0581–AE13 National Organic Program; Market Development for Mushrooms and Pet Food, Federal Register, March 11, 2024, pp17322-17338.
This blog post on the push for strong organic standards in mushroom and pet food production highlights critical issues in sustainable agriculture. It’s commendable that Beyond Pesticides is advocating for adherence to robust, science-based standards that align with the original intent of the National Organic Standards Board. This approach not only supports environmental health but also ensures consumer trust in organic labels. However, addressing the unique biological needs of fungi and the specifics of pet nutrition without synthetic additives is crucial for genuine organic certification.
May 8th, 2024 at 6:48 pm