21
Oct
Delay in Farm Bill Passage Undermines Advocates Call for Universal Adoption of Stronger Organic Standards
(Beyond Pesticides, October 21, 2024) To solve the existential crises of climate change, biodiversity loss, and human disease, Beyond Pesticides is urging that organic agriculture grows—over the next decade becoming universally adopted for all agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.
The OCCSP will disappear in 2025 unless Congress passes a five-year Farm Bill with funding or includes sufficient funding in a stopgap bill this fall.
Chemical-intensive agriculture, with its dependence on petrochemical pesticides and fertilizers, is a major contributor to the existential health and environmental crises and contamination of air, land, and water. Organic agriculture, certified and labeled in compliance with the Organic Foods Production Act (OFPA) provides:
- A definition of organic agriculture that defines health-biodiversity-climate friendly practices;
- A requirement for a systems plan that establishes baseline management practices to create resiliency and prevent pests;
- A rigorous process for an allowed/prohibited substances list with a mechanism for incorporating real-time data on hazards and alternatives into reevaluation of allowed list;
- A third-party certification and enforcement system;
- A process for public participation to ensure a feedback loop for continuous improvement; and,
- Funding to ensure elements are carried out in a robust way.
While environmental and public health advocates say it is essential for organic to grow to solve the existential health, biodiversity, and climate crises, Beyond Pesticides, at the same time, advocates for continuous improvement of organic standards. Both statements before the National Organic Standards Board (NOSB), October 15, 2024, of Jay Feldman, executive director, and Terry Shistar, PhD, board member, of Beyond Pesticides are below.
[Beyond Pesticides thanks all those who participated in the public comment period before the NOSB by submitting comments through Beyond Pesticides’ Keep Organic Strong program.]
Statement of Jay Feldman
The NOSB was established to protect and enhance the integrity of the organic label. integrity is operationalized through continuous improvement, which is key to the sunset process for synthetic materials on National List of Allowed and Prohibited Substances AND through your oversight of USDA’s National Organic Program.
It is in this spirit that we offer our extensive written comments
We look to organic to lead the shift away from petrochemical pesticides and fertilizers with urgency—to confront the existential health, biodiversity, and climate crises of the day. We don’t want cancer in our families or the long list of pesticide-induced illnesses associated with chemicals used in chemical-intensive agriculture—chemicals that end up in our air, water, soil, and food.
However, this shift will only happen if we as an organic community and an organic marketplace move quickly and forcefully to differentiate organic from all the destructive agricultural practices that contribute to the existential crises.
It wasn’t hard to predict that PFAS would end up contaminating farmland. Same for DDT. Contaminated biosolid fertilizer is a cheap waste product, but the externalities of cleanup and remediation, if that is even possible, are certainly not cheap. Neither is the treatment of resulting illnesses and environmental disasters. We had the foresight to prohibit biosolids in organic production.
Of course, the problem extends beyond biosolids to compost. We urge the NOSB to reopen the workplan item on contaminated inputs that is currently on hold after the issuance of a 2014 document on the issue—when I was on the NOSB.
But first, we must not further weaken the standard or exacerbate the problem. As important as compost is to organic, only synthetic materials that are specifically added to the National List should be allowed in compost. More persistent contaminants in “compost feedstocks” awill certainly be found. The petition from BPI should be denied. Thank you Crops Subcommittee for recommending against and rejecting some notion of de minimis or negligible risk assumption foreign to OFPA.
With this same thinking, organic must lead on eliminating plastics. Plastic Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. Make elimination of plastic in organic a research priority.
And, we must push harder to replace nonorganic ingredients more broadly like the proposals to delist dried orange pulp, which is available in organic form.
And, Organic seeds and starts must become a priority, given their limited availability, .
Thank you.
Statement of Terry Shistar, PhD
We are focused on three intertwined existential crises in which pesticides play a role:[1] Climate change, human illness, and biodiversity decline.
I will make six points:
1. Organic practices can and should play a major role in addressing all of these:
- Organic practices can mitigate climate change.
- The Organic Foods Production Act (OFPA) provides a framework for eliminating toxic chemicals in organic production and processing.
- Protecting biodiversity is central to the NOP definition of “organic production.”
Some challenges remain before organic can be the answer.
2. Organic production can mitigate climate change only if it is soil-based because soil-building practices help sequester carbon in the soil. The NOSB must take a strong stance against hydroponic and container systems that do not build soil biology.[2]
3. Although the NOSB does a good job of keeping toxic active ingredients out of organic production, the so-called “inert” ingredients make up the largest part of formulations and pose greater risks.
4. The Materials Subcommittee has proposed two alternatives [at link, search on “inert ingredients”]—one of which would address this problem and another that would not. The NOSB should recommend only Option 1, which meets the requirements of OFPA, and not forward the recommendation for Option 2 to NOP. Option 1 relies on EPA’s decision that residues in food do not pose a risk and ignores risks to farmworkers and the environment. [See “Inert” Ingredients Used in Organic Production.]
5. Another avenue through which toxic chemicals can enter organic food—and by which organic processing fails to promote the health and environmental precepts of organic—is the allowance of non-organic ingredients through listing on §606. There is no reason that organic production cannot meet the needs for these ingredients—if processors are not allowed to use cheaper nonorganic ingredients. Besides removing potential toxic exposures to consumers, elimination of these nonorganic ingredients would avoid the support of chemical-intensive agriculture through their use in organic products.
The NOSB should also work towards elimination of toxic chemicals—such as plastics, PFAS, and bisphenols—in food packaging.
6. The NOSB has made strides towards protecting biodiversity in materials reviews and policies, but needs to address:
- Implementation of biodiversity and marine materials policies
- Phasing out the use of plastics
Thank you.
Letter to the U.S. Congress
Now that the Farm Bill and its extension have expired on September 30, I am reaching out because I am concerned about gaps in funding for programs that are essential for organic farms and businesses.
To solve the existential crises of climate change, biodiversity loss, and human disease, it is critical that organic agriculture grow—eventually becoming the standard for agriculture. However, with the expiration of the Farm Bill on September 30, 2023, and subsequent one-year extension, core organic programs including the Organic Certification Cost Share Program (OCCSP) will expire without Congressional action. This leaves thousands of organic farmers with a huge net increase in their annual certification costs—and presents a disincentive for others to make the transition to organic.
Organic agriculture also promotes economic growth by creating market opportunities for farmers, while supporting rural development through practices that protect natural resources and boost community resilience. I am writing to urge you to pass a five-year Farm Bill before the end of this year. I support the Farm Bill framework put forward by Senate Agriculture Committee Chairwoman Stabenow, which provides funding for essential organic programs and provides a foundation so organic agriculture can thrive. However, as this proposal moves forward, do not accept any legislative language that limit pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed.
If Congress does not renew the five-year Farm Bill, it is imperative that the Farm Bill extension include funding for the Organic Certification Cost Share Program (OCCSP). This essential program provides a partial reimbursement to defray the cost of organic certification.
The cost of certification is one of the biggest challenges faced by organic farmers. Without Congressional action, this program will expire, leaving thousands of organic farmers with a huge net increase in their annual certification costs. A lapse or reduction in funding, will have a big impact on farmers’ ability to stay certified, and would come at a time when most operations are seeing significant increases in certification costs to keep up with inflation and new requirements to strengthen enforcement of organic rules.
Level funding of $8 million, as was provided last year, is no longer enough funding and would result in cuts to this essential program! The cost of the program has risen due to increasing certification costs and as more operations are getting certified. Congress needs to provide at least $11 million for the OCCSP in the Farm Bill extension (or through an ad hoc emergency assistance package).
In addition to the Organic Certification Cost Share Program, please include provisions to reauthorize the Organic Agriculture Research and Extension Program (OREI), and fund the Organic Data Initiative and the Organic Certification Trade and Tracking Program (OCTT), which is necessary for organic fraud prevention activities. Like the OCCSP, the Organic Data Initiative and the Organic Certification Trade and Tracking Program are ‘orphan’ programs. Essential funding for these programs will lapse with devastating consequences unless there is Congressional action.
Please make sure organic programs do not lapse this fall.
Thank you.
On the necessity, viability, productivity, and profitability of organic landl management, attend the 41st National Forum: Imperatives for a Sustainable Future—Reversing the existential crises of pesticide-induced illness, biodiversity collapse, and the climate emergency.
[1] Graphs from: https://www.climate.gov/news-features/understanding-climate/climate-change-global-temperature; https://gco.iarc.fr/overtime/en/dataviz/trends?populations=840&sexes=1_2&types=0&multiple_populations=0&cancers=0_14&mode=cancer&multiple_cancers=1; https://www.ipbes.net/news/global-assessment-summary-policymakers-final-version-now-available
[2] Picture from: https://beyondpesticides.org/dailynewsblog/2024/08/study-documents-value-of-soil-microbiome-nurtured-in-organic-farming-harmed-by-chemical-intensive-ag/
