USDA’s organic advisors draw more marks in the sand to guide decisions on products, practices and processes

National Organic Standards Board works from foundation of healthy soil, natural behaviors and whole systems to rule on hydroponics, materials on the national list and biodiversity.

By Greg Bowman

Farmer input valued at NOSB meetings to lend diversity, producer voice

In the course of its three-day meeting, the NOSB reviewed numerous committee reports on items for discussion (no pending action) and on recommendations (items to be voted on during the third day).

They also had heard public comments from 88 scheduled presenters, including agricultural researchers, seed breeders, certification specialists, dairy farmer organization representatives, grain marketers, food processors, organic product lobbyists, food scientists, consumer groups with interests in food and agriculture, organic watchdog groups, fertilizer manufacturers …. and even a few farmers along with approximately 400 written public comments.

“I’d like farmers to know that what they want really matters to us,” said Jeff Moyer. “Writing to us is important, and sending their farm group representatives is good, but what really makes an impact is having farmers present at the meetings to testify to the whole board. That way, we all understand more exactly how our work matters to the people actually growing organic crops and livestock.”

“We’re their reps to the USDA. We value their opinion. If farmers write or give comment in person, it’s extremely valuable,” Moyer emphasized. Farmer input given at the discussion stage of a topic can have the most influence for shaping policy, while comment during the later stage of board voting on a recommendation is more of yes-no choice.

The next meeting of the NOSB will be in the Washington, D.C., area in the first week of November. Officials publish a meeting notice in the Federal Register six weeks before the meetings, triggering a 30-day public comment period. The meeting agenda will be posted some time earlier as an advance alert to recommendations facing a vote and items for discussion.

Contact:
Ms. Valerie Frances, Executive Director
National Organic
Standards Board
USDA-AMS—TMP-NOP
1400 Independence Avenue, SW
Room 4008-So.
Ag Stop 0268
Washington, DC
20250-0268
valerie.frances@usda.gov
phone (202) 720-3252
fax (202) 205–7808
www.ams.usda.gov/nop

Board boots “allowed synthetic” lecithin from list to illustrate intent

“The current board wants to demonstrate that we are serious about removing allowed synthetics from the NOP materials list,” said Jeff Moyer, board chair. “Whenever possible, we want organic products to replace what’s not organic, but has been on the list to help the organic sector move forward.”

The battle over lecithin at the May meeting is a good case in point. The product is a common ingredient in processed food, used as a natural emulsifier, and usually made from soy. It comes in dozens of specific formulations to perform many functions, such as to give the right mouth feel or to keep chocolate from separating in candy bars.

An earlier attempt to have it removed from the allowed list was denied by the NOSB because the petitioner couldn’t show that organic lecithin was available at that time in the variety of forms to make it a practical option for food processors.

This time around, the petitioner marshaled testimony that made the case and the board approved—even though the organic products may cost more.

“Cost can’t be our main concern,” Moyer explained, although the board doesn’t want to change the rules in a way that will break a company that entered a market on good faith that an allowed synthetic product was OK to use. The lecithin switch will happen over the next year or two.

Moyer explained that the board wants to make clear that the materials list (allowed synthetics and banned natural products) is based on organic integrity, not economic expediency. “Once you allow that argument, there’s no end of special considerations — and no incentive to do the hard work needed to develop the products, crops and systems that the organic standard intends.”

In written comments received and testimony given during the recent session, Moyer said, “We learned that consumers didn’t want lecithin on the list if there was an alternative, and the majority of processors said they could live with the change, given the diversity of organic lecithin formulations now on the market.”

Made most often and most efficiently from soy oil, lecithin can be made from any oilseed, but possibly at a higher price. Its widespread use combined with its soy origin makes it a target for soy-averse shoppers, and anti-GMO consumer sentiment in Europe has further increased demand for new ways to get the food processing values of lecithin from formulations.

It’s worth noting that transnational agribusiness superpower Cargill announced in January that it will produce a non-GMO, non-soy lecithin, with Ukrainian sunflowers processed in an Italian facility under strict segregation from soy and canola products.

~GB

Determined to get beyond the long-simmering access to pasture rule for organic dairy animals, the nation’s highest organic advisory board continued at its May 2009 meeting to lay a foundation of “bright-line” principles to define USDA organic farming, food and products.

Current members of the National Organic Standards Board (NOSB) have developed a good working relationship in their 18 months together, according to 2009 board chair Jeff Moyer, farm director at the Rodale Institute.

The board dealt with a number of items on its “allowed products” list from food ingredients to field water pH treatments to livestock health aids (some yesses and some nos), agricultural biodiversity guidelines (yes), hydroponics (no) and animal welfare (stay tuned).

One principle invoked in various forms was the necessity to recognize the essential biological role of an organism in its natural form. Productivity, profitability and expedience have to be secondary considerations if the board is to succeed in aligning industry with the national standard, Moyer said.

Good examples are the board’s decision on the status of soil-less growing systems, i.e. hydroponics, and its wrestling with the presence of methionine on the allowed synthetics list.

Soil plants in soil

As part of a proposed Greenhouse Production Standard due to be considered at the November 2009 meeting, the board unanimously agreed with its crops committee that organic food production is all about soil—its health, the microorganisms it puts into root contact with plants and its management for continuous improvement. In hydroponic food production, plants usually grown in soil are rather grown with their roots in nutrient-enriched water. Plant roots are merely misted in aeroponic (air-based) systems.

While these systems have a number of attractive features, they should not be considered eligible for organic certification. “Organic is not an energy-efficiency standard, and it’s not a climate-change standard, as important as those parts of sustainable agriculture are,” Moyer explained. “Organic is, in part, a soil health standard, which gives us a focal point for our work and which also excludes other kinds of systems from certification, as interesting as they may seem.”

Other greenhouse items: Just as terrestrial plants need to be grown in soil to be true to their biological context, the board will consider separately the status of aquatic plants and non-vascular species, such as mushrooms. Container production using compost—which the committee says can maintain “proper soil biology” and support similar “beneficial symbiotic ecological relationships”—is under study to determine proper composition, handling and recycling of this medium.

Mark Elzinga, Elzinga & Hoeksema Greenhouses, Kalamazoo, Michigan. Photo Courtesy of Elzinga & Hoeksema Greenhouses

Moyer emphasized the board’s commitment to making as direct a connection as possible between food and healthy, biologically active and always improving soil. “If it’s not in the soil, it’s not in the food and it’s not in you,” he said to explain the difference between growing crops in soil and under hydroponic conditions. “You can’t eat soil, but if you could, you would want the whole biological menu of micro- and macro-nutrients, not just the fast-food reduction of NPK soup.”

Poultry adjustments ahead

The board’s methionine task force reported at the May meeting that it was disappointed with the lack of success in finding an organic source for this essential amino acid, some eight years after it reluctantly agreed to accept this product on its materials list. At the time, the committee said:

Although there may be limitations in the current supply of diverse organic protein sources, a requirement for natural, non-GMO sources of methionine will stimulate market development in organic and approved feedstuffs.

Corn breeding efforts to achieve a high-methionine variety have brought unsatisfactory yields. The board anticipates removing the ingredient on its list because chickens do not need synthetic lecithin to survive, and its use as an artificial feed supplement since poultry began to be confined is primarily to boost the rate of growth and egg production. Systems which include high-quality organic feed and lots of outdoor access to high-quality pasture can still be productive, just at a lower level.

“Yes, organic layers may not produce as many eggs as convention flocks, but artificially supported production can’t be the standard. Organic dairy producers with grass-based herds that honor the cow’s natural environment may also experience relatively lower milk production,” Moyer pointed out.

“Regardless of economic impact, our job is to improve practices within organics to have them conform more closely over time to the plant-soil connection in crops and to natural behaviors and dietary range in livestock,” he said.

Organic Cornish cross chickens.
Photo courtesy Sonday Produce, LLC

These principles will be the crux of much of the coming board discussions and committee work on raising bivalves (aquatic species, such as oysters or shrimp), a general animal welfare standard for all species, organic beekeeping guidelines, and then a comprehensive exploration of organic poultry.

As the second highest market sector for organic livestock (behind dairy), poultry practices have stayed “under the radar” to a large degree. Areas of inquiry will be in stocking density, access to pasture as a significant aspect of production, maintaining bird health and opportunity for expressing natural behaviors (such as perching and foraging).

Grazing standard update: The final outcome of the long-sought and hard-fought effort (19,000 comments were submitted earlier this year, most favoring a stricter standard) has to await the completion of the USDA rule-making function, additional legal examination, then public comment and a final NOP decision. “Maybe a year” is about as exact as anyone dares to be in predicting implementation of a final rule in dairy grazing. Its broad outlines include that cattle be actively grazing whenever possible, but at least 120 days per year, and that they derive at least 30 percent (dry matter basis) of their nutritional intake from pasture/forage crop grazing.

Guidance now, discussion later

The board approved a “guidance” proposal for more consistent and rigorous inclusion of biological diversity in organic agriculture. The guidance document states:

…biological diversity (biodiversity) includes variety in all forms of life, from bacteria and fungi to grasses, ferns, trees, insects, and mammals. It encompasses the diversity found at all levels of organization, from genetic differences between individuals and populations (groups of related individuals) to the types of natural communities (groups of interacting species) found in a particular area. Biodiversity also includes the full range of natural processes upon which life depends, such as nutrient cycling, carbon and nitrogen fixation, predation, symbiosis and natural succession.

This move follows several affirmations to strengthen biodiversity provisions since 2005. The guidance calls for application of biodiversity conservation considerations in two broad areas:

Materials review by the NOSB, using three areas of inquiry: Adverse impacts, organic in formation or essential for organic production, and compatibility with organic production.
Development and implementation of an Organic System Plan (OSP): Required inclusion of biodiversity in a farm’s plan, inspector training, accredited certifier adoption of NOP biodiversity requirements (to even out current disparity in attention to these provisions), and NOP training of certifiers and revision of the program certifier audit criteria to include biodiversity.

Nanotechnology comments requested: Research by the NOSB materials committee found widespread current use of ultra-micro-particles sized at the atomic, molecular and macromolecular level. Just for reference, a nanometer (nm) is one billionth of a meter. A sheet of paper is about 100,000 nm thick; a single gold atom is about a third of an nm in diameter.

Current uses include food packaging to improve gas barrier properties, food ingredients to improve nutritional benefits, anti-bacterial properties and improved mouth feel. The committee report held up potential benefits from the unique properties of nanoparticles, but raised these cautions about them:

They may be more reactive, conductive, and stronger than larger particles of the same material. Concern for these changes include but are not limited to, changes in intake via dermal, respiratory, or oral routes, the ability of the particle to cross biological membranes of individual cells and potentially the blood-brain barrier, increased occupational exposure regarding worker safety, increased risk to the environment via multiple pathways of entry during manufacturing, transport, use or disposal, and decreases in the rate of biodegradation.

Despite bans on humanly engineered nano-particles in products certified by the Soil Association (in the UK) and by organic certifiers in Australia, the committee observed the likely increased use of nanotechnology in food production and handling.

The board agreed to seek public comment on the compatibility of nanotechnology with the principles of organic production and handling. See the end of sidebar "Farmer input valued at NOSB meetings to lend diversity, producer voice" for contact information.)

Reflecting on the nano-discussion, Moyer noted that while nanoparticles occur incidentally already (for example, in milk homogenization or sea spray), engineering nano-bits of substances could cause them to behave very differently. The law setting up the National Organic Program excludes genetic manipulation, but doesn’t seem to have exclusions for most forms of nanotechnology.

“We haven’t adopted the precautionary principle as a board, so we really don’t have a relevant tool that addresses the mix of risk and dangers we see in nanotechnology,” Moyer said.

“We’ll do our best to listen and learn from the organic community, and use the principles of healthy soil, natural behaviors and whole systems in this new phase of agriculture, food and personal care products.”

Greg Bowman is communications manager at the Rodale Institute.