Organics in the News

Conventional excellence tromped by even standard organic
While critics of organic agriculture like to question the safety of manure, the truth is organic producers are held to a much stricter standard on everything from traceability to manure usagethan non-organic producers.

By James A. Riddle

Organics in the News

Editor’s NOTE:

Certified organic farming enjoys success – and challenges – like never before thanks to surging consumer demand, USDA-regulated standards, and increasing attention to how farming impacts our land, water, communities and human health.

We’ve asked Jim Riddle to bring his perspective to our e-pages as a voice from the progressive center of this dynamic food and farming sector. “Organics in the News” will be an occasional series where Riddle shares his insights in the context of current events.

James A. (Jim) Riddle has been an organic farmer, gardener, inspector, educator, policy analyst, author, and consumer. He was founding chair of the Independent Organic Inspectors Association, (IOIA), and co-author of the IFOAM/IOIA International Organic Inspection Manual.

Riddle has helped train hundreds of organic inspectors throughout the world. Riddle serves as vice-chair of the National Organic Standards Board, which advises the USDA on organic agriculture policies and regulations. In 2003, Jim was appointed Endowed Chair of Agricultural Systems at the University of Minnesota.

He serves as an organic policy specialist for NewFarm.org.

October 14, 2004: There has been a lot of talk lately about the safety of organic food. It is important to note that organic foods must meet the same state and federal food safety requirements as non-organic foods. In addition, the National Organic Program (NOP) Final Rule mandates certified organic producers and handlers meet requirements that have food safety implications. Producers and handlers of non-organic products do not have to meet such requirements.

For example, certified organic operations must comply with strict requirements for traceability; restrictions on the use of animal manure and compost; no contact with prohibited toxic substances; and significantly lower residue levels than allowed for non-organic foods.

NOP requirements which have food safety implications can be grouped into five categories: 1) records and traceability; 2) crop management; 3) livestock management; 4) processing and handling; and 5) residue tolerances.

1. Records and traceability

Traceability is a fundamental requirement for organic certification. All organic operations are required to maintain records of their production and handling activities.

Such records must:

  1. Be adapted to the particular business that the operation is conducting;
  2. Fully disclose all activities and transactions of the operation in sufficient detail as to be readily understood and audited;
  3. Be maintained for not less than 5 years beyond their creation; and
  4. Be sufficient to demonstrate compliance with OFPA and the regulations.

In addition, NOP section 205.236.c requires that all organic livestock operations maintain records “sufficient to preserve the identity of all organically managed animals and edible and non-edible animal products produced on the operation.”

Every certified organic operation must make its records available for inspection and copying during normal business hours by authorized representatives of the USDA, the applicable State official, and the certifying agent.

This means that records kept by organic producers and handlers must verify compliance with the organic regulation, and provide traceability. For instance, an organic livestock producer must track all animals, including the source(s) of the animals; the sources and quantities of feed; all medications; and all products produced and sold. This requirement goes well beyond the requirements for non-organic producers, as evidenced by last winter’s case of BSE, where 450 calves were slaughtered because one of the calves was from a BSE-positive cow, but there was no traceability to connect the calf to the cow.

2. Crop Management

In order to be certified organic, land must have had no prohibited substances applied to it for a period of 3 years immediately preceding harvest of the organic crop. Prohibited substances include toxic fertilizers, pesticides, and genetically engineered organisms (excluded methods). Non-use of toxic substances avoids the presence of toxic residues in organic foods.

"The restrictions on the application of raw animal manure for organic producers go well beyond those imposed on non-organic producers."
Certified land must have distinct boundaries and buffer zones such as runoff diversions to prevent the unintended application of a prohibited substance to the organic crop, or contact with a prohibited substance applied to adjoining land that is not under organic management. Certified farmers and handlers must prevent prohibited substances from coming into contact with organic products.

Organic producers must manage plant and animal materials to maintain or improve the soil in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.

Raw animal manure must be composted unless it is:

    (i) Applied to land used for a crop not intended for human consumption;
    (ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or
    (iii) Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles.

The restrictions on the application of raw animal manure for organic producers go well beyond those imposed on non-organic producers. While all producers are required to follow certain nutrient management requirements, there are no restrictions on when or how raw manure is applied to non-organic cropland linked to projected harvest of the crop. These restrictions help prevent certified organic products from coming into contact with microbial contaminants.

A recent study of microbial contamination of certified organic, self-proclaimed “organic,” and conventional produce by Mukherjee, Speh, Dyck, and Diez-Gonzalez of the University of Minnesota, published in the Journal of Food Protection, concluded that “the E.coli prevalence in certified organic produce was not statistically different from that in conventional samples.”

Organic producers must not use sewage sludge or arsenic compounds. Arsenic compounds, commonly used in non-organic poultry feed as growth promoters and parasiticides, are linked to high incidence of cancer and other illnesses in areas where poultry litter containing arsenic is used as fertilizer.

3. Livestock Management

Organic livestock producers must not feed mammalian or poultry slaughter by-products to mammals or poultry. The feeding of manure is also prohibited. While the FDA banned the feeding of cattle brain and spinal tissue to cattle in 1997, and recently banned the feeding of blood, blood products, human food waste, and poultry litter, it still allows the following materials to be fed to non-organic cattle:

  • Gelatin (rendered from the hooves of cattle and other species);
  • Fats, oils, grease, and tallow (from cattle and other species);
  • Poultry and poultry by-products;
  • Rendered pork protein; and
  • Rendered horse protein.

None of these may be fed to organic cattle or other organic livestock, including organic poultry.

In order to produce organic livestock feed, feed mills must be inspected and certified. If they produce both organic and non-organic feed, they must implement procedures, documented with written records, to prevent the commingling of organic and non-organic feed.

Organic feed mills must prevent the contamination of organic feed with antibiotics, hormones, slaughter by-products, and insecticides, which may be added to non-organic rations. They must also ensure that rodenticides and insecticides used in the facility do not contaminate organic feed or packaging.

Organic livestock must be slaughtered in certified organic slaughter facilities. As such, the facilities must slaughter organic animals when all equipment is clean and empty. There must be no chance of commingling organic with non-organic meat, or contaminating organic meat with prohibited materials. Records must be maintained of all organic slaughter activities and steps taken to protect organic integrity.

4. Processing and Handling

There are a number of measures that must be implemented by organic processors and handlers that exceed the requirements imposed on handlers of non-organic products. For instance, organic handlers must use non-toxic management practices to prevent pests, including but not limited to removal of pest habitat, food sources, and breeding areas; prevention of access to processing facilities; and management of environmental factors, such as temperature, light, humidity, atmosphere, and air circulation, to prevent pest reproduction.

An organic handler who applies a nonsynthetic or synthetic substance to control pests must prevent the substance from coming into contact with organic products, ingredients, or packaging. The operator must also update the operation’s organic handling plan to reflect the use of such substances and methods of application, and include a list of all measures taken to prevent the substance from coming into contact of organic products, ingredients, or packaging.

Organic handlers must implement measures to prevent the commingling of organic and nonorganic products and protect organic products and packaging materials from having contact with prohibited substances.

The following are prohibited for use in organic handling: packaging materials, storage containers, or bins that contain synthetic fungicides, preservatives, or fumigants; and the use or reuse of any bag or container that has been in contact with any substance that might compromise the integrity of an organically produced product or ingredient. Such substances and materials are allowed for non-organic food processing.

5. Residue Tolerances

Certifying agents may require pre-harvest or post-harvest testing of any agricultural input or organic product, when there is reason to believe that the input or product has come into contact with a prohibited substance or has been produced using excluded methods (genetic engineering).

If residue tests detect prohibited substances at levels greater than 5 percent of the Environmental Protection Agency’s tolerance for the specific substance detected or unavoidable residual environmental contamination, the agricultural product must not be sold as organic.

"There are many provisions that require organic crop and livestock producers and handling operations to reduce food safety risks beyond those required of non-organic producers and handlers."

Though the NOP regulation is a process- rather than product-based standard, there are many provisions that require organic crop and livestock producers and handling operations to reduce food safety risks beyond those required of non-organic producers and handlers. These include strict requirements for traceability; restrictions on the use of animal manure and compost; no contact with prohibited toxic substances; and significantly lower residue levels than allowed for non-organic foods.

Jim Riddle serves as vice-chair of the National Organic Standards Board, which advises the USDA on organic agriculture policies and regulations. He has been an organic farmer, gardener, inspector, educator, policy analyst, author, and consumer.