How are Organic Farming Inputs Evaluated

How are Organic Farming Inputs Evaluated?

Jim Ferguson
Horticultural Sciences Department, University of Florida, Gainesville, Fla.

How does a certified organic farmer determine which fertilizers, pesticides, and other inputs can be used legally? The answer is complicated not only because there are different but somewhat complementary sources of allowed, regulated, and prohibited materials but also because the rule making process is ongoing. That is, what’s allowed within the US may not be allowed internationally and there may be some disagreement even within the US on certain inputs. The bottom line is that farmers, county agents, consultants and others need to understand the process for evaluation of organic farming inputs and frequently update their information. Our purpose here is to not to list these inputs but to clarify who evaluates these materials and how to obtain this information.

Within the U.S. there are two major sources of information about organic farming inputs: 1) the USDA Generic National List within the National Organic Program and 2) the generic materials list and the brand name products list published by the Organic Materials Review Institute (OMRI). The National List is approved by the Secretary of Agriculture with advice by a 15-member National Organic Standards Board (NOSB), appointed for five-year terms. The NOSB also advises the Secretary of Agriculture on other aspects of implementing the national organic program. The current board is comprised of four farmers/growers, two handlers/processors, one retailer, one scientist, three consumer/public interest advocates, three environmentalists, and one certifying agent that sit on various committees, including those on compliance, accreditation, certification, handling, materials, livestock and crops, policy and international issues. This organizational structure grew out of the Organic Foods Production Act of 1990, part of the 1990 Farm Bill. A "sunset" provision originally provided for materials to remain on this list for 5 years but this time could be reduced. Therefore, this is more of a list in process, subject to petitions and rule changes and will be continually revised.

The National List contains both synthetic and nonsynthetic materials that can be used in organic production. For example, synthetic chlorine materials can be used but chlorine residues in water cannot exceed the maximum residual disinfectant limit under the Safe Drinking Water Act (10ppm). Nonsynthetic materials like ash from burning manure and tobacco dust (nicotine sulfate) cannot be used. Allowed materials can be used as needed. Regulated materials like herbicides containing acetic acid, clove oil, and thyme oil, can also be used, pending approval by the relevant certifying agency and prohibited materials like genetically modified organisms (gmos) can not be used. In many respects the National List is a primary or generic list, identifying the type of materials that can be used like composted manure, elemental sulfur, and mulches but does not contain brand name products or manufacturers. This is where OMRI comes in.

OMRI is a 501(c)(3) nonprofit organization that has no official connection with the USDA National Organic Program. However, OMRI reviews and approves brand name materials for use in organic production, processing, and handling according to the standards established under the National Organic Program. This brand name, third-party review is conducted by an independent review panel that evaluates a product’s compliance with the generic National List of the National Organic Program. Approved products are listed in crop, livestock, and processing categories. Approval by OMRI "assures their suitability for use in certified organic production," and is probably the most convenient list for growers to use. However, recent EPA public notices (March 5, 2003) provide guidelines for pesticide manufacturers to label their products for organic use without going through the OMRI process if the pesticide ingredients meet National Organic Program standards. Accordingly, if a product is not listed by OMRI, it may still be allowed under the National Organic Program.

Note also that both the National Organic List and the OMRI list evaluate materials primarily for their ingredients or constituents but not for their efficacy. OMRI also evaluates products based on information provided by the supplier and does not claim to guarantee product analysis or registration use as a pesticide for example. That is, a fertilizer product may be approved for use in organic fruit and vegetable production but may not provide sufficient nutrients for adequate plant growth and fruit production. Furthermore, such materials may not be the best material to use in terms of nutrient overloading and leaching in specific soil types.

The National List can be accessed by doing an internet search for the "National Organic Program" or at http://www.ams.usda.gov/nop/NOP/standards/ListReg.html and is free. The OMRI list is also listed at http://www.omri.org/ . However, this is only a partial list. Complete OMRI lists can be obtained by subscribing to these OMRI lists and updates for subscription fees ranging from $50 (farmer) to $200 (business). The OMRI lists are also copyrighted and therefore cannot be copied, requiring farmers, county agents, and other agricultural professionals to subscribe to obtain their own copies. Costs for reviewing materials for the OMRI list are based on gross company sales and the type of product such as composts, EPA registered pesticide, processing aids, etc.

International organic standards may differ from US national organic standards and those exporting organic produce should become familiar with the standards of the International Federation of Organic Agriculture Movements, the European Union, the International Federation of Organic Agriculture Movements, Canadian Organic Standards, and Japanese Organic Standards. The International Federation of Organic Agriculture Movements (IFOAM), with headquarters in Germany, establishes international standards, accreditation procedures and policies (http://www.ifoam.org/) and is more or less an international organic farming lobbying group, comparable to the Organic Trade Association within the US.

The European Retail Parties Good Agricultural Practices (EUREPGAP) is a global partnership that establishes documents, standards and a verification framework for fruit, vegetable, ornamental producers and others.

The Japanese Agricultural Standards (JAS), formulated by the the Japanese Ministry of Agriculture, Food and Fisheries recognizes USDA's national organic standards for the production, handling and processing of plant-based organic agricultural products. However, JAS standards do not allow some materials permitted under the USDA standards like alkili-extracted humic acid, lignin sulfonate and potassium bicarbonate, used in raw or processed organic food exported to Japan. On the other hand, in the past, JAS standards allow GMOs in some fertilizers and soil inputs in materials, but prohibits the use of GMO seeds and seedlings, pest control materials, and processing aids. Given the high demand for organic foods and drinks in Japan, the number of JAS approved certification agencies has increased from 30 in 2001 to over 130 in 2002. As organic sales have increased, so have the number and complexity of organic farming standards, regulations, rules and certifying agencies. Fortunately, groups like OneCert at http://www.onecert.net/ocstandards.htm have emerged that attempt to summarize difference US and international standards, including US National Organic Program, European Regulations, Japan Agricultural Standard, Quebec Organic Reference Standards, Bio Suisse Standards, IFOAM Basic Standards and others.

Another complicating factor is that according to National Organic Program Rules, certifying agents and their inspectors can no longer act in a consulting role. This will create situations in which a grower will be informed of failure to comply with a particular area of the National Organic Program, but cannot be advised, either by the inspector or certifier, on how to fix it. All inspectors and certifiers are allowed to do is to refer applicants to consultants, Cooperative Extension Agents, or other organic farming outreach and educational agencies that are not directly connected with organic certifying agencies. This obviously creates a demand, a liability and a need for extension agents to become more knowledgeable about complex organic farming standards.

As national and international organic production and markets increase, organic farmers, packing houses, processors will have to become more knowledgeable about organic farming standards. When pesticide regulations become more complex, large farming enterprises, corporations and land grant institutions hired pesticide coordination officers. This may also be the trend in organic farming.